Madam President of the European Commission,

Members of the European Commission,

Representatives of the Member States in the Council of the European Union,

Members of the European Parliament,

The organisations signing this letter, including representatives of local authorities, municipal utilities, waste management and waste-to-energy operators, district heating and energy service providers, and housing cooperatives, wish to express their deep concern regarding the proposal to revise the European Union Emissions Trading System (EU ETS), which would bring Waste-to-Energy (WtE) plants into the carbon market from 2031 onwards.

We solemnly call for the complete withdrawal of this measure, which would be unfair, environmentally ineffective, and likely to have significant consequences for local authorities, users and communities.

At a time when households are facing persistent pressure on their purchasing power and local authorities are operating under unprecedented budgetary constraints, this reform would impose an additional cost for EU taxpayers and users of industrial and district heating estimated at nearly €4 billion per year with a CO2 price of €100/tonne (see CEWEP & ESWET Joint Policy Brief, available at

cewep.eu/wp-content/uploads/2026/02/CEWEPESWET_Joi....)

WtE plants are not conventional oil- or gas-fired power generation facilities. They fulfil an essential public service mission: the treatment of residual, non-recyclable municipal waste. Treating these facilities in the same way as traditional energy generation activities subject to the carbon market reflects a fundamental misunderstanding of their role.

Moreover, waste management systems are at different levels of development across the EU. It is therefore essential to strengthen WtE capacity in several Member states to achieve an advanced integrated waste management infrastructure. These countries require a dedicated investment phase at this stage to meet EU waste management targets.

Finally, imposing an additional financial burden on WtE facilities would penalise the final link in the chain, without seeking and prioritising action on the root causes of waste generation, contrary to the polluter-pays principle. Responsibility must first be strengthened upstream, particularly in the forthcoming Circular Economy Act through strong waste prevention, reuse, product recyclability, and extended producer responsibility (EPR) measures.

Beyond this clear misjudgment, numerous studies have shown that the EU ETS reform would primarily generate additional costs without creating any meaningful incentive to reduce CO₂ emissions. Worse still, the financial pressure resulting from this measure risks undermining the ability of local authorities and operators to invest in the modernisation and improvement of these facilities.

This measure also threatens a key component of our energy sovereignty. WtE plants currently supply district heating networks and provide a local, reliable and non-relocatable source of energy. In a context marked by significant geopolitical tensions, with war at Europe's doorstep, our continent should be focusing its efforts on strengthening its strategic infrastructure and enhancing its energy autonomy. Instead, this reform risks weakening a sector that contributes every day to the energy security of our territories.

Our fellow citizens expect Europe to protect them, to support transitions and to encourage investments that deliver tangible benefits. They would not understand why they should be asked to pay more for a measure that delivers no environmental benefits, while its economic consequences would be immediate and certain.

Europe must, of course, continue pursuing its climate objectives. But it must do so with pragmatism, sound judgment and a clear understanding of industrial and territorial realities.

For these reasons, we call on the European Commission, the Council of the European Union and the European Parliament to abandon the proposal to include WtE plants within the EU ETS.