Annex to the open letter

on transitioning to a circular economy without more waste incineration

The aim of this annex is twofold. For one, it challenges the legitimacy of calls for an expansion of energy-from-waste (EfW) incineration capacity in the UK. More importantly, however, it presents an initial blueprint of potential regulations and initiatives for kick-starting a sweeping transformation of the UK’s waste and resource sector, with the aim of accelerating the transition towards net-zero carbon as well as zero waste, a goal that is soundly articulated in the Welsh Government’s recent circular economy consultation document:

We want to achieve our aim of Wales being a zero waste nation by 2050. This means that any discarded materials are recycled and re-circulated within the Welsh economy, with no loss of materials from the system—effectively a 100% recycling rate from all sectors.

This blueprint is designed to help the Government build back better as part of our post-Covid recovery, while also meeting greenhouse gas emissions targets on the way to net-zero carbon emissions. The blueprint is not meant to be exhaustive or conclusive; rather, it is offered as a platform for action.

The annex draws on the rapidly growing literature on how best to transition away from the traditional take–make–dispose model to achieve genuine circularity based on a zero-waste economic model. It comprises the following sections:

 1   How energy-from-waste incineration undermines circularity and the net-zero carbon target
This section spells out why EfW incineration is considered a form of ‘leakage’ from the circular economy and underscores that the ongoing expansion of EfW incineration capacity hampers the UK’s ability to deliver on its net-zero carbon ambitions. It identifies six key factors that make the technology a poor choice for waste and resource management, namely that it:

  1. destroys resources instead of recovering them, costing the UK billions per year

  2. impairs the transition to a circular economy by preventing material reuse and recycling

  3. slows economic recovery and hinders job growth in the circular economy

  4. inhibits the full decarbonisation of the power sector

  5.  is among the costliest means of generating energy and managing waste

  6.  presents serious financial risks as EfW facilities become stranded assets.

2   Transforming the UK’s waste and resources sector: a blueprint for regulatory reform and structural investment
This section proposes measures the Government could implement in six key areas to bring about what the UK Committee on Climate Change calls a ‘step-change towards a circular economy’:

  1. implement enhanced programmes to prevent waste arisings

  2. introduce regulations to improve product lifespan, reuse, repair, and remanufacturing

  3. increase the rate and quality of recycling

  4. require more detailed reporting on product and waste flows

  5. make recycling more attractive than EfW incineration

  6. deliver a circular economy infrastructure investment strategy.