COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS The role of waste-to-energy in the circular economy
Date: 2017-01-26
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, action programme, economic development, energy efficiency, energy saving, environmental protection, sustainable development, waste, waste incineration, waste recycling

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, 26.1.2017  COM(2017) 34 final   COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS The role of waste-to-energy in the circular economy  
 
 
1.  Introduction 

On 2 December 2015, the Commission adopted an EU action plan for the circular economy,1 
offering a transformative agenda with significant new jobs and growth potential and aiming at 
fostering  sustainable  consumption  and  production  patterns,  in  line  with  EU  commitments 
under the 2030 Agenda for Sustainable Development.  

The  action  plan  stressed  that  the  transition  to  a  more  circular  economy  requires  action 
throughout a product’s life-cycle: from production to the creation of markets for ‘secondary’ 
(i.e. waste-derived) raw materials. Waste management is one of the main areas where further 
improvements are needed and within reach: increasing waste prevention, reuse and recycling 
are key objectives both of the action plan and of the legislative package on waste2.  

Achieving  these  objectives  can  open  up  tangible  economic  opportunities,  improve  raw 
materials supply to industry, create local jobs and reaffirm European leadership in the green 
technologies sector, which has a proven growth potential also at global level. In the EU, the 
output of environmental goods and services per unit of gross domestic product has grown by 
more than 50 % over the last decade and the employment linked to this production has risen 
to more than 4 million full-time equivalents3. At global level, the World Bank has estimates 
that over the next 10 years EUR 6 trillion will be invested in clean technologies in developing 
countries, with some EUR 1.6 trillion accessible to SMEs.4 

In order to tap into this potential, promote innovation and avoid potential economic losses due 
to stranded assets, investment in new waste treatment capacity needs to be framed in a long-
term circular economy perspective and to be consistent with the EU waste hierarchy, which 
ranks  waste  management  options  according  to  their  sustainability  and  gives  top  priority  to 
preventing  and  recycling  of  waste.  EU  legislation  on  waste,  including  recent  proposals  for 
higher  recycling  targets  for  municipal  and  packaging  waste  and  for  reducing  landfill,  is 
guided  by  the  waste  hierarchy  and  aims  to  shift  waste  management  upwards  towards 
prevention, reuse and recycling. 

This  communication  focuses  on  energy  recovery  from  waste  and  its  place  in  the  circular 
economy. Waste-to-energy is a broad term that covers much more than waste incineration. It 
encompasses  various  waste  treatment  processes  generating  energy  (e.g.  in  the  form  of 
electricity/or heat or produce a waste-derived fuel), each of which has different environmental 
impacts and circular economy potential. 

The main aim of this communication is to ensure that the recovery of energy from waste in 
the EU supports the objectives of the circular economy action plan and is firmly guided by the 
EU  waste  hierarchy.  The  communication  also  examines  how  the  role  of  waste-to-energy 
processes  can  be  optimised  to  play  a  part  in  meeting  the  objectives  set  out  in  the  Energy 

1 Closing the loop — An EU action plan for the circular economy, COM(2015) 614 final. A circular economy is 
one in which the value of products, materials and resources is maintained for as long as possible, minimising 
waste and resource use.  

2 COM(2015) 593, 594, 595 and 596 final. 

3 http://ec.europa.eu/eurostat/statistics-explained/index.php/Environmental_goods_and_services_sector 

4 Building competitive green industries: The climate and clean technology opportunity for developing countries, 
The World Bank, 2014. 

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Union  Strategy5  and  in  the  Paris  Agreement6.  At  the  same  time,  by  highlighting  proven 
energy-efficient technology the approach to waste-to-energy set out here is meant to provide 
incentives for innovation and help create high-quality jobs. 

To attain these objectives, the communication: 

−  clarifies the position of different waste-to-energy processes in the waste hierarchy and 

what this entails for public financial support (section 2); 

−  provides  guidance  to  Member  States  on  how  to  make  better  use  of  economic 
instruments  and  capacity  planning  with  a  view  to  avoiding  or  addressing  potential 
overcapacity in waste incineration (section 3); and 

− 

identifies the technology and processes which currently hold the greatest potential to 
optimise energy and material outputs, taking into account expected changes in the 
feedstock for waste-to-energy processes (section 4). 

