Waste Incineration and Energy from Waste Plants

Swan Energy has produced a guidance document to summarise the Developing the UK Emissions Trading Scheme – UK ETS consultation document under  a number of headlines – one being for Waste Incineration and Energy from Waste Plants.


The Authority is proposing to expand the scope of the UK ETS to include waste incineration with no energy recovery, and energy from waste (EfW). This action aims to incentivise waste management methods like prevention, reuse, and recycling. The Authority also wishes to explore whether the ETS obligations will only apply to incinerators operating above the 20MWth threshold.

The proposal states that the UK ETS should cover the incineration of fossil material by all waste incinerators. This means the UK ETS obligation for robust monitoring, reporting and verification (MRV) would be placed on all operators of waste incinerators. For EfW, this would mean conventional incineration and ATT/ACT (pyrolysis/gasification) would fall under the scope of the UK ETS and pay a carbon price according to their greenhouse gas emissions.

If a waste incinerator or EfW plant processes both fossil and biogenic material, the ETS obligation would only apply to the processing of the fossil waste.

The Authority proposes two methodologies to determine the UK ETS MRV obligations for each plant, by estimating the fossil content that is being incinerated or treated.

  • Individual plant monitoring: This approach would require individual operators to determine the ratio of fossil and biogenic CO2 that is being emitted from their plants.
  • Emissions factor approach: This approach would involve using an estimate for the composition of waste (an ‘emissions factor’). This emissions factor could be national or regional, or each plant could derive their own emissions factor based on international standards for sample collection, preparation, and analysis. This factor would then be multiplied by the tonnes of waste processed by a plant to estimate their emissions from burning fossil waste, and therefore determine their obligation under the UK ETS.


The Authority wishes to hear your thoughts on the following. This section relates to Questions 124 – 146 in the response survey.

  • Do you agree with the proposal to expand the UK ETS to waste incineration and EfW?
  • What would you require to prepare for the expansion of the UK ETS to waste incineration and EfW?2
  • Should all types of waste incinerators be included?
  • Do you agree that the UK ETS MRV obligation should be p2laced on the operators?
  • Do you agree that only CO2 emissions should be reported?
  • Which methodology do you believe should be implemented to determine the UK ETS obligation for waste incinerators and EfW plants?
  • How will ETS inclusion impact stakeholders (e.g., local authorities, customers, consumers, operators of waste incinerators, operators of EfW plants)?
  • Will the expansion of the UK ETS to waste incineration and EfW incentivise the use of landfills?


 If anyone would like to receive our full summary document , please call us on 01484 843867 or email info@swanenergy.co.uk and we’ll be in touch.


Swan Energy has been involved with the UK ETS (formerly EU ETS) since its conception and delivers 100% compliance for our clients. Click here to find out more about our service.

Rebecca Scarratt

Carbon Consultant

Rebecca Scarratt

Carbon Consultant

Rebecca joined the Swan Energy team in 2021, after graduating from the University of Hull with a MSc in Renewable Energy.

In her role at Swan Energy, Rebecca supports the consultancy work the team does with clients across the UK. She has gained experience in the various compliance services we offer. Within the core team, Rebecca is account manager for over 40 UK ETS installations across the healthcare, food manufacturing and energy industry sectors.

Rebecca has managed SECR reporting and ESOS energy auditing for a selection of food manufacturing and retail clients. She has also produced a TCFD report for a large gas and oil company and managed CHPQA applications for NHS clients.