The association of German Waste-to-Energy plant operators ITAD criticises a draft law of the ministry of environment, demanding thermal treatment with carbon capture be recognised as material recycling.
Key Takeaways
- ITAD criticises the draft law that fails to recognise thermal treatment with carbon capture as material recycling.
- The organisation calls for a broader definition of ‘material recycling’ to include technology-neutral approaches.
- ITAD argues that thermal waste treatment reduces health and environmental risks, especially from toxic plastics.
- They highlight that thermal treatment can recover carbon from plastics, supporting climate protection.
- Overall, ITAD sees thermal waste treatment as essential for both sustainable disposal and climate goals.
The Interest Group for Thermal Waste Treatment Plants in Germany (ITAD) has critically assessed a current draft bill to amend packaging legislation and stated that the definition of ‘material recycling’ needs to be expanded. The organisation notes that the draft effectively excludes thermal waste treatment that uses carbon capture plants for the recovery of carbon. ITAD is calling for a technology-neutral design that also considers thermal waste treatment with subsequent carbon capture technology.
Furthermore, ITAD points out that the assumption that chemical recycling should be given unconditional preference over thermal waste treatment is not sufficiently substantiated. The organisation refers to the importance of thermal treatment as a complementary method to recycling, particularly to avoid negative impacts on health and the environment from the recycling of toxic plastics.
Proposed Expansion of Recycling Definition
In the draft bill, “material recycling” is defined according to §3 (1) 40 of Regulation 2025/40(EU) as: “Any recovery operation by which waste materials are reprocessed into products, materials or substances whether for the original or other purposes. It includes the reprocessing of organic material but does not include energy recovery and the reprocessing into materials that are to be used as fuels or for backfilling operations.”
ITAD proposes an expanded definition that includes thermal waste treatment with subsequent carbon capture technology. The proposed definition is: “Material recycling is any recovery operation by which waste materials are reprocessed into materials or substances, whether for the original purpose or for other purposes, with the exception of the biological treatment of waste, the reprocessing of organic material, energy recovery without the separation and recovery of carbon, and the reprocessing into materials that are to be used as fuel or for backfilling.”
Questioning The Priority Of Chemical Recycling
From ITAD’s perspective, thermal waste treatment offers several advantages over chemical recycling. The organisation views thermal treatment as an indispensable part of the circular economy to prevent negative health and environmental effects, especially from toxic plastic recycling.
Many plastics contain harmful chemicals that can enter new products and the environment. Thermal treatment allows for the safe disposal of such substances, whereas chemical recycling could potentially reprocess toxic chemicals into new materials, according to ITAD.
Advantages of Thermal Waste Treatment
With downstream carbon capture plants, carbon from plastic packaging can be recovered and used as a secondary raw material, which contributes to climate protection. ITAD criticises the view that chemical recycling is unconditionally preferable to thermal treatment, arguing that this is not factually proven. The organisation refers to studies that highlight the potential and techniques of thermal treatment.
Overall, ITAD regards thermal waste treatment as a central and sustainable method that supports both disposal security and climate protection.
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