The UK government has been advised to reduce the volume of plastics sent to Energy-from-Waste (EfW) plants and accelerate domestic plastic recycling infrastructure, according to the Independent Review of Greenhouse Gas Removals (GGRs) commissioned by the Department for Energy Security and Net Zero (DESNZ).
Led by former Labour MP Alan Whitehead, the review underscores the growing tension between energy recovery and emissions reduction within the country’s decarbonization strategy.
As the UK edges closer to integrating EfW into the Emissions Trading Scheme (ETS) by 2028, the economic and environmental implications of waste incineration are becoming more pronounced. A SUEZ report estimates that inclusion in the ETS will raise EfW operational costs by roughly 50%, adding £48 per tonne to gate fees. The North London Waste Authority projects an additional £35 million per year in waste disposal costs for local residents once carbon pricing takes effect.
At the core of the review is a recommendation to update the national waste hierarchy—a policy framework that traditionally prioritizes prevention, reuse, and recycling—to explicitly recognize carbon sequestration as a legitimate pathway for non-recyclable waste. The review argues that waste materials, particularly those unsuitable for recycling, could play a valuable role as feedstock in greenhouse gas removal technologies such as waste-to-energy with carbon capture and storage (WECCS).
This perspective challenges the traditional justification for EfW plants as efficient waste disposal and energy generation solutions. Instead, it introduces a new evaluative layer: whether such facilities can verifiably capture and store carbon rather than merely displacing fossil-based power generation.
Plastics: The Weak Link in EfW Decarbonization
The review identifies plastic waste as a critical obstacle in aligning EfW with net-zero objectives. Because most plastics are derived from fossil feedstocks, their incineration produces persistent CO₂ emissions even when energy recovery occurs. The report recommends the government introduce measures to curb the proportion of plastics entering EfW streams by incentivizing domestic plastic recycling capacity.
Currently, the UK exports a substantial share of its low-value plastic waste, leaving recycling infrastructure underdeveloped. Without expanded domestic processing capabilities, EfW operators are likely to continue receiving plastic-heavy waste streams, undermining carbon-reduction targets and inflating compliance costs once the ETS comes into force.
The review situates WECCS alongside bioenergy with carbon capture and storage (BECCS) as a cornerstone technology for achieving net-zero emissions. Both are designed to remove CO₂ from the atmosphere rather than merely avoiding new emissions. However, the economics remain uncertain. Implementing carbon capture in EfW facilities demands high capital investment and long-term policy support—conditions that are not yet guaranteed in the UK’s fragmented waste and energy policy landscape.
Meanwhile, the financial burden of carbon pricing looms large. EfW operators face the prospect of higher gate fees and reduced competitiveness if they fail to adopt carbon mitigation technologies. The recent designation of an underground heat transmission main from a London EfW plant as a “nationally significant project” by the Energy Secretary signals government intent to integrate EfW into broader clean energy systems. Still, whether this approach will balance economic feasibility with climate integrity remains in question.
With EfW’s inclusion in the ETS imminent, operators, local authorities, and recyclers face mounting pressure to align financial planning, infrastructure investment, and emissions compliance.

