The European Emissions Trading System is Undergoing a Review:
Will this finally lead to the Sacred Cow being challenged?
Dipl.-Ing.(TU) Werner P. Bauer
With the proposal to revise the EU Emissions Trading System (EU ETS), the European Commission initiated a major legislative process on 17 July 2026, one that will set benchmarks worldwide.
"The European Commission aims to strengthen Europe's competitiveness, advance decarbonisation, and reduce dependence on fossil fuels."
For the waste management sector, the key issues are:
- how the integration of thermal waste treatment into the European greenhouse gas emissions trading system is to be implemented; and
- how Europe intends to address the fact that 25% of its waste is still landfilled or ends up in dumps.
Under the EU proposal, operators of municipal waste incineration plants would gradually become responsible for acquiring EU ETS allowances for their verified fossil COâ‚‚ emissions. Operators would be required to purchase allowances covering 25% of their verified fossil emissions in 2031. This share would increase to 50% in 2032, 75% in 2033, and reach 100% from 2034 onwards.
In addition, the proposal provides for the continued free allocation of emissions allowances to eligible district heating installations, access to EU funding for carbon capture technologies, and the use of emissions trading auction revenues to support municipalities.
Unlike operators in other sectors covered by the emissions trading system, operators of waste treatment facilities have only limited influence over the quantity and carbon content of the waste they receive for treatment. Accordingly, the ongoing legislative process will take into account responsibility across the entire value chain in order to distribute costs in accordance with the polluter pays principle.
The Sacred Cow
While emissions from waste incineration will gradually become subject to carbon pricing, emissions from landfills are not intended to be included in the EU ETS. Instead, the Commission proposes the introduction of mandatory monitoring, reporting, and verification of methane emissions from landfills. These requirements would only apply from 2034 onwards. By that time, municipal waste incineration will already be fully subject to the compliance obligations of the EU ETS.
In my view, this section of the EU proposal is difficult to understand—not only for me. It is precisely here that there is considerable potential for medium-term reductions in CO₂-equivalent emissions, as demonstrated by the experience gained over the past two decades with the landfill ban in the DACH countries:
It has been scientifically established that:
- one tonne (Mg) of untreated waste disposed of in a landfill generates, on average, 0.05 tonnes of methane. Converted using GWP20 (20-year Global Warming Potential, factor 86), this means that 1 Mg of waste emits 4.25 Mg of COâ‚‚-equivalent (Themelis, Bourtsalas).
- landfills are among the world's largest anthropogenic sources of methane and are the dominant source of methane emissions within the waste sector. The waste sector is responsible for around one-fifth of global anthropogenic methane emissions. (Global Methane Pledge)
- according to UNEP, "...reducing methane is the strongest lever we have to slow climate change over the next 25 years." (Global Methane Assessment)
Comparative data from the National Inventory Report (NIR) on greenhouse gas emissions show that COâ‚‚ emissions increased between 2021 and 2022 in countries with high landfill rates, while they continued to decline steadily in countries where landfilling is no longer practiced.
See
figure and table:
Table 1: Methane emissions from European landfills, as reported by the Member States in their National Inventory Reports (NIRs).
Anyone who proposes that the monitoring, reporting, and verification of methane emissions from landfills should only begin in 2034 overlooks:
- years of scientific research on landfill emissions;
- the repeated warnings from climate experts (the IPCC is the United Nations body for assessing the science related to climate change);
- the existing evidence of the lasting positive impact that a clear landfill ban has on climate protection (for example, in the DACH countries); and
- the objective of the Global Methane Pledge (GMP), now endorsed by 159 countries and the European Union, to achieve a reduction of at least 30% in global methane emissions by 2030 compared with 2020.
Europe is warming at twice the global average rate. This year alone, 300,000 hectares of land have already burned across Europe, and 250,000 people have been forced to flee their homes because of wildfires. Decarbonisation must not stop at the chimneys of waste incineration plants. Reducing methane emissions from landfills is of crucial importance for slowing climate change.
The amendments proposed by the European Parliament and the Council of the European Union should ensure that countries receive financial support for developing sustainable waste management systems. I cannot think of a better way to use the revenues generated by the EU ETS—both to strengthen the EU's competitiveness and to advance global climate protection.
Yours sincerely,
Werner Bauer
Werner Bauer
Sources:
2022, UNEP, Global Methane Assessment 2030: Baseline Report
2023, ipcc, Neewsroom, INTERLAKEN, Switzerland, March 20, 2023
Comments:
Current U.S. climate policy treats waste-to-energy (WTE) facilities and landfills in fundamentally unequal ways. In the states and regional programs that actually put a carbon price on waste-sector emissions, WTE is brought into the pricing system as a visible stationary source of fossil carbon dioxide, while landfill methane is largely left outside explicit carbon pricing and addressed instead through modeling, reporting rules, technical standards, and aspirational capture targets.
