Landfill Tax in Europe: How Cheap Landfill Undermines Recycling and Recovery

The landfill tax is one of Europe’s most important environmental instruments, and one of its least coordinated. A report published by the RDF Industry Group (RDFIG) on 20 October 2026 compares landfill and incineration taxes, landfill restrictions and carbon pricing across 38 countries, and concludes that Europe has no common fiscal signal for residual waste. Where landfill stays cheap, recovery – and indirectly recycling – loses out. The EU carbon price arriving from 2031 could make this worse in several countries, Hungary among them.

In short: The landfill tax in Europe ranges from roughly €11 to €154 per tonne, and 14 countries have no national landfill tax at all. RDFIG’s stress test shows that if a full carbon price is added to incineration around 2030 while landfill costs stay flat, landfilling becomes cheaper than recovery in a significant group of countries. That would invert the waste hierarchy and also raise the cost of handling recycling residues.

What did the RDF Industry Group report examine?

The RDF Industry Group is a European trade association representing producers, shippers and users of waste-derived fuels (WDF, including RDF and SRF). Its report, The Uneven Playing Field, asks two questions: do national waste taxes create a level playing field across Europe, and are they aligned with the waste hierarchy? In Hungary, the report was first covered by Zöld Ipar Magazin, the trade journal of the National Association of Waste Management Companies (HOSZ), whose Hungarian-language article highlights the call for coordinated European reform. Here we go through the detailed data and what they mean for Hungary.

The authors mapped five instruments country by country:

• landfill taxation,
• legal restrictions on landfilling,
• tonnage-based incineration taxes,
• energy-based incineration taxes,
• carbon-based charges on incineration, including EU and national emissions trading.

The starting point is the waste hierarchy: prevention, reuse and recycling first, then other recovery (including energy recovery), with disposal as the least preferred option.

Landfill tax rates: almost anything between €11 and €154

Of the 38 countries reviewed, 24 have an identified landfill tax and 14 have none at national level. The rates vary enormously:

Band	Countries (2026, €/tonne)
Above €100	United Kingdom (154), Belgium (141), Latvia (130)
€60–100	Poland (92), Ireland (85), Finland (80), France (69), Sweden (68), Czech Republic (66), Denmark (64)
Low end	e.g. Slovenia (11), Hungary (c. 17), Slovakia (20), Italy (20), Romania (c. 31), Austria (34), Croatia (35)
No national landfill tax	e.g. Germany, Switzerland, Norway, Luxembourg, Cyprus, Malta, Serbia, Turkey

A low or zero tax does not necessarily mean easy landfilling. Germany, Switzerland and Austria close the gate mainly through regulation: untreated or combustible waste above organic-carbon or calorific thresholds simply cannot be landfilled. That is why the report always reads the landfill tax alongside restrictions.

Differences in landfill tax have limited direct cross-border impact, because waste for disposal can only be shipped between countries in exceptional cases under EU waste shipment rules. Landfills therefore compete in their domestic market – against recovery.

Perhaps the most important finding is that having a tax is not enough. Bulgaria, Greece, Croatia, Romania, Italy, Spain, Portugal and Hungary all levy a landfill tax and still landfill heavily; several still landfill more than half of their municipal waste. The authors argue that fiscal signals only work when they are set high enough and backed by enforcement, treatment capacity, separate collection, sorting infrastructure and functioning end markets.

Taxing incineration: per tonne, per tonne of CO₂ or per gigajoule

Only 13 countries have an identifiable incineration tax, and their designs differ completely:

• Tonnage-based taxes in eight countries (Austria, Belgium, France, Ireland, Latvia, the Netherlands, Portugal, Spain).
• Carbon-based charges in six (Denmark, Germany, the Netherlands, Norway, Sweden, Lithuania), via the EU ETS, national emissions trading or a national CO₂ tax.
• Energy-based taxes only in Denmark, levied on recovered heat and energy input.

The combined burden ranges from €8 per tonne (Portugal) to about €98 (Denmark), with a median of roughly €24. In Germany, waste incineration is already covered by national emissions trading, while the EU is preparing to bring incineration into its own ETS; Zero Waste Europe’s view of how that will work in practice is covered in our analysis of what incinerators will really pay under the EU ETS.

The report identifies two risks. First, incineration could end up taxed more heavily than landfill, creating a perverse incentive. Second, inconsistent incineration taxes push waste-derived fuel not to the most efficient plants or those with heat offtake, but to wherever the tax is lowest.

