ESWET Position Papers, Letters, Answers to Consultations


Taxonomy: Should facts guide the EU Commission and the European
Parliament? What to do after recycling with residual waste?

All waste handling must follow the waste hierarchy: Avoid-Reuse-Recycle-Recover-Dispose. But since some waste cannot or should not be recycled, Waste-to-Energy (WtE) is responsible for closing the "toxic loophole" of pollutant recycling.

Who wants to recycle persistent organic pollutants (POPs) from some plastic waste into plastic toys? Who wants to turn arsenic that was used in wood-preservative (chromated copper arsenate) in a compost for food crops?
This is exactly what the Parliament will achieve if the role of WtE is not recognised as a necessary step to avoid spreading pollutants.

Read the full article:

Author: Patrick Clerens, ESWET Secretary General


Waste-to-Energy’s contribution to the “Long-term EU greenhouse gas emissions reductions strategy”

This position paper, jointly issued by the European associations ESWET and CEWEP, outlines the GHG emissions savings potential of Waste-to-Energy and lays down policy recommendations in the areas of waste, energy, climate, infrastructure and research and innovation to achieve this potential. For instance, it is explained how, with proper waste management in place, far more than 200 million tonnes of CO2 eq can be avoided annually.

Full document available:



EU Public consultation addressing the interface between chemical, product and waste legislation.

ESWET – European Suppliers of Waste to Energy Technology – calls upon the EU to amend its legislation to facilitate the uptake of secondary raw materials in safe applications. 

Click here to read the full response of ESWET to the public consultation. 

Brussels, 29 October 2018 - The current review of the EU products, chemicals, and waste legislation occurs in a context of more and more unsustainable use of primary raw materials. Among other alarming signals, the recent OECD’s Global Material Resource Outlook to 2060 foresees the world’s consumption of primary raw materials to nearly double by 2060.

Approximately 20 million tonnes of incinerator bottom ashes (IBA) are produced in the EU annually. Due to a lack of incentives and/or harmonisation at the EU level, only a few applications are considered in a limited number of Member States while the opportunities to manufacture new products from these residues could be much higher.

A different approach to residues, including IBA, could offset the excess use of primary raw materials such as sand and gravel, which greatly exceeds natural renewal rates. This observation is valid not only for residues from incineration but for many other waste streams containing substances of concern.

Therefore, ESWET suggests adopting a more subtle approach, taking particular account of the end-use of the material in addition to its intrinsic hazardous property. Such an approach would allow much more materials to re-enter into the “loop” while protecting public health and the environment.

In the context of the Public consultation launched by the European Commission ESWET would like to insist on four key messages:

1)    Substances of concern

A broad scope for substances of concern is preferable, provided that an information system for products manufactured inside and outside of the EU takes into account the constraints of waste management. It should, therefore, be the responsibility of the waste producer to provide information regarding the presence of substances of concern. Such information should moreover be handy in order to facilitate the adequate treatment of the waste.

2)    Substances of concern in recycled materials

An adequate level of degradation has to be expected from secondary raw materials. Eco-design, Enhanced Producer Responsibility or other voluntary methods of environmental performance certification should allow, on the basis of a risk assessment, for the use of secondary raw materials in new products even if they contain chemicals no longer permitted in primary raw materials.

3)    End-of-waste

Harmonisation of end-of-waste rules should be sought for additional waste streams. In this respect, the principle that REACH applies for any substance, mixture or article that ceases to be waste should be softened in order to foster the recycling of waste that does not pose unacceptable risks. Should no end-of-waste rules be elaborated for ashes and slag, product legislation should serve as a basis for determining whether or not a substance, mixture or article ceases to be waste.

4)    Classification of waste

In view of protecting public health and the environment, current rules on the classification of waste, based on the List of Waste (LoW) as well as on their intrinsic properties, should be maintained. However, these rules should be supplemented by a second step based on a risk assessment, taking into account, on one hand, the intrinsic properties of the waste but also exposure (risk = danger x exposure). Such rules should be enacted at the EU-level in order to ensure a level playing field in the evaluation.

