NAWDO recognises that the export of waste for energy recovery in The Netherlands (NL) has brought environmental and economic benefits for several of our members, allowing them to move waste up the waste hierarchy, conserve resources and apply circular economy principles in a cost advantageous manner representing value for money for British tax payers. NAWDO supports the reduction of greenhouse emissions and the implementation of a more resource efficient society but we are surprised and concerned to find out about the proposal by the Dutch government to implement a new tax at very short notice on UK imported waste sent for energy recovery in NL and have raised the following concerns.
·Assumptions on greenhouse gas emission savings
There is no capacity to treat the affected waste volumes in the UK any other way than via landfill disposal. The proposed import tax will lead to extra emissions of greenhouse gases in the UK after landfill becomes the most cost-effective and convenient option again. Landfilling this waste will generate greenhouse gas emissions 25 times more potent than CO2, endangering climate change commitments and targets which are the exact concerns the Dutch Urgenda court case, the motivator for this tax proposal, is looking to address.
·Assumptions on increased waste recycling
The Dutch tax proposal is merely on energy recovery plant input which does nothing at all to address the origin and cause of waste; product manufacturers and consumption behaviour. We note that NL’s current EFW tax approach already is not very effective in moving waste towards recycling and we do not foresee the tax on waste imports will do anything to improve this situation. In the wake of export restrictions on the poor-quality waste captured by recycling systems and extreme material price volatility the proposal will endanger the already fragile recycling industry in the UK by making it costlier to dispose of its residues.
NAWDO’s concern on increased costs
Several of our members have made long term investment in waste export infrastructure which is now threatened to become obsolete or unaffordable after 1st January 2020 which could also see an end to the employment derived from operating this infrastructure. The proposal will directly lead to higher waste costs of UK local authorities whilst budget austerity and savings are still very serious issues.
NAWDO’s concern around the proposal endangering public hygiene
The proposal is for this tax to be implemented within just 6 months from 1st January 2020 which leaves virtually no environmentally sustainable alternatives. Due to waste export to NL becoming unattractive we envisage delays to waste handling and transportation causing back-ups in the collection system potentially leaving waste uncollected in our member’s communities.
NAWDO remain committed to working with all our stakeholders around fundamentally important issues such as resources and waste management and look forward to NAWDO’s concerns being addressed at the Dutch House of Representatives meeting on Wednesday 3rd July 2019.