What happens when the carbon price arrives around 2030?

Under the European Commission’s proposal, non-hazardous waste incineration and co-incineration would enter the EU ETS, with surrender obligations phased in from 25% in 2031 to 100% from 2034, and temporary national opt-outs possible until 2035. The proposal is still being negotiated.

RDFIG ran a deliberately strict “full-exposure” stress test: an assumed €110/tCO₂ applied in every country in 2030, on top of the national taxes expected by then. By default the model assumes 1.0 tCO₂ per tonne of waste and a 47% fossil share, adding €51.70 per tonne to incineration. The authors stress that this is a test of the relative fiscal signal, not a forecast.

The results fall into four groups:

• Highest concern: Cyprus, Malta, Italy and Romania, plus eight non-EU countries (including Serbia, Bosnia and Herzegovina and North Macedonia). Incineration would be taxed more than landfill; Italy’s current +€20 advantage for recovery would flip to –€32.25.
• Medium concern: Croatia, Bulgaria, Greece and Portugal, where the gap shrinks to near parity while landfill remains legally available.
• Weak or inverted signal, but landfill restricted: Austria, Denmark, Estonia, France, Germany, Hungary, Lithuania, Luxembourg, Slovakia, Slovenia and Spain, where restrictions should in principle prevent a shift back to landfill.
• Supportive signal: Belgium, the Czech Republic, Finland, Ireland, Latvia, Poland, Sweden, the Netherlands and the United Kingdom, where landfill stays more expensive even with the carbon price.

The report’s remedy is to strengthen the landfill side: a higher landfill tax or a strong, enforced ban. The European Landfill Association has flagged the same trap from the other side – incineration getting more expensive while landfilling does not – as we explained in our article on the ELA position and what it means for Hungary.

How does the cost of landfill affect recycling?

At first glance the debate between landfill and incineration concerns residual waste, not recycling. The report links them in two ways.

The first is the logic of the hierarchy. If landfill is cheap, investment in sorting, pre-treatment, RDF production and the recycling capacity attached to them does not pay back. A cheap landfill competes with every option above it, not just the incinerator. Landfill is also one of the waste sector’s largest methane sources; the UN’s Global Methane Assessment found that Europe’s largest methane-reduction potential lies in minimising landfill. (For a stark picture of what poorly managed landfills do, see our case study on India’s legacy landfills and methane.)

The second is sorting residues. Every sorting and recycling process leaves a residue that is typically used as RDF. If treating that residue is heavily taxed, producing recycled material gets more expensive while virgin fossil feedstock does not. How large these residues can be is clear from our analysis of PET tray recycling, where most collected trays are rejected at sorting and sent to energy recovery. The report cites the Netherlands, where, according to the authors, national carbon and incineration taxes on recycling residues are driving recyclers to move operations to other countries. Its recommendation: primary materials should carry a heavier tax burden than the supply chain for recycled materials.

RDFIG estimates that cross-border WDF shipments avoided 10.5 million tonnes of CO₂e in 2023, mainly by displacing landfill. It also sees WDF as an integral part of the EU’s envisaged transregional Circularity Hubs, whose competitiveness depends partly on cheap and efficient treatment of residues.

Hungary: strict on paper, landfill-dependent in practice

The Hungarian data in the report paint a contradictory picture:

• The landfill levy is HUF 6,000 per tonne, or €16.68 at the report’s exchange rate – near the bottom of the European range.
• There is no incineration tax.
• The legal restriction is rated “severe”: untreated municipal waste cannot be landfilled.
• Yet Hungary is listed among the countries that still landfill heavily despite having a landfill tax.
• In the 2030 stress test, today’s +€16.68 differential in favour of recovery turns into –€35.02, meaning landfill would be that much cheaper per tonne than incineration.

Hungary is not placed in the highest-concern group because the ban on landfilling untreated waste should in principle block a shift back. But a pre-treatment requirement is not the same as a landfill ban: after mechanical-biological treatment, residues can still go to landfill. The authors themselves note that risk categories are based on current, not incoming, landfill restrictions.

Hungary has a single large municipal waste incinerator, in Budapest, and the bulk of its residual waste goes to landfill. The EU Landfill Directive caps landfilling at 10% of municipal waste by 2035. If recovery becomes more expensive because of carbon pricing while landfill does not, the percentage points needed to reach that cap become the hardest to win.

