Incineration overcapacity in Europe: new incinerators keep coming despite 65 million tonnes of unused capacity – Zero Waste Europe’s 2026 data update

Europe keeps building waste incinerators while the plants it already has are not running full. According to a data update published by Zero Waste Europe (ZWE) on 13 October 2026, incineration overcapacity in the EU stands at close to 65 million tonnes: incinerators and co-incinerators could take 198.4 million tonnes of waste, but treated only 133.6 million tonnes in 2022. The analysis, prepared by Equanimator, goes further and argues that the surplus would not disappear even if all landfilled waste suitable for burning were sent to incinerators instead. Here is how the numbers are built, what the organisation recommends, and what it all means from a Hungarian perspective.

In short: Incineration overcapacity in the EU reached almost 65 million tonnes in 2022, as 198.4 million tonnes of capacity faced 133.6 million tonnes of waste actually burned. ZWE calculates that if recycling targets are met and leftover mixed waste is sorted before incineration, the surplus remains even if most landfilled waste is diverted to incinerators. The organisation therefore calls for a moratorium on new capacity.

What did the study examine, and what do R1 and D10 mean?

The publication updates the executive summary of ZWE’s earlier moratorium study, Enough is enough. The methodology is unchanged, but the figures are new: the author, Dr Dominic Hogg (Equanimator Ltd.), used Eurostat’s 2022 waste treatment and capacity data, the most recent year available.

The analysis covers two types of installation, separated by the energy efficiency formula of the Waste Framework Directive:

• R1 (energy recovery): plants that meet the efficiency threshold set in the directive. This includes municipal waste incinerators and co-incineration facilities.
• D10 (disposal): incinerators that fail to reach the threshold, burning waste without meaningful energy capture.

The authors argue that the threshold has become largely meaningless, as practically every legally compliant incinerator now meets it. The R1 label still matters, though: it is what allows waste to be shipped across borders in the name of recovery.

The study was released to open the GAIA-led Global Week of Action to Stop Incineration, held from 13 to 16 October. A year earlier, 156 civil society organisations had already called for an EU-wide moratorium on new incinerators, at that time citing a surplus of around 60 million tonnes.

Incineration overcapacity in numbers: how much fits, and how much is burned?

Based on Eurostat’s 2022 data, EU capacity breaks down as follows:

• R1 facilities: 184.3 million tonnes
• D10 facilities: 14.2 million tonnes
• combined: 198.4 million tonnes

Against this, the quantity actually treated was:

• hazardous waste: 10.5 million tonnes
• non-hazardous waste: 123.1 million tonnes
• combined: 133.6 million tonnes

The difference gives the almost 65 million tonnes of capacity that is free on paper.

The trend is telling. Between 2004 and 2022, EU incineration capacity grew by around 8 million tonnes a year on average, with most of the expansion early in the period. From 2012 onwards the trend line shows growth of only about 2 million tonnes a year, and between 2020 and 2022 total capacity fell slightly. The decline came almost entirely from D10 closures; R1 capacity kept rising.

ZWE’s press release adds that the organisation has identified plans to build or expand plants to burn at least another 8 million tonnes of waste in Europe.

What goes into incinerators today?

More than 90% of the waste treated at R1 and D10 facilities falls into seven waste categories, and four categories alone account for over 80%. The largest non-hazardous streams (as a share of all waste treated) are:

• household and similar wastes: 46.35 million tonnes (35%)
• sorting residues: 36.85 million tonnes (28%)
• wood wastes: 21.5 million tonnes (16%)
• mixed and undifferentiated materials: 5.36 million tonnes (4%)
• chemical wastes: 3.06 million tonnes (2%)
• common sludges: 2.95 million tonnes (2%)
• plastic wastes: 2.51 million tonnes (2%)
• industrial effluent sludges: 2.23 million tonnes (2%)

A large share of the three big mixed categories – household waste, sorting residues and mixed materials – is of municipal origin. In other words, the “fuel” of incinerators is mostly what remains in the residual bin after separate collection, plus what falls out of sorting plants.

What if landfilled waste went to incinerators too?

The most common argument for incineration is that cutting landfill requires more capacity. The study tests this with a scenario built step by step:

1. Starting point: 198.4 million tonnes of capacity, 133.6 million tonnes treated, a surplus of almost 65 million tonnes.
2. All burnable landfilled waste goes to incinerators: this adds 77.5 million tonnes of demand, creating a 12.7 million tonne shortfall if recycling and waste generation stay at 2022 levels.
3. EU recycling targets are met: a further 39.3 million tonnes would need to be recycled, roughly half the burnable quantity landfilled in 2022. The balance swings back to a surplus of 26.7 million tonnes.
4. 10% of municipal waste may still be landfilled: the Landfill Directive allows this, so around 15.1 million tonnes could stay in landfills. The surplus grows to 41.8 million tonnes.
5. Leftover mixed waste is sorted before incineration: the surplus returns to around 65 million tonnes.