2.  Positioning waste-to-energy processes in the waste hierarchy and the role of 

public financial support 

The waste hierarchy7 is the cornerstone of EU policy and legislation on waste and a key to the 
transition to the circular economy. Its primary purpose is to establish an order of priority that 
minimises  adverse  environmental  effects  and  optimises  resource  efficiency  in  waste 
prevention and management.  

This communication covers the following main waste-to-energy processes8: 

−  co-incineration  of  waste  in  combustion  plants  (e.g.  power plants)  and in  cement  and 

lime production; 

−  waste incineration in dedicated facilities; 

−  anaerobic digestion of biodegradable waste; 

−  production of waste-derived solid, liquid or gaseous fuels; and 

−  other  processes  including  indirect  incineration  following  a  pyrolysis  or  gasification 

step.  

5 http://ec.europa.eu/priorities/energy-union-and-climate/state-energy-union_en 

6 http://unfccc.int/paris_agreement/items/9485.php 

7 As set out in Article 4 of Directive 2008/98/EC of the European Parliament and of the Council on waste and 
repealing certain Directives, OJ L 312, 22.11.2008, p. 3. 

8 As identified in the dedicated Commission study: Towards a better exploitation of the technical potential of 
waste-to-energy, European Union, 2016. 
http://publications.jrc.ec.europa.eu/repository/bitstream/JRC104013/wte%20report%20full%2020161212.pdf. 

3 

 
 
 
 
 
 
 
 
 
 
 
                                                      
These  processes  have  different  environmental  impacts  and  rank  differently  in  the  waste 
hierarchy.  In  fact,  waste-to-energy  processes  encompass  very  different  waste  treatment 
operations,  ranging  from  ‘disposal’  and  ‘recovery’  to  ‘recycling'.    For  example, 
processes  such  as  anaerobic  digestion  which  result  in  the  production  of  a  biogas  and  of  a 
digestate are regarded by EU waste legislation9 as a recycling operation. On the other hand, 
waste incineration with limited energy recovery is regarded as disposal. The figure 1 below 
illustrates  the  positioning  of  different  waste-to-energy  processes  along  the  EU  waste 
hierarchy. 

Figure 1. The waste hierarchy and waste-to-energy processes 

It  important  to  stress  that  the  waste  hierarchy  also  broadly  reflects  the  preferred 
environmental option from a climate perspective: disposal, in landfills or through incineration 
with  little  or  no  energy  recovery,  is  usually  the  least  favourable  option  for  reducing 
greenhouse gas (GHG) emissions; conversely, waste prevention, reuse and recycling have the 
highest potential to reduce GHG emissions. 

It  is  also  worth  recalling  that  Member  States  have  some  flexibility  in  the  application  of  the 
hierarchy, as the ultimate goal is to encourage those waste management options that deliver 
the  best  environmental  outcome.10  For  some  specific  waste  streams,  achieving  the  best 
environmental outcome may entail departing from the priority order of the hierarchy, i.a. for 
reasons  of  technical  feasibility,  economic  viability  and  environmental  protection.  This  must 
be  justified  in  line  with  the  provisions  laid  out  in  Article  4(2)  of  the  Waste  Framework 

9 Article 2 (6) of Commission Decision 2011/753/EU establishing rules and calculation methods for verifying 
compliance with the targets set in Article 11(2) of Directive 2008/98/EC of the European Parliament and of the 
Council. OJ L 310 of 25.11.2011. 

10 Article 4 (2) of Directive 2008/98/EC in conjunction with the EU guidance on the interpretation of the waste 
hierarchy: http://ec.europa.eu/environment/waste/framework/pdf/guidance_doc.pdf (pages 48 to 52). 