Neighbouring countries show a similar pattern: Slovakia (+20 → –31.70), Romania (+30.52 → –21.18), Slovenia (+11 → –40.70) and Austria (+25.10 → –24.99) all turn negative in the stress test, and Croatia (+35 → –1.70) falls to near parity. The Czech Republic, by contrast, keeps a supportive signal thanks to its high landfill fee.

Restrictions also need capacity behind them: Seoul’s experience with a direct landfill ban shows what happens when a ban arrives before the treatment infrastructure does.

The report’s six recommendations

RDFIG calls on policymakers to:

1. Ensure landfill is always less attractive than energy recovery. Where there is no effective, enforced ban, a sufficiently high landfill tax should be mandatory – whether the recovery capacity is domestic or in another Member State.
2. Harmonise residual waste taxes, so that treatment decisions reflect capacity, efficiency, heat recovery and access to carbon capture and storage rather than national tax gaps.
3. Make the ETS the default carbon price for incineration, phasing out or redesigning separate incineration taxes accordingly.
4. Standardise carbon-cost pass-through: how fossil carbon is measured, allocated between waste streams and charged on.
5. Keep secondary raw materials competitive with primary ones, without over-taxing the treatment of sorting residues.
6. Support a predictable transition, with ETS revenues backing sorting, fossil-carbon reduction, district heating and CCS.

A critical reading: who benefits from a single European market?

The report was produced by an industry association whose members earn their living from cross-border RDF trade. It is no surprise that its conclusions point towards freer shipments, fewer incineration taxes and European-level capacity planning. That does not make the analysis less transparent: the methodology is explained, sources are listed country by country, and the authors spell out the limits of their stress test.

Others see it differently. Environmental NGOs campaigning against incineration argue that Europe already has incineration overcapacity and that taxing incineration protects prevention and recycling rather than undermining them. Zero Waste Europe’s concern is the opposite of RDFIG’s: that free allowances and phase-ins will leave the carbon price too weak to change anything.

Both camps nonetheless agree on the point that matters most for Hungary: landfill must not be the cheapest way out. Whether the alternative is recovery or recycling, neither can compete with a landfill protected by a low landfill tax and a weak ban.

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Frequently asked questions about landfill tax

How high is landfill tax in Europe in 2026?

According to the RDF Industry Group’s 38-country dataset, 24 countries have a landfill tax and 14 have none at national level. Rates range from about €11 per tonne in Slovenia to €154 in the United Kingdom. Only the UK, Belgium and Latvia exceed €100, while a further seven countries charge more than €60 per tonne.

What is the landfill tax in Hungary?

The report puts Hungary’s landfill levy at HUF 6,000 per tonne, about €16.68, near the bottom of the European range. Hungary has no incineration tax, and untreated municipal waste cannot be landfilled. Even so, the authors list Hungary among the countries that still landfill heavily despite having a landfill tax in place.

Why is it a problem if incineration costs more than landfill?

Because the economic incentive then works against the waste hierarchy: non-recyclable residual waste becomes cheaper to landfill than to recover. Landfills emit methane, investment in sorting and pre-treatment fails to pay back, and treating sorting residues gets more expensive, which weakens the competitiveness of recycled materials against virgin ones.

How will a carbon price affect waste incineration by 2030?

The report’s stress test applies €110 per tonne of CO₂, adding about €51.70 per tonne of waste to incineration. In several countries, including Hungary, Italy and Romania, this turns the landfill–incineration tax differential negative. Under the EU proposal, full surrender obligations would apply from 2034, with temporary national opt-outs possible until 2035.

What does the RDF Industry Group recommend?

It makes six recommendations: keep landfill always more expensive than recovery or effectively banned, harmonise residual waste taxes, make the ETS the main carbon price for incineration, standardise carbon-cost pass-through, protect the competitiveness of secondary raw materials, and support investment in sorting, heat recovery and carbon capture and storage.

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🔗 Official sources and references: 👉

• RDF Industry Group: The Uneven Playing Field – How Europe’s Waste Taxes Distort Recovery, Landfill and Trade (October 2026): https://rdfindustrygroup.org/resources/2026-report-the-uneven-playing-field/
• Zöld Ipar Magazin: Iparági jelentés sürget összehangolt reformot az európai hulladéklerakók ügyében (in Hungarian, 22 October 2026): https://zipmagazin.hu/iparagi-jelentes-surget-osszehangolt-reformot-az-europai-hulladeklerakok-ugyeben/
• Technical annex of the report (Tables A1 and A2): country-level tax rates, sources and full results of the 2030 stress test

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