I. Implement enhanced programmes to prevent waste arisings.

The UK’s waste prevention programmes date back to 2013 and are currently under revision. In 2019, Northern Ireland published its updated waste prevention programme, which does not include quantitative targets except for reducing food and drink waste arisings by 20% by 2025 compared to 2015. In updating the waste prevention policy, the UK should:

o   Set ambitious targets with explicit actions for reducing all waste arisings and require that progress against these new goals be consistently monitored and reported.[17]

o   Require local authorities to implement a zero-residual-waste strategy for households using ambitious five-year targets. DEFRA could integrate such a requirement in the Environment Bill and its statutory instruments, based on its proposed exploration of reductions in the per capita tonnage of residual waste.[18] An instructive case study is the Dutch VANG programme, which underpins efforts to cut residual waste from 240 kg per person in 2014 to 100 kg in 2020 and 30 kg in 2025.[19] As of 2018, the average weight of residual waste had dropped to 170 kg per person.[20]

o   Expand efforts to reduce single-use plastics and packaging waste, which together account for the majority of plastic waste. The Government could consider introducing instruments such as:

• a ban on expanded polystyrene food and beverage containers, as well as on products made of oxo-degradable plastic, so as to deliver outcomes that are in line with or better than those promoted in EU Directive 2019/904;[21]

• a target to reduce product packaging density (the weight of packaging per volume of product) for non-food products to incentivise light-weight and new packaging options, as already introduced by industry leaders;[22] and

• a target for packaging reuse to incentivise industrial take-back and reuse schemes as part of extended producer responsibility initiatives.

o   Promote the Food Waste Reduction Roadmap among industry partners[23] to help eliminate the preventable edible portion of food waste—which currently accounts for 60% of commercial and industrial (C&I) arisings and 67% of residual waste in England.[24] Doing so would assist the UK in meeting the requirement for separate food waste collection by 2023,[25] while helping Scotland prepare for its ban on landfilling biodegradable waste by 2025.[26] Progress in this area could be supplemented through measures that prevent supermarkets from throwing away or destroying unsold food (as is already the case in France)[27] and that require companies that process and sell large amounts of food to establish a food waste tracing and prevention programme. 

II. Introduce regulations to enhance product lifespan, reuse, repair, and remanufacturing, with a focus on durable goods such as electronic equipment, home appliances, textiles, and furniture:

o   Instate national targets for reuse. Lessons could be learnt from Spain, which in 2018 introduced a 3% reuse target for household appliances and a 4% target for IT equipment, and from the Flemish region of Belgium, which has a reuse target of 7 kg of material per person by 2022.[28]

o   Adopt legislation to increase the longevity of products and enhance their reparability, including by ensuring that spare parts for equipment and appliances are available for at least ten years after the time of purchase. In this context, the UK could introduce ‘right to repair’ rules that match or surpass the updated EU Ecodesign Directive (2009/125/EC).[29]

o   Require a minimum guaranteed lifespan of equipment and appliances sold on the UK market to tackle premature and planned obsolescence.

o   Introduce ease-of-repair criteria through a dedicated programme with industry. The aims should include enhanced ease of disassembly, access to parts, and provision of repair information[30] to support the UK’s product repair sector and social repair initiatives, such as Restart.[31]

o   Require manufacturers to include lifespan and repairability information on their labels, as such details have been shown to influence purchasing decisions.[32]

III. Increase the rate and the quality of recycling. The CCC’s 2020 Progress Report emphasises the need to roll out universal collection of separated food waste, garden waste, and other recycling across England in 2022–24.[33]

o   Increase the rate of recycling by taking steps to:

• Introduce a legally binding recycling target of 70% by 2030 for England in the Environment Bill, in accordance with the CCC’s 2020 Progress Report, which stresses that achieving this goal ‘will be key to phasing out waste exports and limiting fossil emissions from energy-from-waste plants’.[34]

• Allow local authorities to institute pay-as-you-throw or save-as-you-sort schemes for residents,[35] while guarding against illegal dumping, fly-tipping, and contamination of recycling streams. The evidence for such schemes demonstrates that cities and local authorities with pay-as-you-throw schemes achieve significant reductions in waste arisings, higher recycling rates, and lower overall waste management costs.[36]

o   Enhance the collection, segregation, and treatment of recyclables by electing to:

• Standardise the collection of recyclables by 2023,[37] including by mandating the use of standardised bag colours and sizes across the UK, as a way to help industry provide a uniform waste-to-resource market. 

• Standardise materials used for all packaging by 2023 together with industry, including composition standardisation of packaging for recyclability across food and non-food grade packaging (for example uniform requirements of polymers for plastics packaging),  by updating the 2007 Producer Responsibility Obligations for Packaging Waste.[38]

• Ensure biowaste is collected separately by 2023, as envisioned in the Waste Management Plan for England,[39] with the aim of diverting it from landfill and incineration and redirecting it towards anaerobic digestion (AD), composting, or other organic waste recycling practices. Treated biowaste can be used to replenish English farming soils, which urgently need organic carbon, with the dual aim of future-proofing English agriculture[40] and increasing soil carbon sequestration as a means of reducing atmospheric CO2 levels.[41]

• Impose a ban on the EfW incineration of separately collected biowaste, along with penalties for non-compliance, to ensure that the 2030 ‘zero food waste to landfill’ target does not lead to dramatic increases in food waste to incineration.

• Impose mandatory biowaste sorting and recycling for businesses that handle large amounts of food waste. A useful reference is the French Grenelle II law, which requires businesses that produce more than a threshold tonnage of biowaste per year to sort and recycle their own food waste; the threshold dropped from 120 tonnes in 2012 to 10 tonnes in 2016.[42]

• Mandate single-stream collection incuding the segregation of glass as well as paper and board waste. While this practice is not currently required in England, it is recommended by the British paper and glass industries based on the success of this approach in Wales.[43] Separate glass and separate paper and board collection improves both the quantity and the value of these waste resource streams. In Wales glass recycling is nearing 90% (vs. 68% in England),[44] and 65% of paper and board collected in Wales is processed in the UK (vs. 40% in England),[45] thanks to high collection quality (see point VI, below). Separate glass collection also prevents commingled waste streams from causing damage to processing equipment in material recovery facilities.[46]

• Establish an initiative to reduce contamination[47] in source-separated waste streams under existing industry programmes (such as the UK Plastics Pact or the Business Food Waste Prevention programme[48]). Immediate goals can include replacing sticky labels on fruit and vegetables with laser-coding; further improving glues and residues for use in pre-processing; and substituting recyclable packaging for multi-material packaging that cannot be source-separated.[49]

o   Improve labelling to encourage proper recycling, such as by deciding to:

• Mandate the use of standardised recycling labels on all packaging to reduce consumer confusion. To ensure full participation, the Government could establish its own label scheme. Alternatively, it could fund the On-Pack Recycling Label (OPRL) initiative to make the label widely available, and align it with on-going improvements in source separated recycling systems;[50] the OPRL scheme is currently voluntary and comes at a charge for retailers and brand owners, reducing the incentive for industry to adopt the label.

