12. Waste Management

Statement on the PSF report with recommendations on technical screening criteria

12. Waste Management

28. The thermal treatment of non-recyclable waste by way of incineration and co-incineration is an integral part of a functioning and climate-friendly circular economy. In this context, thermal waste treatment contributes decisively to the hygienisation of the environment, reduces dependence on fossil fuels such as oil, gas and coal, recovers valuable raw materials and reduces carbon emissions. The thermal use of waste focuses on the processing of non-recyclable residues from recycling processes and waste that is not collected separately. In compliance with strict legal requirements and the waste hierarchy, low-carbon energy or heat is thus used in the respective plants.

On the one hand, thermal processes for the treatment of waste are operated as combined heat and power plants and make an important regional contribution to the goal of Europe and its member states to implement the energy transition towards more renewable energies and less coal and gas use. On the other hand, high-quality refuse-derived fuels from waste make a direct contribution to the substitution of fossil primary energy sources in industrial plants, e.g. in cement production.

Should the thermal utilisation of non-recyclable waste not be considered sustainable in the sense of the EU taxonomy, there is a danger that in the future the necessary access to the capital market will be made more difficult and subsidies will be denied. This would mean that the political goal formulated in the EU's Circular Economy Action Plan of moving away from landfill of waste, for reasons of climate protection among others, and of diverting hazardous substances from the economic cycles, would not be achievable. Without a high-performance infrastructure for the thermal treatment of non-recyclable waste, waste will continue to be disposed of in landfills.

29. As to the treatment of hazardous waste as a means for material recovery (chapter 13.4, Annex Part B), the scope of this chapter should not exclude important waste streams, such as inorganic materials containing metals as well as inorganic materials from incineration processes like ashes, slags and dust. Why the latter is explicitly excluded from the scope of chapter 13.4 is not comprehensible since material recovery of ashes and slags replaces primary materials and prevents their disposal in landfills. Another obstacle to recovery activities could be rooted in the formulation that recovered materials “should substitute virgin materials in production processes”. Since

“production processes” are not defined, important recovery options might be excluded, in particular the direct material recovery of treated waste, e.g. as building material. Hence, we propose to delete the term “production processes” or replace it by “production and recovery processes” .