Bioavailability/bioaccessibility of substances contained in the waste could be used to assess exposure, and, hence, risk. However, to date, these concepts are neither defined nor standardised and do not cover all exposure pathways in all cases. Therefore, risk should be assessed for each category of waste based on the intended use.



ESWET response to the EC Public Consultation on the Strategy for Long-Term EU Greenhouse Gas Emissions Reductions


In March 2018, the European Council and the European Parliament invited the European Commission to present a strategy for long-term EU greenhouse gas (GHG) emissions reductions in line with the commitment made in the Paris Agreement to formulate such strategy.

The EU’s current objective is to reduce emissions by 80-95% by 2050 compared to 1990 levels.

In this context, the Commission launched earlier this year a public consultation for stakeholders, companies, and the general public from all sectors of the EU economy and society to include their visions and reflections in the future climate and energy policy.

ESWET response

ESWET welcomes this opportunity to participate in the elaboration process of the strategy and believes that the European Union will be a leading global force for a clean and innovative energy transition.

In particular, ESWET believes that the waste management sector should be fully involved in the transition as it could contribute to important GHG emissions savings by fully switching from a “business-as-usual” approach to waste to a stronger focus on prevention, reuse, recycling, and recovery.

ESWET believes that the Future EU climate and energy policy should take into accounts the following points:

-          Developing energy-efficient processes, in particular with the help of R&D;

-          Developing the circular economy;

-          Fostering economic support from both the public and private sector and increasing the price of CO2 emissions;

-          Making the transition take place on a global scale so as to maintain a level playing field between all actors.

The waste management sector has a number of options to reduce its GHG emissions, such as landfill diversion, the use of CHP and CCU in Waste-to-Energy (WtE) plants, etc. Technologies are already available with high mitigation potential and the possibility of a large-scale deployment from now to 2025.

On the other hand, the waste sector still suffers from a financing gap for finalising the transition to a low carbon economy. Direct investment from the public sector, and especially from regional governments, is required.

You can find the full response of ESWET to the public consultation here.



Industry4Europe Joint Paper: “A Governance Structure for an ambitious EU Industrial Strategy”

ESWET co-signed together with other 121 association member of the Industry4Europe coalition the Joint Paper A Governance Structure for an ambitious EU Industrial Strategy”. The paper proposes a governance structure which enables the implementation of an ambitious EU Industrial Strategy, based on an informed dialogue between the industry, decision-makers at EU, national, regional and local levels and the Civil Society.

Read it here!



For an ambitious EU industrial strategy: going further

Following the publication of the Communication from the European Commission “Investing in a smart, innovative and sustainable Industry: a renewed Industrial Strategy for Europe” ESWET joined other 118 European industrial associations and signed the Joint Reaction Paper: “For an ambitious EU industrial strategy: going further”.

The paper was presented to the Council Industry Working Party on 23rd October and it reaffirms the commitment of the industrial sector to cooperate with the EU institutions to implement a long-term strategy to keep the EU a competitive global industrial player.

Read the full paper here.



ESWET Position Paper: Renewable Energy Directive II

ESWET supports the transition to more renewable Europe. The European Union’s commitment to the Paris Agreement needs to be translated into ambitious targets and practical measures that will help mitigate climate change. However, the transition needs to be executed in a manner that will ensure security of energy supply. Using sustainable biomass is a way to accommodate both goals, and this is where Waste-to-Energy plays an important role.

Please download the full Position Paper here.



ESWET Position Paper: EU Strategy on Plastics

ESWET welcomes the Commission’s initiative to create an EU Strategy on Plastics. From packaging protecting food from rotting (and humans – from food poisoning) to pipes in our homes, plastics have proven their usefulness and versatility. They are light and durable and can be moulded into different shapes. In an ideal world, we would be able to recycle all of these materials infinite number of times. However, a reality check shows that in certain cases energy recovery is a better solution due to several recycling constraints.

Please read the full Position Paper here.



ESWET comments - ENVI vote on the Circular Economy Package

To download, please click here.