• Require producers to display the percentage of recycled content on product labels to incentivise the use of recycled content from a marketing perspective.

IV. Require more detailed reporting on product and waste flows based on an assessment of the current collection and reporting of statistics on product reuse, product lifespan, and remanufacturing, so as to enable the evidence-based setting and evaluation of policy targets and standards.

o   Require reporting of durable product stocks and flows in the economy, including lifespan, reuse, repair, and remanufacturing information. Without such data, it will not be possible to measure the circular economy for products. DEFRA and the ONS could jointly institute requirements as part of extended producer responsibility programmes, and by setting up a reporting standard in collaboration with retailers, reuse centres, and repair companies.

o   Require waste collection operators and processors to submit quarterly reports on the capacity of EfW incineration, mechanical biological treatment, landfill, RDF processing, materials recovery facilities (MRFs), and recycling facilities in relation to both local authority-collected waste and C&I arisings,[51] and make standardised local, regional, and national data readily available online. Transparency and access to reliable data is critical to an accurate understanding of the changing relationship between arisings and treatment capacity, as well as of the risk of overcapacity;[52] transparency will also facilitate sector transformation planning. 

o   Require businesses that process and sell a large quantity of food to report on food waste to support the (voluntary) Courtauld 2025 food reduction targets and UN Sustainable Development Goal 12.3 (halving per capita food waste by 2030).

o   Require EfW incinerator operators to report on the waste flows and CO2e emissions of individual facilities on a monthly basis, including the feedstock material composition of the waste inputs and its fossil/biogenic origin, and make the corresponding, standardised local, regional, and national data available online. At present, this data is accessible only in an aggregate format in the National Atmospheric Emissions Inventory, as the majority of incinerator operators do not publish their CO2e emissions data.[53] The reporting should include fossil-derived and biogenic emissions, as specified under the reporting requirements of the Intergovernmental Panel on Climate Change (IPCC): ‘if incineration of waste is used for energy purposes, both fossil and biogenic CO2 emissions should be estimated. Only fossil CO2 should be included in national emissions under Energy Sector while biogenic CO2 should be reported as an information item also in the Energy Sector.’[54]

V. Make recycling more attractive than EfW incineration by reforming financial incentives to level the playing field for investors.

The current market system of gate fees, subsidies, and financial support schemes has led to significant market distortions that artificially lower the risk and increase the profitability of investments in EfW incineration and RDF treatment plants, while increasing the risk and limiting the profitability of recycling investments.[55] Operators are keeping EfW incinerator and RDF gate fees slightly below the total landfill gate fee (including the landfill tax of £94.15 per tonne as of April 2020), instead of charging market prices based on infrastructure cost, supply, and demand.[56] In the absence of a well-functioning, dynamic residual waste and recycling market, recycling streams are not adequately separated and local authorities are locked into long-term contracts with operators of outdated, unnecessary waste treatment infrastructure. As highlighted by the UK Competition & Markets Authority: ‘The data analysed showed that longer and broader domestic waste collection contracts which can limit competition remain in use by some local authorities and are associated with statistically significantly higher local authority spending.’[57]

To address these challenges, the UK Government should:

o   Modernise and revitalise the market by taking steps to:

• Establish a waste and resources market regulator whose principal duty is to protect the interests of consumers, while also supporting decarbonisation and other government policies, in line with the statutory framework set by Parliament (not unlike Ofwat for water and Ofgem for gas and electricity).

• Place the costs and rewards of waste generation and source separation on residents by developing the business-to-consumer (retail) market, such as through pay-as-you-throw schemes and deposit return schemes.

• Replace long-term waste management contracts with an annual auction system. This shift will involve moving the wholesale market away from static gate fees per tonne in chosen processing routes (such as EfW, RDF, landfill, or MRF) and instead to bidding for processing lots based on expected residual waste arisings and source-separated recycling streams. This approach introduces flexibility and responsiveness into the market, allowing it to adjust to changes in the amount and composition of residual waste. It is similar to the successful electricity market auction system regulated by Ofgem, which has aided greatly in driving down power-sector carbon emissions.[58]

• Apply minimum and maximum gate fees per tonne within the new auction market system—such as a £60/tonne minimum for food waste, in line with Western European rates—to equalise risks and stabilise the market.[59]  

o   Ensure a level playing field by holding EfW incineration to the same standards as all other energy sources:

• Amend the National Policy Statements for energy infrastructure so that renewable energy and low-carbon options include only EfW incinerators that operate as combined heat and power (CHP) plants and that are equipped with either carbon capture and storage (CCS) or carbon capture and utilisation (CCU) technology. From an energy perspective, the main advantage of EfW incineration is that it can deliver a large supply of heat; with CCS or CCU, that supply can be carbon-neutral.[60] The planning framework should be amended to ensure that new incinerators make full use of their waste heat, and that they are equipped with CCS or CCU.[61] Without such requirements, EfW incineration plants cannot achieve carbon neutrality. Even with CHP, EfW incineration emits more CO2 per kWh produced than the current UK grid mix, which means it cannot be treated as a low-carbon source (see point IV in Section 1 of this annex).[62]

• Include EfW incineration in the UK Emissions Trading Scheme and the carbon emissions tax, as a way of introducing competitive abatement costs for CO2 emitted by EfW facilities and ensuring a level playing field for all energy-generating assets.[63]

• Amend the Contract for Difference (CfD) scheme to allow EfW incinerators only if they are equipped with CCS or CCU, as only low-carbon sources should be considered in the government CfD bidding rounds that support technologies in providing a stable, long-term electricity price. At present EfW CHP incinerators can bid in Pot 1—‘established’ technologies—including in the upcoming fourth allocation round, which begins in 2021.[64]

