Joint statement cites evidence of persistent pollutants including PFAS and heavy metals in ash used as construction aggregate.
More than 40 environmental and health organisations have written to EU Environment Commissioner Jessika Roswall calling for incinerator bottom ash (IBA) to be excluded from the forthcoming Circular Economy Act (CEA) until its long-term safety has been independently established.
The joint statement, coordinated by Zero Waste Europe and co-signed by the European Environmental Bureau (EEB), the UK Without Incineration Network (UKWIN) and national zero waste organisations from more than a dozen EU member states, says the use of IBA in construction and civil engineering is "premature and poses potential risks to human health and the environment."
IBA is the solid residue left after municipal waste is burned in energy-from-waste plants. Across Europe, it is increasingly processed into aggregate for use in road construction and civil engineering. The signatories argue that this material contains hazardous substances - persistent organic pollutants (POPs), heavy metals, PFAS and microplastics - that can leach into soil, surface water and groundwater over time under real-world conditions.
The letter cites two independent reports, Toxic Fallout and A Toxic Legacy, as evidence that current testing regimes are inadequate. Testing is often limited to short-term, controlled scenarios that do not reflect how the material behaves once placed in the environment, the groups say. Regulation varies between member states, allowing material that would be classified as hazardous in one country to be used as non-hazardous aggregate in another.
Expected in the second half of 2026, the CEA aims to create an EU single market for secondary raw materials and increase the supply of recycled content. The Commission held a high-level stakeholder dialogue on the Act in late April. Without strong safeguards, the signatories warn, the legislation could normalise the dispersal of hazardous waste streams into the built environment.
Specifically, the groups call for the precautionary principle to be applied to all incineration residues, for harmonised EU-wide safety standards based on long-term environmental conditions, and for full consideration of PFAS, microplastics and other persistent pollutants in any assessment framework. IBA's mineral fraction does not constitute recycling under EU law, the letter states, and its deployment is driven primarily by the need to avoid disposal costs rather than by environmental benefit.
A circular economy "must be non-toxic by design," the statement adds, warning that widespread use of incineration residues risks creating a long-term pollution legacy.
Signatories span more than 20 countries and include GLOBAL 2000 (Friends of the Earth Austria), the Danish Consumer Council, OceanCare, the Plastic Soup Foundation and Arnika's toxics and waste programme.
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There's no easy solution to include glass in the DRS while maintaining a level playing field. Potential approaches include a phased introduction of glass, potentially with higher deposits to reflect its logistical challenges. The government and DMOs could incentivise innovation in glass packaging design and subsidise dedicated return points for glass-handling. Exemptions for smaller businesses unable to handle glass might also be necessary. Any successful solution will likely blend several approaches. It must address the differing priorities of devolved administrations, balance environmental benefits with logistical and cost implications, and be supported by robust consumer education campaigns emphasizing the importance of glass recycling.