The last step needs explaining. Incinerators are generally limited by the total calorific value of the waste they burn, not by its weight. When leftover mixed waste sorting (LMWS) pulls plastics out of residual waste, the calorific value of what remains drops, so the same furnace can accept more tonnes. According to the study, just over 77 million tonnes of waste would have been eligible for such sorting in 2022, and its output could be handled at facilities that today treat around 55 million tonnes. That frees another 22 million tonnes of capacity. We covered why mixed waste sorting is key to meeting recycling targets in our article on an earlier ZWE–Reloop report.

The authors call the result “remarkable”: if targets are met and sorting spreads, roughly the same amount of non-hazardous waste would remain for incineration as today – even with landfills largely emptied. If municipal waste grew at its historical rate of 0.7% a year until 2035, the surplus would ease to 57 million tonnes. The study notes that municipal waste generation actually fell between 2021 and 2023.

Municipal waste on its own: much less room for manoeuvre

The authors also looked at municipal waste separately, because mixed municipal waste usually goes to dedicated incinerators built for it. Eurostat reports just over 59 million tonnes of municipal waste burned at R1 and D10 facilities in 2022. The incineration industry association CEWEP reports 79 million tonnes treated at waste-to-energy plants for the same year, with total capacity of around 81 million tonnes.

The result here is more modest: with no waste growth, meeting the 65% recycling target and bringing landfilling down to no more than 10% in Member States currently above that level means there is no need for additional non-landfill treatment at EU-27 level. In fact, a net 2.7 million tonnes of capacity would be released.

The word “net” matters. Some Member States would free up capacity, while others would still need more non-landfill treatment even at a 65% recycling rate. The study suggests two ways to ease this tension: biological stabilisation of residual waste, which cuts both the landfilled mass and methane formation, and rational use of existing capacity across borders rather than new construction. Waste already moves between Member States – partly thanks to the R1 label.

Copenhagen and Rome: when an incinerator has to be fed

ZWE’s press release highlights two European cases from the case-study collection GAIA published for the week of action.

Copenhagen’s Amager Bakke (CopenHill) was built with a capacity of around 560,000 tonnes a year, even though city officials had warned before approval that it was too large for the expected residual waste volumes. Later estimates of locally available waste fell to about 350,000 tonnes a year. In 2016 the owner municipalities changed their agreement to allow imported waste and biomass; according to ZWE, around 30,000 tonnes of imported waste were burned in 2018, mainly from the British Isles.

In Rome, construction of the Santa Palomba incinerator began in May 2026. Planned capacity is 600,000 tonnes a year, with first deliveries expected in September 2029. The roughly €946 million project ties the city to a 33-year concession, while Rome plans to raise separate collection to 70% by 2035.

Janek Vähk, Zero Pollution Policy Manager at ZWE, said in the release that there is really no justification for continuing to build new incinerators. The organisation argues that an oversized plant locks in waste for decades because loans must be repaid and the furnace must be fed – which competes with prevention, re-use and recycling.

The study’s eight recommendations

1. Recognise overcapacity: Member States and the EU should acknowledge the problem and plan for progressive, year-by-year decommissioning.
2. EU-level coordination: closures should be coordinated so that a plant shut in one country is not replaced by a new one elsewhere.
3. Moratoria: where excess capacity already exists, no new R1 or D10 capacity should be built. Decisions on reductions should weigh plant age, its role in the network, district-heating connections and access to carbon capture.
4. EU-wide capacity planning: Member States should account for capacity in other countries when assessing their own needs.
5. Equivalence of pre-treated residual waste options: before building new incinerators, recognise that landfilling sorted and biologically stabilised waste is equivalent to incineration. Landfilling of untreated waste should end, and incineration and landfill of suitably pre-treated waste should sit on the same, lowest tier of the waste hierarchy.
6. Reconsider the 10% landfill limit: if pre-treatment requirements are properly enforced, the authors argue the limit needlessly constrains Member States.
7. The place of incineration in the hierarchy: the Commission should use the Article 12 assessment under the Waste Framework Directive to consider classifying incineration as disposal.
8. Mandatory pre-sorting: in future, incinerators should only accept mixed municipal waste that has been through advanced sorting.

In the press release, ZWE and 83 other organisations also ask for municipal waste incineration to enter the EU Emissions Trading System without free allocations. We explained what the Commission’s proposal contains in comparison in our analysis of waste incineration under the EU ETS, and summarised the industry’s counterarguments in this article.

What does this mean for Hungary?

Very different national situations lie behind the EU aggregate, and Hungary is not among the countries struggling with overcapacity. It has a single large municipal waste incinerator, and most residual waste still goes to landfill. The study does not name countries, but by its logic Hungary belongs to the group that will still need non-landfill treatment even if targets are met.

