INSIGHT by Zero Waste Europe

The EU has a surplus in waste incineration capacities and a moratorium on new incinerators must be considered, urges a new report by the environmental network Zero Waste Europe. 

The report, titled “Enough Is Enough: The case for a moratorium on incineration”, sheds light on the pressing issue, calling for strong coordinated effort at the EU level.

The EU has consistently seen an annual increase of approximately 8 million tonnes in waste incineration capacity from 2004 to 2020. 60 million tonnes of additional waste incineration capacity was spent unused in 2020 alone. By 2023, the total capacity may have soared to around 220 million tonnes.

“Any planned decommissioning would benefit from being carefully coordinated,” the report advises. “Those Member States where excess capacity already exists should consider imposing moratoria, and potentially, managing a reduction in capacity.”

The report finds that even with intervening measures in place, surplus capacity would still stand around the same mark. This suggests a need to reevaluate waste management strategies and policies, according to the report.


“In an era where waste management and environmental sustainability take center stage, the findings of the this study for Zero Waste Europe are clear: it’s time for a moratorium on incineration. With overcapacity looming and recycling targets on the horizon, the European Union must reassess the role of incineration in its waste management hierarchy.”

-Janek Vahk, Zero Pollution Policy Manager at Zero Waste Europe


The report suggests that 5% of incinerators could be decommissioned every year.

The hurdle in downsizing incineration capacity arises from its privileged position within the waste hierarchy, a system that sets the order of preference for waste management methods. The report asserts that this preference is largely “ideological”, highlighting that the decision-making process regarding decommissioning of facilities would be made easier if not for this privileged spot.



“[P]lacing incineration and landfill of suitably pre-treated waste on the same – lowest – tier of the waste hierarchy would likely give greater flexibility to Member States pursuing higher recycling rates, and allow more rapid progress towards climate mitigation,” the report said.

Urgent EU-level coordination is imperative to confront the mounting incineration capacity problem and ensure responsible waste management practices. A re-evaluation of incineration’s role in the waste hierarchy is proposed, with potential reclassification as a disposal operation. The report calls for a reconsideration of the 10% landfill quota, especially for properly treated residual waste.

By December 2024, the Waste Framework Directive mandates an assessment of disposal operations, offering an opportunity to revisit incineration’s role in the waste hierarchy and tackle overcapacity concerns.

“As we approach the Waste Framework Directive’s Article 12 assessment deadline,” Vahksaid, “the call for change is louder than ever – incineration must be reclassified as a disposal operation, with strict criteria for the treatment of municipal waste.”

Zero Waste Europe calls for a moratorium on waste incinerators in the EU to address waste treatment capacity and steer waste management toward a more sustainable path. Coordinated efforts among Member States are deemed essential to tackle these challenges and establish environmentally responsible waste management practices.


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Zero Waste Europe is a European network of communities, local leaders, experts, and change agents working towards the elimination of waste in our society. Advocating for sustainable systems and the redesign of mankind’s relationship with resources, they accelerate a just transition towards zero waste for the benefit of people and the planet.


All opinions expressed are those of the author and/or quoted sources. is an independent and neutral platform dedicated to generating debate around ESG investing topics.