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Directive11.  .For  instance,  in  some  specific  and  justified cases,  (e.g.  materials  that  contain 
certain  substances  of  very  high  concern),  disposal  or  energy  recovery  may  be  preferable  to 
recycling12. 

To  support  the  transition  towards  a  more  circular  economy,  public  financing  of  waste 
management, whether national or at EU level, should be consistent with the goal of shifting 
upwards in the implementation of the EU waste hierarchy.  

At  EU  level,  the  transition  towards  more  sustainable  waste  management  systems  receives 
financial support, mainly through the co-financing of the Cohesion Policy funds13 In the case 
of these funds, pre-conditions must be met to ensure that new investments in the waste sector 
are in line with waste management plans designed by Member States to meet their preparation 
for reuse and recycling targets. As stated in the circular economy action plan, this means that  
investments  in  treatment  facilities  for  residual  waste,  such  as  extra  incineration  capacity 
would  only  be  granted  in  limited  and  well  justified  cases,  where  there  is  no  risk  of 
overcapacity and the objectives of the waste hierarchy are fully respected. 

Investments channelled through other EU financing mechanisms, such as the European Fund 
for  Strategic  Investment  (EFSI)  also  have  an  important  role  to  play  in  attracting  private 
financing  to  the  best  and  most  ‘circular’  solutions  for  waste  management  through  loans, 
guarantees,  equity  and  other  risk-bearing  mechanisms.  In  addition,  available  EU  financial 
support for research and innovation in waste-to-energy technologies, (e.g. Horizon 202014, but 
also  Cohesion  Policy  funds)  contributes  to  ensuring  continued  EU  leadership  and  bringing 
advanced energy-efficient technologies to the market. 

At national level, public financial support has also often played a key role in developing more 
sustainable  waste  management  solutions  and  in  promoting  renewable  energy  and  energy 
efficiency.  When  assessing  public  financial  support  for  waste-to-energy  processes,  it  is 
particularly  important  not  to  undermine  the  waste  hierarchy  by  discouraging  waste 
management  options  with  higher  circular  economy  potential.  This  is  clearly reflected  in  the 
existing  guidelines  on  state  aid  for  environmental  protection  and  energy  which  state  that 
support  for  energy  from  renewable  sources  using  waste  or  support  for  cogeneration  and 
district  heating  installations  using  waste  can  make  a  positive  contribution  to  environmental 
protection  provided  it  does  not  circumvent  the  waste  hierarchy.  Public  funding  should  also 
avoid  creating  overcapacity  for  non-recyclable  waste  treatment  such  as  incinerators.  In  this 
respect  it  should  be  borne  in  mind  that  mixed  waste15  as  a  feedstock  for  waste-to-energy 

11 Supporting environmentally sound decisions for waste management, European Union, 2011. 
http://publications.jrc.ec.europa.eu/repository/bitstream/JRC65850/reqno_jrc65850_lb-na-24916-en-
n%20_pdf_.pdf 

12 As announced in the Circular Economy action plan, the Commission is currently analysing options to address 
the interface between chemicals, products and waste legislation, including how to reduce the presence and 
improve the tracking of chemicals of concern in products.  

13 In particular, the European Regional Development Fund and the Cohesion Fund. 

14 http://www.eib.org/products/blending/innovfin/ 

15 For the purpose of this communication, this category includes the following non-separately collected waste 
streams: household and similar waste, undifferentiated materials and sorting residues. 

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processes is expected to fall as a result of separate collection obligations and more ambitious 
EU  recycling  targets.  For  these  reasons,  Member  States  are  advised  to  gradually  phase-out 
public support for the recovery of energy from mixed waste. 

3.  Waste-to-energy processes for treating residual waste: finding the right balance 

The transition towards a circular economy requires striking the right balance when it comes to 
waste-to-energy  capacity  for  the  treatment  of  non-recyclable  waste.  This  is  critical  to  avoid 
potential  economic  losses  or  the  creation  of  infrastructural  barriers  to  the  achievement  of 
higher recycling rates. Previous experience in some Member States shows the risk of stranded 
assets is real. 

