Bringing incineration into the EU’s carbon market could finally push Europe up the waste hierarchy – not back to landfill, writes Janek Vahk.
As the EU considers bringing waste incineration into its Emissions Trading System (ETS), a familiar warning has resurfaced: put a price on incineration, and Europe will slide backwards into landfill.
It is a compelling argument.
It is also wrong.
New analysis suggests that including incineration in the ETS is unlikely to trigger any large-scale return to landfill. If anything, it could accelerate what European policy has long promised but only partially delivered: less residual waste, more recycling, and lower emissions.
The fear rests on a simple assumption—that waste follows price. Make incineration more expensive, and waste will shift to the cheapest alternative.
But Europe’s waste system is not a normal market.
A system shaped by policy, not price
Across much of the EU, landfill is no longer a viable fallback. In countries such as Belgium, Germany, Sweden and the Netherlands, landfill rates are already below 5%. Together, they account for a large share of Europe’s incineration capacity.
This is not accidental. It is the result of decades of policy: landfill bans, strict treatment requirements, and high taxes that have made disposal both costly and politically unacceptable.
Infrastructure has followed policy. Municipalities are often locked into long-term contracts with incinerators, sometimes for decades. In practice, switching to landfill is not just undesirable- it is often impossible.
So if waste cannot easily move down the hierarchy, where does it go?
The real shift: up the hierarchy
Incineration emits roughly one tonne of CO₂ per tonne of waste, much of it from fossil-based materials such as plastics.
Putting a price on these emissions changes the equation. It creates a direct incentive to remove fossil materials before they are burned.
That means better sorting. More recycling. Less residual waste.
In other words, carbon pricing does not push waste sideways -from incineration to landfill. It pushes it upwards- towards material recovery and circularity.
This is the opportunity the current debate risks missing.
The political fear – and its limits
Concerns about landfill are not entirely unfounded. In a small number of Member States, landfill remains cheaper and less strictly regulated. Some diversion could occur.
But the scale is limited. Only a relatively small share of EU waste flows is realistically at risk.
More importantly, this risk is not an inevitable outcome. It is the result of uneven implementation of EU law.
The Landfill Directive already requires waste to be treated before disposal. Yet enforcement varies widely, and several countries continue to fall short.
This matters because landfill is not a neutral alternative. When untreated waste is dumped, it produces methane—a greenhouse gas far more potent than CO₂ in the short term.
If policymakers are concerned about landfill, the solution is straightforward: enforce the rules that already exist.
A test of policy coherence
The debate over incineration in the ETS is, at its core, a test of Europe’s ability to align its policies.
For years, the EU has promoted the waste hierarchy: prevention, reuse, recycling, recovery, and only as a last resort, disposal. At the same time, it has built one of the world’s most advanced carbon pricing systems.
Yet the two have not always worked together.
Bringing incineration into the ETS would change that. It would make visible the climate cost of burning resources, especially plastics, and reinforce incentives to keep materials in the economy.
But carbon pricing alone is not enough.
To work as intended, it must be paired with:
- strict enforcement of landfill rules
- stronger economic disincentives for disposal
- investment in sorting and recycling infrastructure
- binding targets to reduce residual waste
Without this broader framework, the policy risks being misunderstood—and politically weakened.
Europe’s missed opportunity?
There is a deeper risk in the current debate.
Not that Europe will return to landfill, but that it will hesitate.
For decades, European waste policy has tried to move away from disposal and towards circularity. Progress has been real, but uneven. In some regions, dependence on incineration has become the new lock-in.
The ETS offers a rare chance to correct course.
By pricing incineration, the EU can expose the hidden climate cost of burning materials. By enforcing landfill rules, it can close off the lowest rung of the hierarchy. And by strengthening recycling incentives, it can accelerate the transition to a circular economy.
Or it can delay, and allow structural problems to persist.
The choice is not between incineration and landfill.
It is between maintaining the status quo and finally aligning Europe’s climate and waste policies.