That is why recommendations five and six are interesting. If landfilling pre-treated, stabilised waste counted as equivalent to incineration, and the 10% landfill cap were removed, systems built on landfill and mechanical-biological treatment would gain room for manoeuvre. It is important to remember, however, that this is an NGO proposal, not current law: the 2035 target of landfilling no more than 10% still applies. How far Hungary is from it is shown in our article on the University of Pannonia network model, and we looked at how landfill is priced in our analysis of landfill taxes in Europe.

Recommendation four – taking neighbouring countries’ capacity into account – is not a theoretical question in the region either. Slovakia’s largest incinerator, planned in Bratislava, has recently received approval, and Croatia is building its first waste-to-energy plants. If ZWE’s figures are right, these investments are entering a European market that already has more furnaces than waste overall.

A critical reading: what the EU aggregate shows, and what it doesn’t

The study was published by an anti-incineration NGO network on the opening day of a campaign week. That does not invalidate it: the data are official Eurostat figures and the steps can be followed. Some limits are worth keeping in mind, though – the authors flag several of them themselves.

• The surplus exists “on paper”. The type of spare capacity and the type of waste available do not necessarily match. Permitted capacity at co-incineration plants may also be well above what they can realistically handle.
• Dedicated incinerators are close to full. According to the CEWEP figures cited in the study, 79 million tonnes of the 81 million tonne capacity of waste-to-energy plants are in use. Our reading is that most of the 65 million tonne surplus therefore sits at co-incinerators and other R1 facilities rather than at plants built for municipal waste – and those typically cannot take unsorted mixed waste.
• The scenario rests on several “ifs”. Recycling targets are met, mixed waste sorting spreads, and waste actually reaches the plants with spare capacity. All three are far from today’s practice.
• The data are from 2022. Plants opened or closed since then are not included.

The overall picture is still a strong message for investors and decision-makers: the payback of an incinerator built for 30–40 years depends on waste volumes that EU targets are designed to reduce.

Conclusion

According to ZWE’s data update, the bottleneck in the EU is not incineration capacity but prevention, separate collection and sorting. If these develop in line with the targets, existing plants can absorb the waste diverted from landfill as well. The calculation works with EU averages, so it does not replace national decisions – but it makes clear that any case for a new incinerator now has to reckon with the spare capacity of neighbouring countries.

More of our articles on the topic are available under the zero waste europe tag.

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Frequently asked questions about incineration overcapacity

How large is incineration overcapacity in the European Union?

Close to 65 million tonnes, according to Zero Waste Europe’s 2026 data update. Based on Eurostat’s 2022 data, combined capacity at EU R1 and D10 facilities was 198.4 million tonnes, while they actually treated 133.6 million tonnes of waste: 10.5 million tonnes of hazardous and 123.1 million tonnes of non-hazardous waste.

What is the difference between R1 and D10 incinerators?

R1 plants meet the energy efficiency threshold of the Waste Framework Directive, so they count as energy recovery; D10 incinerators do not, so they are classed as disposal. In 2022, 184.3 million tonnes of EU capacity was R1 and 14.2 million tonnes D10. The study argues that practically every legally compliant incinerator now meets the threshold.

Would the surplus disappear if landfilled waste were burned instead?

Not if recycling targets are met. Burnable landfilled waste alone would create a 12.7 million tonne shortfall, but meeting the targets brings back a 26.7 million tonne surplus. Allowing 10% landfill raises it to 41.8 million tonnes, and sorting mixed waste before incineration returns it to roughly 65 million tonnes, according to the study.

Why does sorting mixed waste increase incineration capacity?

Because incinerators are generally limited by the calorific value of the waste, not its weight. When high-calorific plastics are sorted out of residual mixed waste, the same furnace can accept more tonnes of what remains. According to the study, this could free up around 22 million tonnes of capacity at EU incinerators.

What does Zero Waste Europe recommend to tackle overcapacity?

A moratorium on new incineration capacity where a surplus already exists, plus EU-coordinated, progressive decommissioning of existing plants. It also asks that incinerators accept only pre-sorted mixed municipal waste, that the Commission assess classifying incineration as disposal, and that municipal waste incineration enter the EU ETS without free allocations.

Does incineration overcapacity affect Hungary?

Only indirectly, as Hungary has a single large municipal waste incinerator and most residual waste still goes to landfill. The study’s recommendations remain relevant, though: taking neighbouring countries’ spare capacity into account, and treating landfill of pre-treated, stabilised waste as equivalent to incineration, could give landfill-based systems more room for manoeuvre.

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🔗 Official sources and references: 👉

• Zero Waste Europe – Equanimator Ltd.: Incineration overcapacity in Europe: 2026 data update – The case for a moratorium on incineration (study, October 2026; author: Dr Dominic Hogg)
• Zero Waste Europe: New study: Europe continues to build waste incinerators despite excess capacity (press release, 13 October 2026)
• Eurostat: Treatment of waste by waste category, hazardousness and waste management operations (env_wastrt dataset)

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