VI. Deliver a circular economy infrastructure investment strategy.

What is needed is a public–private investment and transformation programme akin to Defra’s Waste Infrastructure Delivery Programme (WIDP). As part of the Treasury’s National Infrastructure Strategy, such a programme can be supported by post-Brexit import–export trade instruments. It can be designed to provide a significant boost to the UK’s post-Covid economic recovery, attracting investment from the private sector by allocating funds to circular economy infrastructure and innovation. In addition to locking circularity into the recovery, this approach is able to create more than 200,000 additional jobs and inject more than £35 billion into the UK economy.[65]

o   Integrate a circular economy pillar in the new capital investment programme of the National Infrastructure Strategy. Doing so will help mobilise post-Brexit public–private infrastructure investment, which could be operationalised in the following areas via the proposed national infrastructure bank, whose initial asset base is expected to be £20 billion.[66]

• Remanufacturing. Only 1%–2% of end-of-life durable goods are used in remanufacturing, mainly in the automotive and aerospace sectors.[67] Indeed, this domain has been at a standstill despite an estimated £20.9 billion opportunity.[68] The Government can help to energise remanufacturing by mobilising investment for world-class demonstration facilities. These can draw on and showcase the UK research community’s wealth of cutting-edge knowledge in various focus areas, such as robotic disassembly (University of Birmingham),[69] remanufacturing planning and logistics (University of Strathclyde),[70] and material knowledge for remanufacturing (University of Exeter).[71]

• Reuse and repair. A lack of structural support has limited the professionalisation of reuse and repair operations in the UK. An investment programme that brings together local authorities and non-profits could stimulate the sector’s development. By opening 500 reuse and repair centres and training more than 1,000 repair technicians, for instance, such a programme would significantly prolong the average lifespan of appliances, furniture, and other durable goods, while providing a substantial number of local jobs.

• Low-emission steel production. An estimated 10 million tonnes of steel scrap is produced every year in the UK, but 80% of it is exported instead of put to use in domestic steel plants. At the same time, UK industries require about 15 million tonnes of steel per year and therefore need to import large quantities.[72] The Government can safeguard the future of the steel industry and dramatically reduce its CO2 emissions by mobilising investment in the transformation of existing blast furnace steel plants into energy-efficient electric arc furnaces,[73] which process scrap steel and release less than half of the CO2 emissions generated by traditional plants.[74]

• Glass. Whereas Wales recycles nearly 90% of its glass, England only recycles 68% and sends the remainder to landfill or EfW incineration. The main difference is that Wales has a kerbside glass collection system. As a result, British Glass has called on local authorities to transition to separate collection systems. A government investment programme could facilitate that shift and ensure similarly high recycling levels in England, Scotland, and Northern Ireland, while substantially boosting the UK glass economy (see point III, above).[75]

• Paper and board. The UK is experiencing a significant processing gap: only 3 million of the 7.3 million tonnes (just over 40%) of source-separated paper and board are used in domestic paper mills. A main cause is the low quality of the feedstock, which is attributable to commingled collection. The most effective way to resolve this problem is a switch to source separation of paper and board, which the Government can support through a dedicated investment programme that helps local authorities make the transition.[76]

• Plastics. The UK suffers from a significant plastic reprocessing capacity gap: while about 1 million tonnes of plastic per year are treated in MRFs, less than half (440,000 tonnes) is recycled into new packaging in reprocessing facilities. The plastics packaging tax, which will come into force in April 2022, is expected to exacerbate this challenge.[77] The Government could usefully launch an investment programme to start boosting capacity before the tax takes effect, alongside measures to strongly reduce the usage of single use plastics.

• Biowaste. Substantial investment in processing capacity is required by 2023, when biowaste collections will become obligatory. An additional 5 million tonnes of biowaste—including up to 3 million tonnes of food and up to 1 million tonnes of garden waste—that are currently being disposed of in landfill will need to be processed separately.[78]

o   Align the capital investment programme with past, current, and new smaller investment programmes that cover lessons learnt, complementarity, and continuation, including the £18 million Resource Action Fund,[79] the WRAP Cymru £6.5 million Circular Economy Fund,[80] and the £20 million 2015–20 London Waste and Recycling Board Funds.[81]

o   Carry out an infrastructure needs assessment to inform the capital investment programme. Evaluate all material and waste streams in the context of a circular economy, including the current and planned capacity for reuse, repair, remanufacturing, and recycling.[82]

o   Promote innovation in the circular economy through a five-year catalyst programme with Innovate UK. A budget of around £400 million distributed in about ten rounds would serve to fund a large number of small and medium-sized businesses that are developing circular economy solutions, including better design, durability, reuse, refurbishment, remanufacturing, and advanced recycling solutions that deliver material reductions, product life extensions, enhanced recycling quantities and quality, and carbon savings.[83]

o   Align waste infrastructure investments with circular economy and net-zero targets. In its Sustainable Finance regulation, the European Union specifies that an economic activity qualifies as ‘contributing substantially to the transition to a circular economy, including waste prevention, re-use and recycling’ if it ‘minimises the incineration of waste and avoids the disposal of waste […], in accordance with the principles of the waste hierarchy’.[84] In this context, the UK Government should:

• Reduce the risk of stranded assets by charging DEFRA with examining ‘how waste reduction and higher recycling rates will impact the utilisation of (and need for further) energy from waste plants’ and by tasking it with drafting guidance notes to ‘help align local authority waste contracts and planning policy to these findings’, in line with the CCC’s 2020 recommendations.[85]

• Prohibit public investment in the construction of new EfW incineration capacity. When it was state-owned, the Green Investment Bank invested most of its funds in EfW incineration projects; since its privatisation in 2017 as the Green Investment Group (GIG), all of its investments have gone to large-scale incineration, largely in partnership with incineration giant Covanta.[86] As the CCC underscores in its 2020 Progress Report, ‘Local authorities and private waste management firms need to urgently invest in collection infrastructure and new recycling, composting and anaerobic digestion facilities. There must be sufficient treatment capacity made available before the landfill ban for biodegradable wastes comes into force [in 2025], so that increases in incineration or exports are avoided.’[87]

• Upgrade and extend the £320 million Heat Networks Investment Project (HNIP), which will come to an end in 2022. An extended HNIP can become a focal point for the delivery of heat networks across the UK for long-term zero carbon heating. It would  serve to ensure that a majority of the 54 operational EfW incinerators fully utilise their waste heat and switch to supplying predominantly heat instead of electricity for as long as they remain in use, since less costly renewable sources are readily available for the provision of electricity. At present, only ten EfW incinerators are operating in CHP mode in the UK.[88] An estimated £1.8–3 billion in public investment is needed to unlock £13–22 billion in private investment through the HNIP.[89] An extended HNIP should include arrangements to include a diversity of present and future heat sources alongside EfW incinerators, including industrial waste heat, heat pumps and geothermal energy.

