A recent official report published by the environmental network Zero Waste Europe (ZWE) on April 16, 2026, firmly refutes industry and political concerns that incorporating municipal waste incinerators into the European Union’s Emissions Trading System (EU ETS) would lead to an increase in landfilling across Europe. The comprehensive analysis, conducted by Equanimator Ltd. and titled “Including incineration in the EU ETS: An assessment of potential impacts on landfilling,” highlights that strict EU legislation, national landfill bans, and established long-term market contracts collectively prevent a return to more polluting practices while actively promoting higher-level waste management strategies.
Unfounded Fears: Why a Renaissance of Landfilling is Unlikely
A central issue in recent European waste management debates has been the potential consequence of mandating waste incineration plants to participate in the EU ETS. Skeptical voices within the industry warned that the new carbon costs associated with carbon dioxide emissions would automatically make the waste incineration process significantly more expensive. The primary concern was that this price increase would incentivize market players to abandon incineration in favor of the cheapest, yet most environmentally polluting alternative: a massive return to the intensive use of landfills.
However, the latest analysis by Zero Waste Europe thoroughly proves that these fears are largely unfounded. The report clearly indicates that the flow of waste is not determined merely by short-term price signals or immediate cost fluctuations. While carbon pricing does indeed raise the operational costs of incineration, the offsetting legal, infrastructural, and economic factors form such strong barriers that they practically eliminate the possibility of a mass reversion to landfilling.
A Series of Legislative and Infrastructural Barriers
The research highlights that European Union and national waste management policies have fundamentally transformed the market over the past few decades. Existing EU directives, stringent member state regulations, and established market structures work in tandem to strictly limit the use of landfills.
The report identifies the following key barriers:
-
Landfill bans and mandatory pre-treatment: In numerous European countries, strict bans on the landfilling of untreated waste are already in full effect. These mandatory pre-treatment regulations, combined with steadily rising landfill taxes, inherently make landfilling more expensive than waste incineration in most cases, even when incineration is burdened by the new carbon costs of the EU ETS.
-
Long-term contracts: Operating municipal waste management systems requires decadal commitments. Infrastructural and service contracts established between municipalities and operators prevent waste management systems from flexibly switching overnight from incineration to landfilling based purely on temporary price fluctuations.
Telling Quantitative Data: Minimal Room for Diversion to Landfills
The Equanimator analysis utilizes concrete quantitative data to demonstrate why the risk of increased landfilling is highly marginal in regions with advanced waste management infrastructures.
The report specifically highlights the examples of Belgium, Germany, and Sweden. Due to the high level of infrastructural development and strict legal constraints in these nations, currently less than 5 percent of municipal solid waste is sent to landfills. In these member states, the practice of landfilling is already so heavily regulated and suppressed that there is virtually no physical or legal room left for any significant diversion or regression. In such highly optimized markets, economic signals unequivocally steer the industry toward superior treatment processes rather than mere disposal.
Countries with Marginal Risk Profiles
Maintaining absolute objectivity, the report acknowledges that the situation is not entirely uniform across all European countries. The researchers found that a marginal risk of increased landfilling exists only for a very narrow group consisting of a “small number of countries.” The common characteristics shared by these specific states include exceptionally low landfill costs coupled with a critical weakness in the legal enforcement mechanisms designed to uphold European directives.
Expert Perspective: Prices Do Not Override the Law
Evaluating the research findings, Janek Vahk, the Zero Waste Policy Manager at Zero Waste Europe, delivered a clear and definitive message to policymakers: “Mere price signals alone do not dictate waste flows in Europe.” The expert emphasized that market behavior is dictated by a highly complex regulatory ecosystem. He further explained: “The combination of landfill restrictions, taxes, and policy commitments means that a shift toward landfilling is not only expensive but strongly constrained by Europe’s policy framework.” Consequently, these comprehensive regulatory measures play a far more dominant role in macro-level decision-making than the short-term cost increases of incineration caused by the ETS.
Climate Protection and Reinforcing the Waste Hierarchy
The study also addresses the critical climate protection aspect of avoiding landfills. Landfills remain one of the most significant sources of methane emissions, which is an extremely potent and dangerous greenhouse gas. Therefore, the strict enforcement of EU waste legislation is not merely an economic issue, but a fundamental environmental necessity.
Based on the findings of the report, Zero Waste Europe concludes that including waste incineration in the EU ETS system does not undermine, but rather specifically supports, the enforcement of the European waste hierarchy—provided that existing European laws are adequately and strictly enforced by the member states.
Reference and Official Source:
-
Zero Waste Europe Press Release (April 16, 2026): Including incineration in the EU ETS will not drive more landfilling, new report finds