Communication on Waste-to-Energy

ESWET comments on the European Commission's Communication on Waste-to-Energy.

To download, please click here.



ESWET Voting Recommendations - ENVI vote on the Circular Economy Package

The ENVI Committee of the European Parliament will vote on the 24th January on the proposals for 4 directives on waste management.

Please find our voting recommendations concerning the Compromise Amendments here. We also invite you to read our recommendations from 14th November.



ESWET's comments - ITRE vote on the Circular Economy Package

To download, please click here.



Input Public Consultation on Renewable Energy Directive Review

In preparation for the Renewable Energy Directive review, ESWET is confident that EU decision-makers will maintain the current recognition of the renewable energy contributions made by Waste-to-Energy.

To download, please click here.



Circular Economy Package

ESWET welcomes the new proposals from the European Commission towards a Circular Economy.

Read ESWET’s statement here.



Input Public Consultation on Risk Preparedness in the Area of Security of Electricity Supply

As the landscape of electricity generation, transmission, distribution and consumption changes, ESWET wants to underline the advantages WtE - representing a secure, predominantly local and partially biogenic fuel - can bring to the grid.

To download, please click here.



Input Public Consultation on the Functioning of Waste Markets

ESWET provided input to various challenges to integrate Waste-to-Energy in the EU waste market.

To download, please click here.



Input Public Consultation on the Circular Economy

ESWET, the European Suppliers of Waste to Energy Technology, would like to welcome the opportunity to provide input on the Circular Economy, ahead of the package’s re-release.

To download, please click here.



Input Effort Sharing Decision Consultation

ESWET commented on the consultation on the Effort Sharing Decision. Waste-to-Energy is part of this Decision and should remain covered by it as it constitutes the best way to account for Waste-to-Energy’s Climate Benefits.

To download, please click here.



Waste-to-Energy: Essential for Future Energy Systems, Essential for the Circular Economy

Energy systems of the future and the Circular Economy are being developed separately. If Europe acts smartly, Waste-to-Energy can connect the two.

For more information, please check out the original article in European Energy Innovation.



Energy and Materials from Waste

In the past decades there have been two exponentially growing concerns, both in the developed and the developing world. On the one hand, there is waste and its management; our consumption-driven lifestyle produces more and more waste, leading to environmental and sanitary issues. On the other hand, there is a growing energy demand around the world, and an increasing desire for this energy to be sustainable.

How can waste management and sustainable growth objectives be combined? ESWET believes that Waste-to-Energy (WtE) could offer solution to both – and other concerns.

For more information, please check out the original article in Logistyka Odzysku.



ESWET welcomes the R1 Climate Correction Factor

Several years in the making, this factor recently adopted by the European Commission will take into account local climatic conditions and their influence on Waste-to-Energy plants' ability to use and export heat. The possibility to use heat for instance in District Heating systems significantly influences the resulting R1 value a plant can feature.

More information in the ESWET article in Waste Management World



ESWET supports the Circular Economy Package

Read the Position Paper



ESWET explains the challenges and opportunities surrounding the revision of the Waste Incineration BREF

Read the 1st part of the article in Waste Management World.

Read the 2nd part of the article in Waste Management World.



ESWET supports a ban on landfilling of recyclable and recoverable waste by 2020

Read the joint letter signed by ESWET and 6 other organisations



Europe needs more District Energy from Waste

Find here our common proposals with other associations

Download here our common proposals



Incineration Caps undermine Resource-Efficiency!

Read the ESWET Letter to Environment Commissioner


Waste should remain waste! ESWET and other associations oppose any End-of-Waste status for Waste Derived Fuels

Read the Press Release



ESWET Answers to the Phosphorus Consultation

Read the ESWET Answers



ESWET Answers to the Waste Model Consultation

Read the ESWET Answers



ESWET Answers to the Consultation on Waste Management Targets Review

Read the ESWET Answers



ESWET Answers to the Green Paper on Plastic Waste

Read the ESWET answers



Call from ESWET and other associations for a ban on landfilling of recyclable and combustible waste

Read the joint letter