It would be irresponsible for Europe to follow the same path as the United States.
See my paper: "Why U.S. Landfill MRV (Monitoring, Reporting, Verification) and CO2 Treatment Have Serious Structural Flaws"
It would be irresponsible for Europe to follow the same path as the United States.
See my paper: "Why U.S. Landfill MRV (Monitoring, Reporting, Verification) and CO2 Treatment Have Serious Structural Flaws"
06.08.2026 18:53:24
Dear Mr. Bauer,
Thank you for your kind response. I agree that transforming sites such as the Dandora Dumpsite will require strong partnerships, sustainable financing, and effective implementation of circular economy principles to create dignified green jobs and reduce environmental impacts.
Kenya has established a strong policy framework, and the lessons emerging from the EU on methane mitigation and sustainable waste management will be valuable as we strengthen implementation.
I also look forward to staying in touch and exchanging ideas on advancing sustainable waste management and climate action in both Europe and Africa.
Best regards,
Jimmy Owiti
Thank you for your kind response. I agree that transforming sites such as the Dandora Dumpsite will require strong partnerships, sustainable financing, and effective implementation of circular economy principles to create dignified green jobs and reduce environmental impacts.
Kenya has established a strong policy framework, and the lessons emerging from the EU on methane mitigation and sustainable waste management will be valuable as we strengthen implementation.
I also look forward to staying in touch and exchanging ideas on advancing sustainable waste management and climate action in both Europe and Africa.
Best regards,
Jimmy Owiti
01.08.2026 16:45:19
Dear Mr. Owiti, dear Jimmy,
Thank you very much for your feedback and for sharing your perspective from Kenya. Dendora Dumpsite is one of the biggest in Africa. In contrast Kenya's economy is the largest in East and Central Africa, with Nairobi serving as a major regional commercial hub. There must be a way to repair this damage to nature using industry or word banc funding and to establish a waste management system that provides waste collectors and recycladores with jobs that meet their standards for dignity and workplace safety. Let us keep contact.
Best regards
Werner
Thank you very much for your feedback and for sharing your perspective from Kenya. Dendora Dumpsite is one of the biggest in Africa. In contrast Kenya's economy is the largest in East and Central Africa, with Nairobi serving as a major regional commercial hub. There must be a way to repair this damage to nature using industry or word banc funding and to establish a waste management system that provides waste collectors and recycladores with jobs that meet their standards for dignity and workplace safety. Let us keep contact.
Best regards
Werner
30.07.2026 21:36:18
Dear Mr. Bauer,
Thank you for your insightful article. I agree that while the proposed inclusion of waste incineration in the EU ETS is a positive step, greater attention should be given to landfill methane emissions. Given methane's high global warming potential, delaying stronger measures until 2034 risks missing an important opportunity for near-term climate action.
The experience of countries that have phased out landfilling demonstrates the climate benefits of prioritising waste prevention, recycling, and Material Recovery Facilities (MRFs) within a circular economy framework. These lessons are equally relevant for developing countries such as Kenya, where improved waste management can simultaneously reduce emissions, recover valuable resources, and strengthen environmental governance.
The strategic use of EU ETS revenues to support sustainable waste management infrastructure is also commendable and could serve as a model for other regions.
One question that comes to mind is: What implications do you foresee this EU ETS revision having for Africa and other developing economies? As the EU increasingly integrates climate considerations into its regulatory and economic frameworks, could these reforms influence waste management policies, climate finance, carbon markets, investment decisions, or trade requirements in developing countries? It would be valuable to understand how such reforms might support—or challenge—the transition towards a circular economy beyond Europe.
Thank you for stimulating this important discussion.
Jimmy Owiti
Thank you for your insightful article. I agree that while the proposed inclusion of waste incineration in the EU ETS is a positive step, greater attention should be given to landfill methane emissions. Given methane's high global warming potential, delaying stronger measures until 2034 risks missing an important opportunity for near-term climate action.
The experience of countries that have phased out landfilling demonstrates the climate benefits of prioritising waste prevention, recycling, and Material Recovery Facilities (MRFs) within a circular economy framework. These lessons are equally relevant for developing countries such as Kenya, where improved waste management can simultaneously reduce emissions, recover valuable resources, and strengthen environmental governance.
The strategic use of EU ETS revenues to support sustainable waste management infrastructure is also commendable and could serve as a model for other regions.
One question that comes to mind is: What implications do you foresee this EU ETS revision having for Africa and other developing economies? As the EU increasingly integrates climate considerations into its regulatory and economic frameworks, could these reforms influence waste management policies, climate finance, carbon markets, investment decisions, or trade requirements in developing countries? It would be valuable to understand how such reforms might support—or challenge—the transition towards a circular economy beyond Europe.
Thank you for stimulating this important discussion.
Jimmy Owiti
28.07.2026 14:36:54
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