Notes

[1] DEFRA, Digest of Waste and Resource Statistics: 2018 Edition, 2018, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/878124/Digest_of_Waste_and_Resource_Statistics_2018_v2_accessible.pdf.

[2] DEFRA, UK Statistics on Waste, 19 March 2020, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/874265/UK_Statistics_on_Waste_statistical_notice_March_2020_accessible_FINAL_rev_v0.5.pdf.

[3] DEFRA, Our Waste, Our Resources: A Strategy for England, 2018, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/765914/resources-waste-strategy-dec-2018.pdf; Committee on Climate Change, Reducing UK emissions: Progress Report to Parliament, June 2020, https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/.

[4] Nabil Nasr et al., Re-defining Value—The Manufacturing Revolution: Remanufacturing, Refurbishment, Repair and Direct Reuse in the Circular Economy, Summary for Business Leaders, International Resource Panel, United Nations Environment Programme, https://www.resourcepanel.org/reports/re-defining-value-manufacturing-revolution.

[5] Committee on Climate Change, Reducing UK emissions: Progress Report to Parliament, June 2020, https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/.

[6] Policy Connect, MPs call for ‘Scandinavian’ approach to UK waste policy to fuel post-COVID recovery, heat half a million homes, deliver net zero, 2020, https://www.fccenvironment.co.uk/wp-content/uploads/2020/07/EFW-news-release-FINAL-VERSION.pdf.

[7] The Intergovernmental Panel on Climate Change guidelines require emissions from the incineration of waste used for energy purposes to be accounted for in the energy sector. For transparency purposes, we argue that these emissions should also be reported in the waste sector as an information item, since a primary purpose of waste incineration is waste disposal. See IPCC Intergovernmental Panel on Climate Change, IPPC Guidelines for National Greenhouse Gas Inventories, Chapter 5: Incineration and Open Burning of Waste, 2006, https://www.ipcc-nggip.iges.or.jp/public/2006gl/pdf/5_Volume5/V5_5_Ch5_IOB.pdf; Intergovernmental Panel on Climate Change, 2019 Refinement to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories, vol. 5, 2019, https://www.ipcc-nggip.iges.or.jp/public/2019rf/vol5.html.

[8] HM Revenue & Customs, Carbon Emissions Tax, Policy paper, 29 October 2018, https://www.gov.uk/government/publications/carbon-emmisions-tax/carbon-emmisions-tax.

[9] The Scandinavian countries and Finland have all set a target for a carbon-neutral waste and resource sector: Denmark’s target is 2030, Finland’s is 2035, Sweden’s is 2045, and Norway is aiming for a 50% reduction by 2030 and 100% by 2050.

[10] Patrick Mahon, Keith James, and Peter Sainsbury, How moving to a circular economy can help the UK to build back better, WRAP, 29 June 2020, https://wrap.org.uk/sites/files/wrap/How%20a%20Circular%20Economy%20can%20help%20us%20Build%20Back%20Better.pdf.

[11] In 2019 the UK’s total CO2 emissions were estimated at 451 million tonnes, based on which a savings of 68 million tonnes translates into a 15% reduction in economy-wide CO2 emissions. Data sources: Committee on Climate Change, Reducing UK emissions: Progress Report to Parliament, June 2020, https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/; Keith James, Peter Mitchell, and Dorothea Mueller, Extrapolating resource efficient business models across Europe, WRAP, 2016, http://www.rebus.eu.com/wp-content/uploads/2017/07/Extrapolating-resource-efficient-business-models-across-Europe.pdf; Patrick Mahon, Keith James, and Peter Sainsbury, How moving to a circular economy can help the UK to build back better, WRAP, 29 June 2020, https://wrap.org.uk/sites/files/wrap/How%20a%20Circular%20Economy%20can%20help%20us%20Build%20Back%20Better.pdf; CIE-MAP, Resource consumption, industrial strategy and UK carbon budgets, 2018, http://ciemap.leeds.ac.uk/wp-content/uploads/2018/05/Briefing-Note-4.pdf.

[12] Danish Government, Denmark without Waste II: A Waste Prevention Strategy, 2015, https://eng.mst.dk/media/164923/denmark-without-waste-ii_wasteprevention.pdf; Danish Government, Aftale mellem regeringen (Socialdemokratiet) og Venstre, Radikale Venstre, Socialistisk Folkeparti, Enhedslisten, Det Konservative Folkeparti, Liberal Alliance og Alternativet om Klimaplan for en grøn affaldssektor og cirkulær økonomi, 16 June 2020, https://www.regeringen.dk/media/9591/aftaletekst.pdf; Danish Ministry of the Environment and Food and the Ministry of Business Affairs (Miljø- og Fødevareministeriet og Erhvervsministeriet), Strategi for cirkulær økonomi: Mere værdi og bedre miljø gennem design, forbrug og genanvendelse, 2018, https://mfvm.dk/miljoe/strategi-for-cirkulaer-oekonomi/.

[13] European Environment Agency, Overview of national waste prevention programmes in Europe: Finland Country Fact Sheet, 2019, https://www.eea.europa.eu/themes/waste/waste-prevention/countries/finland-waste-prevention-country-fact-sheet/view; Finnish Ministry of the Environment (Ympäristöministeriö), Kierrätyksestä kiertotalouteen: Valtakunnallinen jätesuunnitelma vuoteen 2023, 2018, https://julkaisut.valtioneuvosto.fi/handle/10024/160441; Finnish Ministry of the Environment (Ympäristöministeriö), Jätemäärien ennakointi vuoteen 2030: Painopisteenä yhdyskuntajätteet ja kierrätystavoitteiden saavuttaminen, 2015, https://julkaisut.valtioneuvosto.fi/bitstream/handle/10138/155189/YMra_17_2015.pdf?sequence=1; Finnish Prime Minister’s Office (Valtioneuvoston Kanslia), Valtioneuvoston selvitys: ja tutkimussuunnitelma 2020 taustamuistio, 2019, https://tietokayttoon.fi/selvitys-ja-tutkimussuunnitelma; Finnish Government, Ympäristöministeriö pyytää lausuntoja ehdotuksesta jätelain ja eräiden muiden lakien muuttamisesta, 2020, https://valtioneuvosto.fi/-/ymparistoministerio-pyytaa-lausuntoja-ehdotuksesta-jatelain-ja-eraiden-muiden-lakien-muuttamisesta; SITRA, Kriittinen SIIRT: Suomen Kiertotalouden Tiekartta 2.0., 2019, https://www.sitra.fi/hankkeet/kriittinen-siirto-kiertotalouden-tiekartta-2/.

