WRAP has published a new report comparing UK residual waste policy with four other countries, commissioned by energy-from-waste operator enfinium.

Circular Economies: Residual Waste Policy – International Findings benchmarks the UK against Japan, the Netherlands, Norway and Portugal across seven policy categories. It finds the UK has most of the elements of a best-practice system in place or planned, but still landfills 12 per cent of its municipal waste. The authors identify EfW as the preferred route for managing what cannot be recycled, provided it sits within the waste hierarchy.

The study comes ahead of Defra's Circular Growth Plan for England, expected in early 2026, and as the sector prepares for the inclusion of EfW in the UK Emissions Trading Scheme from 2028.

WRAP assessed UK waste policy across seven categories: separate collection; recycling targets; landfill restrictions; taxes on disposal and thermal treatment; pay-as-you-throw (PAYT) schemes; extended producer responsibility (EPR); and deposit return schemes (DRS).

The UK has policies in place or planned across almost all of them, with the notable gap of PAYT, last seriously considered in 2008.

The report argues no circular system will ever eliminate residual waste entirely. It cites thermodynamic limits, human sorting error (estimated at 5.5 incorrect disposal decisions per UK household), and technical constraints - cotton fibre recycling, for instance, yields less than 80 per cent of input material. Even if all recyclable material were captured globally, the circularity rate would only rise from 6.9 per cent to around 25 per cent.

In doing this, the report frames residual waste management as a circular economy activity rather than a failure of it. EfW facilities recover value through electricity generation, heat supply, reuse of incinerator bottom ash in construction, and potential carbon capture and storage (CCS). The Oxford Institute for Energy Studies estimates the UK EfW fleet could remove 5-8 million tonnes of CO₂ per annum if CCS can be successfully implemented.

"Designing waste out of the system must remain the priority, but no circular system will ever be 100 per cent waste-free," comments Claire Shrewsbury, Director of Insights and Innovation at WRAP. "This report shows how residual waste can be managed in a way that supports higher-value circular activities, to reduce environmental harm and help extract value from materials that cannot be recycled."

International comparison

The five-country comparison shows markedly different outcomes. Notably, Japan generates the lowest waste per capita at 326 kg per person and has near-zero landfill, but its recycling rate is just 19 per cent, with 75 per cent of waste going to thermal treatment. The Netherlands, which the authors describe as the closest comparator to the UK, achieves a one per cent landfill rate through strict landfill bans since 1995, a thermal treatment tax, and PAYT schemes covering 41 per cent of households.

Norway has the highest waste generation at 728 kg per person and a five per cent landfill rate. But the report flags concerns that over-reliance on EfW may crowd out higher-value material recovery.

Portugal, the authors note, offers a cautionary tale. Despite an escalating landfill tax and thermal treatment tax, it still sends 54 per cent of its municipal waste to landfill. This is attributed to recent policy introduction, limited infrastructure, and low public engagement with sorting.

The report draws a lesson from the Dutch DRS experience. When the Netherlands later added smaller PET bottles and metal cans to its initially narrower scheme, collection rates for those items improved more slowly than for materials included from the start. The authors suggest this underlines the importance of getting scope right before the UK's own DRS launch in October 2027 rather than relying on phased expansion.

Restricted residual waste collections – fortnightly or three-weekly pick-ups, now common across much of the UK – are presented as a politically viable alternative to PAYT. On fly-tipping, the authors say there is no strong evidence that variable charging increases illegal dumping. Only one Dutch municipality out of those operating PAYT has held a referendum to discontinue it.

"Unrecyclable waste is unavoidable, even in the most advanced circular economies," said Wayne Robertson, Chief Commercial and Strategy Officer at enfinium. "Energy from waste plays a critical role in helping the UK to manage this unrecyclable waste in a responsible way, diverting it from climate-damaging landfill, whilst contributing to the UK's energy security with homegrown electricity and heat."

Greater use of heat networks and CCS could improve the circularity of EfW, the report concludes. But it cautions that setting mandatory feedstock material thresholds too high could prevent some materials from being recycled. The UK ETS inclusion of EfW from 2028 is identified as an opportunity to incentivise both CCS and heat network expansion.