Integration of Landfills into the EU-ETS 1

An option to prevent possible waste diversion from municipal waste incineration?

by Dr. Bärbel Birnstengel, Dr. Jochen Hoffmeister, Sebastian Lübbers, Richard Simpson

This exploratory study assesses whether the potential integration of landfills into the EU-ETS 1 could be a viable strategy to prevent waste streams from being diverted from municipal waste incineration (MWI) to landfills. Such a diversion could result from the potential and currently discussed inclusion of MWI in the EU-ETS 1, leading to additional methane emissions. To this end, the study briefly reviews the existing legal framework, provides an overview of existing data and statistics on relevant waste streams, and assesses factors related to the risk of diversion. After this, the study sketches a potential landfill integration design and discusses its advantages and disadvantages. The study concludes with an outline of further research needs.

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published: German Environment Agency, 4|2026
Keywords: Energy Recovery, Pollution Control, Policy Tax Instruments, Sustainability, Climate, Resource management, Mixed Waste, Methods, Analyses, Data, EU