[14] Government of the Netherlands (Nederlandse Rijksoverheid), Invoering CO2-heffing industrie vanaf 2021, 2020, https://www.rijksoverheid.nl/onderwerpen/belastingplan/belastingwijzigingen-voor-ondernemers/co2-heffing; Government of the Netherlands (Nederlandse Rijksoverheid), Nederland Circulair in 2050, 2016, https://www.rijksoverheid.nl/onderwerpen/circulaire-economie/documenten/rapporten/2016/09/14/bijlage-1-nederland-circulair-in-2050 and https://www.rijksoverheid.nl/onderwerpen/circulaire-economie/nederland-circulair-in-2050; INTERREG cocoon, Landfill Management in the Netherlands, 2018, https://rwsenvironment.eu/publish/pages/126540/landfill_management_in_the_netherlands_cocoon_20180503.pdf; VNG, Uitvoeringsprogramma VANG: Huishoudelijk afval herijking 2018–2020, 2018, https://www.vang-hha.nl/publish/pages/106281/uitvoeringsprogramma_vang-hha_2018-2020.pdf.

[15] Norwegian Environment Agency (Miljødirektoratet), Klimakur 2030, 2020, https://www.miljodirektoratet.no/klimakur; European Environment Agency, Overview of national waste prevention programmes in Europe: Norway Country Fact Sheet, 2016, https://www.eea.europa.eu/themes/waste/waste-prevention/countries/norway-waste-prevention-fact-sheet/view; Afvall Norge, Deponi, 2020, https://www.avfallnorge.no/hva-jobber-vi-med/fagomr%C3%A5der/deponi; Norwegian Environment Agency (Miljødirektoratet), Afvallsplan 2020–2025: Status og planer for avfallshåndtering, inkludert avfallsforebyggingsprogram, 2019, https://www.regjeringen.no/contentassets/c6a9a384d90c4af18bfd8458f3167708/avfallsplan-2020-2025.pdf; Norwegian Environment Agency (Miljødirektoratet), Miljøstatus tema Avfall, 2020, https://miljostatus.miljodirektoratet.no/tema/avfall/.

[16] European Environment Agency, Overview of national waste prevention programmes in Europe: Sweden Country Fact Sheet, 2019, https://www.eea.europa.eu/themes/waste/waste-prevention/countries/sweden-waste-prevention-country-fact-sheet/view; Swedish Parliament, Skatt på avfallsförbränning, 2019, https://www.riksdagen.se/sv/dokument-lagar/dokument/proposition/skatt-pa-avfallsforbranning_H70332/html; Swedish Environmental Protection Agency (Natursvardsverket), Att göra mer med mindre: Nationell avfallsplan och avfallsförebyggande program 2018–2023, December 2018, https://www.naturvardsverket.se/Documents/publikationer6400/978-91-620-6857-8.pdf?pid=23951; Swedish Government (Regeringskansliet), Cirkulär ekonomi: strategi för omställningen i Sverige, 2020, https://www.regeringen.se/informationsmaterial/2020/07/cirkular-ekonomi---strategi-for-omstallningen-i-sverige/.

[17] In the 2013 plan, the Scottish Government committed to a 15% reduction in waste arisings by 2025; the Welsh Government pledged to reduce household as well as commercial and industrial (C&I) waste by 1.2%–1.4% per year until 2050; and DEFRA’s Waste Prevention Programme for England did not set specific targets. See: Scottish Government, Zero Waste—Safeguarding Scotland’s resources: Blueprint for a more resource efficiency and circular economy, 2013, https://www2.gov.scot/Resource/0043/00435308.pdf; Llywodraeth Cymru (Welsh Government), Towards Zero Waste—One Wales: One Planet—The Waste Prevention Programme for Wales, 2013, https://gov.wales/sites/default/files/publications/2019-05/the-waste-prevention-programme-for-wales.pdf; DEFRA, Prevention is better than cure: the role of waste prevention in moving to a more resource efficient economy, 2013, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/265022/pb14091-waste-prevention-20131211.pdf.

[18] DEFRA, Environment Bill: environmental targets, 19 August 2020, https://www.gov.uk/government/publications/environment-bill-2020/august-2020-environment-bill-environmental-targets.

[19] VNG, Uitvoeringsprogramma VANG: Huishoudelijk afval herijking 2018–2020, 2018, https://www.vang-hha.nl/publish/pages/106281/uitvoeringsprogramma_vang-hha_2018-2020.pdf.

[20] NVRD and Rijkswaterstaat, Benchmark Huishoudelijk Afval: Analyse Peiljaar 2018, 5 November 2019, https://businessmonitor.azurewebsites.net/nvrd/BENCHMARK-ANALYSERAPPORT-PJ-2018.PDF.

[21] The ban on plastic straws, stirrers, and plastic-stemmed cotton buds could be expanded to cover these additional products. See European Parliament, Directive (EU) on the reduction of the impact of certain plastic products on the environment, 2019, https://eur-lex.europa.eu/eli/dir/2019/904/oj.

[22] For example, Unilever UK & Ireland have committed to an absolute reduction of 30% in plastic packaging by 2025. Unilever, Unilever announces ambitious new commitments for a waste-free world, 7 October 2019, https://www.unilever.co.uk/news/press-releases/2019/unilever-announces-ambitious-new-commitments-for-a-waste-free-world.html#:~:text=Unilever%20has%20confirmed%20that%20by,plastic%20packaging%20than%20it%20sells.

[23] WRAP, Food Waste Reduction Roadmap, 2020, https://www.wrap.org.uk/food-waste-reduction-roadmap.