A  recent  study16  commissioned  by  the  European  Environment  Agency  maps  existing 
dedicated incineration capacity for municipal waste in the EU-28 countries and the flows of 
municipal  waste  and  refuse-derived  fuel  (RDF)17  between  Member  States.  The  study  shows 
that  between  2010  and  2014,  the  incineration  capacity  in  the  EU-28  countries  (plus 
Switzerland  and  Norway)  increased  by  6 %  to  81  Mt  and  that  waste  flows  between  some 
Member States for the incineration of municipal waste and RDF remained significant in some 
cases. In 2013, close to 2.5 Mt of waste (most of it RDF) was shipped for energy recovery. 

The study also confirms that dedicated incineration capacity for municipal waste is unevenly 
spread in the EU. Germany, France, the Netherlands, Sweden, Italy and the UK account for 
three quarters of the EU’s incineration capacity. Sweden and Denmark have the highest per 
capita  incineration  capacity  with  591 kg/cap  and  587 kg/cap  respectively,  followed  by  the 
Netherlands, Austria Finland and Belgium. In contrast, the southern and eastern parts of the 
EU are practically devoid of dedicated incineration capacity and are highly reliant on landfill. 
This data is in line with Eurostat statistics on the incineration rates of municipal waste which 
also show great variation across Member States.  

Depending  on  their  specific  situation,  Member  States  have  various  options  to  ensure  that 
waste-to-energy capacity, in particular incineration, is properly balanced:  

Member States with low or non-existent dedicated incineration capacity and high reliance on 
landfill 

These  Member  States  should  give  priority  to  further  development  of  separate  collection 
schemes  and  recycling  infrastructure  in  line  with  EU  legislation.  The  gradual  diversion  of 
waste  from  landfill  should  go  hand-in-hand  with  the  creation  of  greater  recycling  capacity. 
Reducing  the  landfilling  of  biodegradable  waste  is  particularly  urgent  from  a  climate 
perspective  so  as  to  reduce  methane  emissions.  Here,  the  development  of  combined  energy 
recovery and material recycling capacity in the form of anaerobic digestion could represent an 
attractive management option. 

16 Assessment of waste incineration capacity and waste shipments in Europe, WI et al, 2016. European Topic 
Centre on Waste and Materials in a Green Economy (ETC/WMGE), 2017.  
 http://forum.eionet.europa.eu/nrc-scp-waste/library/waste-incineration 

17 RDF is a fuel produced from the treatment (e.g. shredding and dehydrating) of municipal solid waste. 

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When  reviewing  national  waste  management  plans  and  assessing  the  need  for  additional 
waste-to-energy  capacity  for  the  treatment  of  non-recyclable  waste  (e.g.  incineration), 
Member States should take a long-term perspective and carefully assess the following factors: 

− 

the  impact  of  existing  and  proposed  separate  collection  obligations  and  recycling 
targets  on  the  availability  of  feedstock  to  sustain  the  operation  of  new  incineration 
plants over their lifespan (20 -30 years); 

− 

the available capacity for co-incineration in combustion plants and in cement and lime 
kilns or in other suitable industrial processes; and 

−  planned or existing capacity in neighbouring countries. 

In justified cases, the cross-border shipments of waste could help to make optimal use of the 
waste-to-energy  capacity  already  available  in  a  number  of  Member  States.  Exporting  non-
recyclable waste for energy recovery to another Member State should not necessarily be seen 
as contradicting the so-called principle of proximity (i.e. using the nearest appropriate facility) 
that  underpins EU  waste legislation.18  However,  before  opting for such  approach competent 
authorities  in  the  Member  States  should  carry  out  a  life-cycle  analysis  to  ensure  that  the 
overall environmental impacts, including those related to the transport of waste, do not offset 
the sought benefits 

