The UK waste fuels industry is facing potential challenge from changing Dutch environmental legislation. As part of its new National Climate Agreement the government in the Netherlands is considering imposing a tariff of Euro32/t on imported refuse-derived fuel (RDF) from the start of January 2020. It also wants to add a CO2 tax of Euro30/t on industrial emitters from the start of 2021.

This is bad news for the UK’s waste export market because 1.28Mt or 44% of exported waste fuels from the UK in 2018 went to the Netherlands. The majority of this was RDF. That was more than the next two biggest destinations, Sweden and Germany, combined. Andy Hill of Cynosure Partners summed up the UK situation in the June 2019 issue of Global Cement Magazine when he said, “The UK generates more far more waste than it has landfill, recycling and alternative fuel capacity combined. Quite simply, that’s why the UK exports and has become a leading force in Europe in terms of RDF and solid recovered fuel (SRF) exports.”

Graph 1: International Waste Shipments exported from England, 2011 – 2018. Source: UK Environment Agency.

Graph 2: Destinations of English waste fuels exports in 2018. Source: UK Environment Agency.

Waste management companies and their representative associations on both sides of the North Sea are not taking this terribly well. Robert Corijn, chair of the RDF Industry Group, a European waste organisation, summed up his members response by pointing out both the environmental cost of the new legislation and the risk to jobs in the UK. “RDF export forms a vital and flexible part of the UK’s waste management system, supporting over 6800 additional jobs in the UK, and saving over 0.7Mt/yr CO₂e emissions.” Robert Loos of the Dutch Waste Management Association made a similar response questioning what exactly the Dutch government was attempting to achieve.

Steve Burton, one of the directors of UK-fuels producer Andusia, went further by saying that the Dutch had proposed the move on environmental grounds because it has an incineration capacity of 8Mt/yr but produces only 6Mt/yr of waste. “So they think that by setting a tax it will significantly curtail how much gets incinerated in the Netherlands and thus produce less CO₂. All very sensible if you consider CO₂ in isolation in your own country. However, the Dutch Government aren’t looking at the bigger picture…” He then went on to point out that the RDF would then either get burnt elsewhere or landfilled resulting in no overall CO₂ emissions reduction. His further assessment, which you can read here, goes on to speculate amongst other things that Dutch Energy for Waste (EFW) plants could end up having to cut their gate fees by more than the import tariff in order to keep running. The state-owned EFW plants would then made a loss for the tax payers until the market stabilised. It should be noted that the data from the Environment Agency indicates that Andusia exported just under 38,000t of RDF to the Netherlands in 2018.

The more prickly issues of using waste fuels may prove tricky for Dutch legislators. Corijn’s distinction above of using CO₂e for the savings from RDF usage is important in this argument since burning RDF and alternative fuels, either for generating energy or making cement, still releases CO₂. In the European Union (EU) it’s the biomass fraction of RDF that’s important for the Emissions Trading Scheme (ETS) and the like because biomass emissions are counted as carbon-neutral. Remove this effect and the benefit of waste fuels are more to do with the waste hierarchy and reusing materials rather than leaving them to rot and release methane, a gas with a more potent global warming effect than CO₂. Despite this, at face value, importing rubbish and then burning it to release yet more unwanted CO₂ may seem nonsensical to the parliamentarians. Perhaps the other thing they should consider is that waste-derived fuels are manufactured products to set specifications. On-going arguments around the world about the developed world ‘exporting its rubbish’ frequently ignore this point.

Since the new Dutch National Climate Agreement is currently at the proposal stage it has a long way to go before it becomes law. First it has to be turned into legislation and then this has to be approved by the Dutch Parliament. As indicated so far the waste management industry will continue to fight its corner with vigour.