[24] WRAP, Compositional analysis of local authority collected and non-local authority collected non-household municipal waste (England), 2020, https://wrap.org.uk/sites/files/wrap/Compositional%20analysis%20of%20LA%20collected%20and%20non-LA%20collected%20non-household%20municipal%20waste%20%28England%29.pdf; WRAP, National municipal waste composition: England 2017, 2019, https://wrap.org.uk/sites/files/wrap/National%20municipal%20waste%20composition_%20England%202017.pdf.

[25] DEFRA, Consistency in recycling collections in England: executive summary and government response, 2019, https://www.gov.uk/government/consultations/waste-and-recycling-making-recycling-collections-consistent-in-england/outcome/consistency-in-recycling-collections-in-england-executive-summary-and-government-response.

[26] Darrel Moore, Scotland’s landfill ban delayed until 2025, Circular, 20 September 2019, https://www.circularonline.co.uk/news/scotlands-landfill-ban-delayed-until-2025/.

[27] Eleanor Beardsley, French Food Waste Law Changing How Grocery Stores Approach Excess Food, NPR, 24 February 2018, https://www.npr.org/sections/thesalt/2018/02/24/586579455/french-food-waste-law-changing-how-grocery-stores-approach-excess-food.

[28] RREUSE, Re-use targets, n.d., https://www.rreuse.org/reuse-targets.

[29] Helen Brown and Julia Hemmings, Sustainability Drives New ‘Right to Repair’ Rules for Household Products in Latest Update to EU Ecodesign Legislation, Global Compliance News, 15 November 2019, https://globalcompliancenews.com/sustainability-drives-new-right-to-repair-rules-household-products-eu-ecodesign-legislation-20191104/.

[30] RREUSE, Easy Product Repair, n.d., https://www.rreuse.org/improving-product-design/.

[31] Restart Project, Website, n.d., https://therestartproject.org/.

[32] European Economic and Social Committee, The Influence of Lifespan Labelling on Consumers, 2016, https://www.eesc.europa.eu/resources/docs/16_123_duree-dutilisation-des-produits_complet_en.pdf.

[33] Committee on Climate Change, Reducing UK Emissions: Progress Report to Parliament, June 2020, https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/; Stephen Jenkinson, Reviewing biowaste treatment in the UK, Resource, 14 August 2020, https://resource.co/article/reviewing-biowaste-treatment-uk.

[34] Committee on Climate Change, Reducing UK Emissions: Progress Report to Parliament, June 2020, https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/.

[35] In Guernsey such a scheme swiftly halved household waste and boosted recycling rates by more than 20%. See BBC News, Guernsey household waste halves under new system, 10 September 2019, https://www.bbc.co.uk/news/world-europe-guernsey-49647409.

[36] For examples, including evidence from Germany, Japan, the United States, and European cities, see the following studies: Juergen Morlok et al., The Impact of Pay-As-You Throw Schemes on Municipal Solid Waste Management: The Exemplar Case of the County of Aschaffenburg, Germany, Resources, 6(1), 2017, https://www.mdpi.com/2079-9276/6/1/8; Christopher Wright, John M. Halstead, and Ju-Chin Huang, Estimating Treatment Effects of Unit-Based Pricing of Household Solid Waste Disposal, Agriculture and Resource Economics Review, 2019, https://www.cambridge.org/core/services/aop-cambridge-core/content/view/BCB860759B12645C695E1C519B61AB9E/S1068280518000023a.pdf/div-class-title-estimating-treatment-effects-of-unit-based-pricing-of-household-solid-waste-disposal-div.pdf; Takehiro Usui and Kenji Takeuchi, Evaluating Unit-Based Pricing of Residential Solid Waste: A Panel Data Analysis, Environmental and Resource Economics, 58, 245–71, https://link.springer.com/article/10.1007/s10640-013-9702-7; Nicole Seyring et al., Assessment of separate collection schemes in the 28 capitals of the EU, European Commission Directorate-General Environment, 2015, https://ec.europa.eu/environment/waste/studies/pdf/Separate%20collection_Final%20Report.pdf.

[37] DEFRA, Consistency in recycling collections in England: executive summary and government response, 2019, https://www.gov.uk/government/consultations/waste-and-recycling-making-recycling-collections-consistent-in-england/outcome/consistency-in-recycling-collections-in-england-executive-summary-and-government-response.

[38] UK Government, The Producer Responsibility Obligations (Packaging Waste) Regulations 2007, 2007, https://www.legislation.gov.uk/uksi/2007/871/contents/made.

[39] DEFRA, Waste Management Plan for England, August 2020, https://consult.defra.gov.uk/waste-and-recycling/waste-management-plan-for-england/supporting_documents/Waste%20Management%20Plan%20for%20England.pdf.

[40] Stephen Jenkinson, Reviewing biowaste treatment in the UK, Resource, 14 August 2020, https://resource.co/article/reviewing-biowaste-treatment-uk.

[41] As the Farm Carbon Toolkit notes: ‘Fixing carbon in soils is one of the few practical means we currently have to actually reduce global atmospheric carbon dioxide levels.’ Farm Carbon Toolkit, Building carbon in farm soils, 2015, https://www.farmcarbontoolkit.org.uk/resources/articles/building-carbon-farm-soils. See also James Mulligan et al., 6 Ways to Remove Carbon Pollution from the Sky, World Resources Institute, 9 June 2020, https://www.wri.org/blog/2020/06/6-ways-remove-carbon-pollution-sky.

[42] ADEME, Waste from large organic waste producers: guide for large producers of organic waste, 2020, https://optigede.ademe.fr/outils-gros-producteurs-dechets-organiques.

[43] British Glass, Getting British Glass Recycling Right for the Future, 2020, https://www.britglass.org.uk/sites/default/files/Getting%20glass%20recycling%20right%20for%20the%20future%20-%20event%20report%20.pdf; UK Confederation of Paper Industries, Quality and Consistent Collections, Position Paper, 2020, https://thecpi.org.uk/library/PDF/Public/Publications/Position%20Papers/PP_QualityConsistent_Aug2020.pdf.

[44] British Glass, Getting British Glass Recycling Right for the Future, 2020, https://www.britglass.org.uk/sites/default/files/Getting%20glass%20recycling%20right%20for%20the%20future%20-%20event%20report%20.pdf.