Where the creation of new capacity for the treatment of residual waste appears justified based 
on  the  assessment  of  all  the  factors  mentioned  above,  Member  States  should  pay  particular 
attention  to  the  use  of  state-of-the-art  energy-efficient  technologies  and  to  the  size  and 
location  of  the  plant  (e.g.  to  avoid  future  overcapacities  and  ensure  combined  supply  of 
electricity and heat or cooling to local residents and industry where possible). It is also crucial 
to ensure full compliance with the requirements for incineration and co-incineration facilities 
set out in EU legislation, in particular the Industrial Emissions Directive 2010/75/EC.19 

Member States with high dedicated incineration capacity  

The  European  Environment  Agency  study  suggests  there  is  currently  no  incineration 
overcapacity  in  the  EU  as  a  whole.  However,  the  statistics20  show  that  some  individual 
Member States are excessively reliant on incineration of municipal waste. This situation may 
be  partly  explained  by  high  demand  for  heat  through  district  heating  networks,  the  higher 
efficiency  of  their  waste-to-energy  processes  and  high  levels  of  social  acceptance. 
Nonetheless,  such  high  rates  of  incineration  are  inconsistent  with  more  ambitious  recycling 
targets. To address this problem a number of measures can be taken at national level and have 
already been implemented in some Member States, in particular: 

18 See Article 16 of Directive 2008/98/EC. 

19

 OJ L 334, 17.12.2010. This Directive includes operational requirements and emission limit values based on the 

best available techniques, aimed at protecting human health and the environment from industrial processes. 

20 http://ec.europa.eu/eurostat/documents/2995521/7214320/8-22032016-AP-EN.pdf 

7 

 
                                                      
 
 
 
− 

introducing or increasing incineration taxes, especially for processes with low energy 
recovery while ensuring they are paired with higher landfill taxes; 

−  phasing  out  support  schemes  for  waste  incineration  and,  where  appropriate,  

redirecting support to higher-ranking processes in the waste hierarchy; and 

− 

introducing  a  moratorium  on  new  facilities  and  decommissioning  older  and  less 
efficient ones. 

4. Optimising the contribution of waste-to-energy processes to the EU’s climate and 
energy objectives in the circular economy 

According  to  the  Commission  study,  in  2014  approximately  1.5 %  of  the  EU’s  total  final 
energy  consumption  was  met  by  recovering  energy  from  waste  through  incineration,  co-
incineration in cement kilns and anaerobic digestion (i.e. around 676 PJ/year). Whereas this 
percentage  should  not  significantly  increase  in  the  future  as  more  waste  is  directed  to 
recycling, improving the energy efficiency of waste-to-energy processes and promoting those 
processes  which combine material and energy recovery  can contribute to decarbonising  key 
sectors  such  as  heating  and  cooling  or  transport  and  to  reducing  greenhouse  gas  emissions 
from  the  waste  sector.  For  instance,  diverting  one  tonne  of  biodegradable  waste  from  a 
landfill  towards  anaerobic  digestion  to  produce  biogas  and  fertilisers  can  prevent  up  to 
2 tonnes of CO2 equivalent emissions.21  

Expected changes in waste-to-energy feedstock 

Mixed  waste  still  accounts  for  a  substantial  share  of  the  waste  used  in  waste-to-energy 
processes, mainly incineration (52 %). Existing legal requirements and the circular economy 
waste  proposals  are  bound  to  change  this  situation.  Rules  on  separate  collection  and  more 
ambitious recycling rates covering wood, paper, plastic and biodegradable waste are expected 
to  reduce  the  amount  of  waste  potentially  available  for  waste-to-energy  processes  such  as 
incineration and co-incineration. Ljubljana is an example of a city that has already managed 
to  move  rapidly  and  successfully  to  high  levels  of  separate  collection:  From  2011  on 
Ljubljana has invested in the modernisation of the waste management infrastructure leading to 
the separate collection rate of 60% on total municipal waste generation22.  

