September 28, 2022

To European Commission

Dear Mr. Frans Timmermans, Ms. Mairead McGuinness, Mr. Virginijus Sinkevičius,Mr. Aurel Ciobanu-Dordea and Mr. Martin Spolc

Japan Environmental Sanitation Center (JESC)

Comments on Waste-to-energy (WtE) in EU Taxonomy:“Carbon Neutrality, Circular Economy, and Biodiversity in Waste Management”

The Japan Environmental Sanitation Center (JESC) has been discussing waste
management and recycling with academics, practitioners, businesspeople, andexperts in the sector since last year. In March 2022, JESC launched the "Study onWaste Management toward Decarbonization and the EU Taxonomy."
The study group discussed the future of waste management in Japan with a focus
on WtE in relation to the EU Taxonomy used to classify sustainable economic activities.
The group consisted of eight academics and persons from local governments andprivate businesses. An online audience of about 200 persons viewed the discussions,along with lectures on related topics presented by participating experts from theMinistry of the Environment.
Please see the comments of our study group below. We hope to continue ourdiscussions with your federation and our joint work toward the development of WtE.
Our Comments：【Conclusion】➢ We fully agree with Dr. Ella Stengler's opinion on WtE (see the article
indicated below).
[ “Waste-to-Energy：the missing piece of the taxonomy puzzle,” The Energy
Industry Times－ January 2022 ]➢ WtE will contribute to the EU Taxonomy regarding pollution prevention
management. It can also contribute to other environmental objectives. WtE
can play a major role as a mechanism for climate change mitigation, climatechange adaptation (promotion of decarbonization), the creation of a circulareconomy, the maintenance and improvement of sanitation levels, and theconservation of biodiversity.
➢ We expect to reach reasonable judgments on the conditions for maintaining agreen economy (sustainable economic activity) with respect to the position ofWtE in the extended taxonomy.
【Evaluation of WtE】
1) Carbon Neutrality： Energy Supply and Climate Change Solutions
・ Japan intends to pursue the following decarbonization strategies mainly in thewaste sector in order to achieve the 2050 CN Declaration:(1) Promote the 3Rs and increase the size of WtE facilities for high-efficiency heatrecovery from non-recyclable combustible waste(2) Introduce CCU/CCUS(3) Promote methane fermentation of kitchen garbage(4) Promote the recycling of plastic resources
・ Energy produced from biogenic waste, which accounts for more than half ofmunicipal solid waste (MSW), is considered a renewable energy source.
・ WtE is also a reliable and stable baseload energy source, unlike other renewableenergy sources that fluctuate widely, such as solar power.
・ WtE contributes to climate change mitigation by replacing fossil fuels.
2) Circular Economy: Resource Circulation and Recycled Residues
・ Separate collection and recycling (plastic containers and packaging, bottles /cans / PET bottles, paper, etc.) have been steadily progressing in Japan.
・ The Act on Promotion of Resource Circulation for Plastics came into effect inApril 2022. Efforts to recycle not only containers and packaging plastics, but also
product plastics, have begun.
・ Even if recycling develops in accordance with the waste hierarchy, residues andnon-recyclable materials will always be generated after treatment. Thesematerials cannot be ignored. We hope that guidelines for the treatment ofrecycling residues will be established in the EU.
・ It is important to ensure that non-recyclable wastes are treated in WtE,
especially during the phased transition phase (low-recycling-rate phase).
3) Biodiversity and Detoxification: Reduction of the final disposal volume・ WtE has been a solution for the lack of suitable land for final disposal sites inJapan. WtE allows a significant reduction in volume compared to direct landfill,
and the reduction in direct landfill reduces methane emissions. The promotion ofWtE has minimized the negative impacts on biodiversity.

・ Japan has followed a long tradition of developing incineration as a means ofcombating infectious diseases since the enactment of the Waste Cleaning Law in1900. Japan’s achievements in incineration have been world-class. Today, WtE
remains extremely effective in the sanitary treatment of infectious wastes.
・ The current WtE technologies contribute to the prevention of pollution byproperly treating exhaust gasses and mineralizing and stabilizing organic wastes.
・ Japan's long-standing efforts and CN Declaration for 2050 do not significantly
harm the six environmental objectives of the taxonomy (DNSH).
4) Disaster Garbage Disposal: Effectiveness of incineration process
・ Climate change is causing frequent disasters. Floods, especially large-scale
floods, claim lives in many parts of the world and generate large amounts ofunsanitary disaster waste.
・ The most appropriate solution to this problem is to incinerate combustible
disaster waste as soon as possible. WtE is an effective climate change
adaptation measure.
5) Proper disposal of waste in developing countries
・ The waste management systems suitable for developing countries differ
according to economic conditions, waste discharge conditions, and the markets
for recycled materials. In examining and selecting the suitable methods among
the many options, WtE must be recognized as a powerful option.