[45] UK Confederation of Paper Industries, Quality and Consistent Collections, Position Paper, 2020, https://thecpi.org.uk/library/PDF/Public/Publications/Position%20Papers/PP_QualityConsistent_Aug2020.pdf; My Recycling Wales, Paper, 2020, https://myrecyclingwales.org.uk/materials/paper.

[46] WRAP, Dry recyclables: improving quality, cutting contamination, 2015, https://www.wrap.org.uk/sites/files/wrap/Dry%20Recyclables%20Improving%20Quality%20Cutting%20Contamination.pdf; Zero Waste Scotland, Glass Collection & Re-processing Options Appraisal in Scotland, 2012, https://www.zerowastescotland.org.uk/sites/default/files/Glass%20Collection%20%26%20Re-processing%20Options%20report.pdf.

[47] For a classification of such contaminants, see Appendix B of Zero Waste Scotland, Contamination in source-separated municipal and business recyclate in the UK 2013, 2014, https://www.zerowastescotland.org.uk/sites/default/files/Contamination%20in%20source-separated%20municipal%20and%20business%20recyclate%20in%20the%20UK%20report.pdf.

[48] WRAP, Eliminating problem plastics, n.d., https://wrap.org.uk/content/the-uk-plastics-pact; WRAP, Business Food Waste Prevention, n.d., https://wrap.org.uk/food-drink/business-food-waste.

[49] Options include easily separable packaging (bag in a box, layers that are easy to peel off, and water-separable layers); the replacement of multi-layer materials with mono-material multi-layer packaging (such as Zotefoams packaging from the UK); and the introduction of fully biodegradable multi-layer packaging.

[50] On-Pack Recycling Label, Website, https://www.oprl.org.uk.

[51] The current absence of reliable data on C&I arisings has contributed to debates about EfW incineration overcapacity. See DEFRA, Waste Management Plan for England, August 2020, https://consult.defra.gov.uk/waste-and-recycling/waste-management-plan-for-england/supporting_documents/Waste%20Management%20Plan%20for%20England.pdf.

[52] Adrian Judge, Understanding the risk of EfW overcapacity, Letsrecycle.com, 19 August 2020, https://www.letsrecycle.com/news/latest-news/understanding-risk-efw-overcapacity.

[53] Louise Smith and Nikki Sutherland, Waste Incineration Facilities, House of Commons Library, Debate Pack Number CDP 2020/0029, http://researchbriefings.files.parliament.uk/documents/CDP-2020-0029/CDP-2020-0029.pdf.

[54] Intergovernmental Panel on Climate Change, IPPC Guidelines for National Greenhouse Gas Inventories, Chapter 5: Incineration and Open Burning of Waste, 2006, https://www.ipcc-nggip.iges.or.jp/public/2006gl/pdf/5_Volume5/V5_5_Ch5_IOB.pdf; Intergovernmental Panel on Climate Change, 2019 Refinement to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories, vol. 5, 2019, https://www.ipcc-nggip.iges.or.jp/public/2019rf/vol5.html.

[55] For example, Viridor’s owner KKR is in the process of selling its recycling facilities division while maintaining the 11 EfW plants due to the more stable income stream generated by long-term EfW incineration contracts. See Steve Eminton, Viridor’s recycling assets ‘on the market’, 2 October 2020, https://www.letsrecycle.com/news/latest-news/viridors-recycling-assets-on-the-market/.

[56] Environment Agency, Evidence: reasons for trends in English refuse derived fuel exports since 2010, 2015, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/438906/Reasons_for_trends_in_English_refuse_derived_fuel_exports_since_2010_report.pdf.

[57] UK Competition & Markets Authority, Local authority waste contracts: CMA analysis, 2017, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/657858/local-authority-waste-contracts-cma-analysis.pdf.

[58] In this more dynamic market, operators of facilities that process residual waste and recyclables would manage the bidding and investment risk would become market-driven, since infrastructure decisions would reflect expected changes in residual waste and source-separated streams (as opposed to gate fees influenced by the landfill tax, which drives investments artificially towards RDF facilities and EfW incineration, locking local authorities into contracts of 15 years or more).

[59] Stephen Jenkinson, Reviewing biowaste treatment in the UK, Resource, 14 August 2020, https://resource.co/article/reviewing-biowaste-treatment-uk.

[60] This assessment of carbon neutrality is made from the perspective of infrastructure operations. Full carbon neutrality requires measures beyond CCS and CCU, including in the construction sector for EfW facility building materials and with respect to vehicles that transport waste feedstocks.

[61] Birmingham Energy Institute, Energy from Waste and the Circular Economy: Net zero and resource efficient by 2050, 2020, https://www.era.ac.uk/write/MediaUploads/Other%20documents/EfW_Policy_Commission_Report_accessible.pdf.

[62] UKWIN, Evaluation of the climate change impacts of waste incineration in the United Kingdom, October 2018, rev. edn. April 2019, https://ukwin.org.uk/files/pdf/UKWIN-2018-Incineration-Climate-Change-Report.pdf; Bloomberg New Energy Finance, Tumbling Costs for Wind, Solar, Batteries Are Squeezing Fossil Fuels, 28 March 2018, https://about.bnef.com/blog/tumbling-costs-wind-solar-batteries-squeezing-fossil-fuels/.

[63] Dennis Gammer and Susie Elks, Energy from Waste Plants with Carbon Capture: A Preliminary Assessment of Their Potential Value to the Decarbonisation of the UK, Catapult Energy Systems, May 2020, https://es.catapult.org.uk/reports/energy-from-waste-plants-with-carbon-capture/?download=true. A judicial review of the BEIS decision to exclude EfW incineration emissions from the UK Emissions Trading Scheme is currently under way; see Leigh Day, Legal challenge to exclusion of waste incinerators from post-Brexit emissions trading scheme, 7 September 2020, https://www.leighday.co.uk/News/Press-releases-2020/September-2020/Legal-challenge-to-exclusion-of-waste-incinerators.

[64] In the first allocation round two EfW CHP incinerators were awarded at a strike price (guaranteed pricing) of £80 per MWh for 15 years. No plants were awarded in the second or third allocation rounds as they were outbid by lower-cost offshore wind projects. BEIS, Contracts for Difference, 2020, https://www.gov.uk/government/publications/contracts-for-difference/contract-for-difference.