For  biodegradable  waste,  the  implementation  of  the  requirements  laid  down  in  the  Landfill 
Directive,23 in combination with the proposed new rules to ensure separate collection of bio-
waste, should result in greater production of waste-derived biogas for the use in cogeneration, 
injection  into  the  gas  grid,  and  the  use  in  transport  fuels,  and  fertilisers  through  anaerobic 
digestion.  Proposed  changes  to  the  Fertilisers  Regulation,24  currently  under  discussion  in 
Parliament  and  the  Council,  should  support  this  trend  by  opening  up  the  single  market  for 

21 Review of comparative LCAs of food waste management systems – Current status and potential improvements, 
A. Bernstad, J. la Cour Jansen, Science Direct, Volume 32, Issue 12, December 2012. 

22 http://ec.europa.eu/environment/waste/studies/pdf/Separate%20collection_Final%20Report.pdf 

23 Article 6 (a) of Directive 1999/31/EC on the landfill of waste. OJ L 182 of 16.7.1999. 

24 http://ec.europa.eu/DocsRoom/documents/15949 

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waste-derived  fertilisers.  The  potential  of  biodegradable  waste  coupled  with  anaerobic 
digestion  processing  in  a  biogas  plant  is  seen  in  Milan.25  Since  2014,  the  city  has  almost 
reached 100% collection of food and organic waste, providing an average of 120 000 tonnes 
of  biodegradable  waste  per  year.  At  full  capacity  (12.8 MW),  the  city  biogas  plant  should 
produce some 35 880 MWh of electricity a year, enough to supply 24 000 people, and yield 
14 400 tonnes of fertiliser.  

In  the  case  of  waste  edible  oils  and  fats,  there  is  scope  for  improving  the  efficiency  of 
collection  and  treatment  systems  to  produce  products  such  as  biodiesel  and  hydrogenated 
vegetable oils (HVO). The resulting waste-derived biofuel can be used directly in transport, 
including the use of HVO in aviation.. 

As regards plastic waste, industry data26 shows that disposal and energy recovery remain the 
most  common  treatment  options  and  that  while  landfilling  has  decreased  over  the  past  ten 
years  incineration  has  been  growing  with  big  disparities  between  Member  States  linked  to 
various states of implementation of existing EU legislation. This confirms the need for urgent 
and  concrete  steps  to  improve  the  recyclability  and  reusability  of  plastics  and  to  encourage 
innovation in this field. The upcoming EU strategy on plastics in the circular economy27 will 
precisely aim to improve the economics, quality and uptake of plastic recycling and reuse by 
looking at the entire value chain. It will consider some new developments in the treatment of 
plastic waste, such as re-refining and innovations in design, so that in the future a higher share 
of plastic waste can be prevented or diverted from energy recovery to recycling, thus reducing 
overall GHGs impacts.28. 

The  Commission  study  found  that  wood  waste  is  commonly  used  as  a  feedstock  for 
incineration. As highlighted in the circular economy action plan, a cascading use of renewable 
resources such as wood, with several reuse and recycling cycles, should be encouraged where 
appropriate, in line with the waste hierarchy. In this context, it should be recalled that in its 
legislative  package  on  waste,  the  Commission  has,  inter  alia,  proposed  a  higher  mandatory 
EU-level target on recycling wood packaging waste. Where reuse or recycling is not possible, 
energy use of wood waste is desirable to replace fossil fuels and avoid landfilling of wood. 

Using the most energy-efficient waste-to-energy techniques 

Where  waste-to-energy  processes  are  opted  for,  there  is  a  need  to  ensure  that  the  most 
efficient  techniques  are  used:  this  maximises  their  contribution  to  the  EU’s  climate  and 
energy objectives. The Commission study estimates that if proven techniques and supporting 
measures are properly implemented, the amount of energy recovered from waste could rise by 
29 %  to  872 PJ/year,  using  exactly  the  same  amount  of  waste  as  feedstock.  This  shows  the 
potential  for  energy  efficiency  improvements.  The  Commission  study  found  that  the  best 

25 http://european-biogas.eu/wp-content/uploads/2016/03/Milan.pdf 

26 http://www.plasticseurope.org/Document/plastics---the-facts-2016-15787.aspx?FolID=2 

27http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52013DC0123 

28 Recycling plastics releases only a forth or even less of the GHG emitted by producing plastics from fossil-
based primary feedstock (Increased EU Plastics Recycling Targets: Environmental, Economic and Social 
Impact Assessment, Bio by Deloitte, 2015). 

