A post by Marc Puyuelo – Head of Strategy
Balancing today’s waste crisis with tomorrow’s need for circular feedstock
1. Introduction
Europe is at a crossroads. With the transposition of the Waste Framework Directive underway, Extended Producer Responsibility (EPR) systems in textiles face a decisive moment.
The present context is complex:
- Reuse markets are collapsing.
- Textile recycling is not yet mature at scale.
- Incineration emerges as the immediate safety valve to absorb volumes and guarantee continuity.
This raises a strategic dilemma: relying too heavily on incineration may solve today’s waste management crisis — but at the cost of constraining tomorrow’s access to recycled feedstock.
And this is where the Ecodesign for Sustainable Products Regulation (ESPR) comes in: when the industry is legally required to incorporate recycled content, will the system be ready to deliver the feedstock, or will it have locked itself into a waste-to-energy pathway?
2. Evidence from Waste Management
2.1. OECD econometric evidence
Kinnaman & Yamamoto (2023) analysed data from 35 OECD countries (1990–2018). Their findings:
- Descriptive data shows a non-linear relationship:
- At low levels of incineration (<30%), recycling and incineration can grow together as landfill decreases.
- Beyond that threshold, recycling rates appear to stagnate or decline as incineration grows.
- Econometric results: the effect of incineration on recycling is negative but statistically not significant.
Interpretation: there is no conclusive proof of substitution, but there are strong indications that excessive reliance on incineration may crowd out recycling at higher levels.
2.2. European plastics trajectory (Plastics Europe, 2022)
Between 2006 and 2020:
- Recycling of post-consumer plastics increased from 23% → 35% (+12 pp).
- Incineration with energy recovery rose from 36% → 42% (+6 pp).
- Landfilling dropped from 40% → 23% (–17 pp).
Interpretation: recycling is advancing — but incineration is also expanding, suggesting that the shift away from landfill is being split between the two, instead of channelling primarily into recycling.
2.3. The case of Flanders (Belgium)
Flanders has become a European frontrunner by using regulation and fiscal tools to constrain incineration:
- The VLAREMA framework prohibits incineration of recyclable waste and enforces strict sorting obligations.
- Municipal waste recovery (reuse + recycling + composting) has reached ~75%.
- The Flemish Climate Plan 2021–2030 sets a target to reduce incineration capacity by 25% by 2030.
This demonstrates how regulatory design can shift the balance: rather than letting incineration grow in parallel with recycling, Flanders prioritises material recovery as the dominant pathway.
3. Key Insight
In textiles, the temptation is obvious: to rely on incineration as a transitional safety valve while recycling capacity scales up. In the short term, this makes sense.
But if incineration becomes the focus of structural investment (CAPEX in plants, long-term contracts), the result could be a lock-in that constrains the very development of textile circularity.
Incineration per se is not necessarily less sustainable than other recycling routes — it always depends on the system in which it is embedded. Yet, given today’s policy agenda and the need to secure recycled feedstock for ESPR compliance, prioritising circularity must remain the clear direction of travel.
4. Conclusion
The lesson is simple but urgent:
- Incineration as a bridge, yes.
- Incineration as a destination, no.
The strategic challenge for textile EPR systems is to ensure that what is meant as transitional does not become permanent — and that, when ESPR obligations on recycled content take hold, the system is ready to supply recycled materials, not merely to dispose of waste.
References
- Kinnaman, T., & Yamamoto, M. (2023). Has Incineration Replaced Recycling? Evidence from OECD Countries. Sustainability, 15(4), 3234. https://doi.org/10.3390/su15043234
- Plastics Europe (2022). Plastics – the Facts 2022. https://plasticseurope.org/wp-content/uploads/2022/12/PE-PLASTICS-THE-FACTS_FINAL_DIGITAL.pdf
- European Environmental Bureau (2020). Member States delay meeting inevitable targets: incineration capacity in Europe. https://eeb.org/wp-content/uploads/2020/11/Member-States-delay-meeting-inevitable-targets_report.pdf