[65] Olivia Rutherford, Circular economy could boost UK economy by £75bn, says WRAP, Waste and Resources Action Programme (WRAP), 29 June 2020, https://resource.co/article/circular-economy-could-boost-uk-economy-75bn-says-wrap; Patrick Mahon, Keith James, and Peter Sainsbury, How moving to a Circular Economy can help the UK to build back better, WRAP, 29 June 2020, https://wrap.org.uk/sites/files/wrap/How%20a%20Circular%20Economy%20can%20help%20us%20Build%20Back%20Better.pdf.

[66] Financial Times, UK Treasury draws up plans for infrastructure bank, 2020, https://www.ft.com/content/0d28fbfd-d829-429b-93ad-190332d2a636; Pinsent Masons, CBI: UK infrastructure bank will encourage private investment, Out-law News, 17 September 2020, https://www.pinsentmasons.com/out-law/news/cbi-uk-infrastructure-bank-will-encourage-private-investment.

[67] Nabil Nasr et al., Re-defining Value—The Manufacturing Revolution: Remanufacturing, Refurbishment, Repair and Direct Reuse in the Circular Economy, Summary for Business Leaders, International Resource Panel, United Nations Environment Programme, https://www.resourcepanel.org/reports/re-defining-value-manufacturing-revolution.

[68] Keith James, Peter Mitchell, and Dorothea Mueller, Extrapolating resource efficient business models across Europe, WRAP, 2016, http://www.rebus.eu.com/wp-content/uploads/2017/07/Extrapolating-resource-efficient-business-models-across-Europe.pdf.

[69] Birmingham Energy Institute, Robotic disassembly and end of life, University of Birmingham, n.d., https://www.birmingham.ac.uk/research/energy/research/reusing-recycling-energy-technologies/robotic-disassembly-end-of-life.aspx.

[70] University of Strathclyde, Sustainability & Remanufacturing Research Group, n.d., https://www.strath.ac.uk/engineering/designmanufacturingengineeringmanagement/sustainabilityresearchmanufacturinggroup/.

[71] University of Exeter, Exeter Technologies Group: Centre for Alternative Materials and Remanufacturing (CALMARE), n.d., http://emps.exeter.ac.uk/engineering/research/etg/centres/calmare/.

[72] Envirotec, Transition to green steelmaking vital to UK industry’s long-term future, says report, 27 May 2019, https://envirotecmagazine.com/2019/05/27/transition-to-green-steelmaking-vital-to-uk-industrys-long-term-future-says-report/.

[73] Colin Richardson and Ronan Murphy, UK unions to ‘fight’ for blast furnace ironmaking, 20 July 2020, https://www.argusmedia.com/en/news/2124601-uk-unions-to-fight-for-blast-furnace-ironmaking.

[74] Julian M. Allwood et al., Steel Arising: Opportunities for the UK in a transforming global steel industry, University of Cambridge, 2019, https://www.uselessgroup.org/sites/www.uselessgroup.org/files/steel-arising-200319_2.pdf.

[75] British Glass, Getting British Glass Recycling Right for the Future, 2020, https://www.britglass.org.uk/sites/default/files/Getting%20glass%20recycling%20right%20for%20the%20future%20-%20event%20report%20.pdf.

[76] UK Confederation of Paper Industries, Quality and Consistent Collections, Position Paper, 2020, https://thecpi.org.uk/library/PDF/Public/Publications/Position%20Papers/PP_QualityConsistent_Aug2020.pdf.

[77] RECOUP, UK plastics reprocessing capacity needs to double by 2022, 21 August 2020, https://www.recoup.org/news/8052/uk-plastics-reprocessing-capacity-needs-to-double-by-2022.

[78] Stephen Jenkinson, Reviewing biowaste treatment in the UK, Resource, 14 August 2020, https://resource.co/article/reviewing-biowaste-treatment-uk; Committee on Climate Change, Reducing UK emissions: Progress Report to Parliament, June 2020, https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/.

[79] WRAP, Resource Action Fund, n.d., https://wrap.org.uk/content/resource-action-fund.

[80] WRAP Cymru, Circular Economy Fund, n.d., https://wrapcymru.org.uk/grants.

[81] London Waste and Recycling Board (LWARB), LWARB launches new £20 million fund for waste infrastructure projects, n.d., https://www.lwarb.gov.uk/lwarb-launches-new-20-million-fund-for-waste-infrastructure-projects/.

[82] Green Alliance and Resource Recovery from Waste Programme, Building a Circular Economy: How a new approach to infrastructure can put an end to waste, 2019, https://www.green-alliance.org.uk/resources/Building_a_circular_economy.pdf.

[83] Green Alliance and Resource Recovery from Waste Programme, Building a Circular Economy: How a new approach to infrastructure can put an end to waste, 2019, https://www.green-alliance.org.uk/resources/Building_a_circular_economy.pdf.

[84] European Union, Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088, Official Journal of the European Union, PE/20/2020/INIT, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0852.

[85] Committee on Climate Change, Reducing UK emissions: Progress Report to Parliament, June 2020, https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/.

[86] Libby Peake, Scandinavians call their waste incineration ‘crazy’, so why copy them?, Green Alliance, 20 July 2020, https://greenallianceblog.org.uk/2020/07/20/scandinavians-call-their-waste-incineration-crazy-so-why-copy-them/; Green Investment Group (Macquarie Group), Financial close achieved on Newhurst Energy-from-Waste Facility, 11 February 2020, https://www.greeninvestmentgroup.com/news/2020/financial-close-achieved-on-newhurst-energy-from-waste-facility.html.

[87] Committee on Climate Change, Reducing UK emissions: Progress Report to Parliament, June 2020, https://www.theccc.org.uk/publication/reducing-uk-emissions-2020-progress-report-to-parliament/.

[88] Tolvik, UK Energy from Waste Statistics 2019, 2020, https://www.tolvik.com/wp-content/uploads/2020/05/Tolvik-UK-EfW-Statistics-2019-Report-June-2020.pdf.

[89] Joshua Emden, Jimmy Aldridge, and Byron Orme, Piping Hot: The Opportunity for Heat Networks in a New Industrial Strategy, Institute for Public Policy Research, March 2017, https://www.ippr.org/files/publications/pdf/piping-hot_Mar2017.pdf; Birmingham Energy Institute, Energy from Waste and the Circular Economy: Net zero and resource efficient by 2050, 2020, https://www.era.ac.uk/write/MediaUploads/Other%20documents/EfW_Policy_Commission_Report_accessible.pdf.