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proven techniques to increase energy efficiency for the four waste-to-energy processes below 
were as follows: 

−  co-incineration in combustion plants: gasification of solid recovered fuel29 (SRF) and 
co-incineration of the resulting syngas in the combustion plant to replace fossil fuels in 
the production of electricity and heat; 

−  co-incineration in cement and lime production: conversion of waste heat to power in 

cement kilns; 

−  waste incineration in dedicated facilities: 
the use of super heaters;  

o 
o  harnessing the energy contained in flue gas; 
o 
o  supplying chilled water for district cooling networks; and 
o  distributing heat from waste through low temperature district heat networks. 

the use of heat pumps;  

−  anaerobic digestion: upgrading of the biogas into bio-methane for further distribution 

and use (e.g. injection into the gas grid and transport fuel). 

Apart  from  the  above-mentioned  specific  techniques,  the  Commission  study  highlights  the 
superior  energy  efficiency  levels  attainable  by  installations  working  in  combined  heat  and 
power (CHP) mode, compared to plants merely producing either heat or electricity. 

In addition to these techniques, the study lists supporting measures to improve energy and/or 
material efficiency in these processes. This includes the development of industrial parks and 
symbiosis  whereby  a  waste-to-energy  plant  processes  the  waste  generated  by  industries 
located  nearby  while  providing them  heat  and  power  in  return;  or  the  recovery  of materials 
found in incinerator bottom ash. 

In  anaerobic  digestion,  it  is  also  important  to  avoid  the  risk  of  methane  leaks  from  biogas 
plants  due  to  poor  design  or  maintenance,  as  these  would  offset  some  of  the  plants’ 
environmental benefits. 

5. Conclusions  

Waste-to-energy  processes  can  play  a  role  in  the  transition  to  a  circular  economy  provided 
that  the  EU  waste  hierarchy  is  used  as  a  guiding  principle  and  that  choices  made  do  not 
prevent higher levels of prevention, reuse and recycling. This is essential in order to ensure 
the  full  potential  of  a  circular  economy,  both  environmentally  and  economically  and  to 
reinforce the European leadership in green technology. Moreover, it is only by respecting the 
waste  hierarchy  that  waste-to-energy  can  maximise  the  circular  economy's  contribution  to 
decarbonisation,  in  line  with  the  Energy  Union  Strategy  and  the  Paris  agreement.  As 
mentioned earlier, it is waste prevention and recycling that deliver the highest contribution in 
terms of energy savings and reductions in GHGs emissions. 

29 SRF is a fuel produced from non-hazardous waste in accordance with EU standards EN15359. 

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In  the  future,  more  consideration  should  be  given  to  those  processes,  such  as  anaerobic 
digestion of biodegradable waste, where material recycling is combined with energy recovery. 
Conversely,  the  role  of  waste  incineration  –  currently,  the  predominant  waste-to-energy 
option - needs to be redefined to ensure that increases in recycling and reuse are not hampered 
and that overcapacities for residual waste treatment are averted.  

The Commission calls on all Member States to take into account the guidance provided in this 
communication  when  evaluating  and  revising  their  waste  management  plans  under  EU 
legislation30.  When  planning  future  investments  on  waste-to-energy  capacity,  it  is  essential 
that  Member  States  take  into  consideration  the  risk  of  stranded  assets.  When  assessing 
national waste management plans and monitoring progress towards the EU recycling targets, 
the Commission will continue to provide guidance on ensuring that waste-to-energy capacity 
planning  is  consistent  with,  and  supportive  of,  the  waste  hierarchy  and  that  it  takes  into 
account the potential of new and emerging waste treatment and recycling technologies. 

The Commission remains committed to ensuring that EU funding and other public financial 
support is directed towards waste treatment options that are in line with the waste hierarchy, 
and that priority is given to waste prevention, reuse, separate collection and recycling.  

30 See Article 30(1) of Directive 2008/98/EC. 

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