I have chosen to start this article by presenting a letter that was sent by European Civil Society Organizations to Ursula von der Leyen a few weeks ago, on 30 September, 2025. 

To: Ursula von der Leyen President of the European Commission and The College of European Commissioners and National Ministers of Environment of the European Union Member States

We, the undersigned, call on the European Commission and EU Member States to immediately halt the approval and construction of new waste incineration facilities across the European Union.

The EU already faces an overcapacity crisis of municipal waste incineration, estimated at 60 million tonnes 1 After Europe meets its existing recycling and waste reduction targets, the current infrastructure will, without any doubt, meet all future needs. Expanding incineration capacity will lock Europe into a burning materials system that directly undermines waste prevention, reuse, and recycling - the top priorities of the EU waste hierarchy and a circular economy.

Waste incineration is increasingly recognised as a growing climate liability. As documented in recent analysis,2 the carbon intensity of energy generated by incineration is higher than that of many conventional energy sources, especially when factoring in the high fossil content of residual waste - largely from plastics. The associated greenhouse gas emissions from incineration, even in energy recovery facilities, directly conflict with the EU's commitments to climate neutrality. Building new incineration facilities now would entrench high-emission infrastructure for decades, making it harder for Member States to meet their climate targets under the EU Green Deal and the Clean Industrial Deal.

Despite improvements in emission controls, growing evidence links waste incineration to serious contamination and potential health harms.3 Contrary to claims that incineration eliminates the need for landfills, up to 16 million tonnes of incineration residues (including hazardous waste) are landfilled annually.4 Communities near incinerators across Europe are exposed to very persistent and toxic pollutants such as dioxins, heavy metals, and PFAS. These have been found in soil, food, and even human bodies, and are associated with cancer, immune dysfunction, and developmental disorders.5 Even legally compliant facilities contribute to repeated, long-term, and cumulative toxic exposures that threaten public health, especially among vulnerable populations.

A moratorium on new waste incineration infrastructure would prevent very high construction costs, unnecessarily high emissions, and harmful pollution. It would also support a just transition toward circular economy infrastructure - such as reuse systems, composting, and advanced recycling - delivering far greater climate, health, and economic benefits. It would also help achieve the goal of the Clean Industrial Deal: to make the EU the world leader in the circular economy.

We call for:

● An immediate EU-wide moratorium on new waste incineration facilities (R1 and D10);

● National and EU strategies to phase down existing capacity; along with

● Investment in circular economy infrastructure that supports a climate-safe, environmentally friendly, and resilient waste management. We remain available should you require any further information or wish to discuss these recommendations in more detail.

Sincerely, The signatories

This letter was not signed by one or two organizations;  it was signed by 156 Civil Society organizations from over 20 European countries including Germany, France, Spain, United Kingdom, Cyprus, Malta, and many others. 

It is the result of many years of experience and scientific studies across multiple countries where residents have been subjected to the health hazards caused by incineration plants.

As you can see, these organizations are asking for an immediate moratorium on incineration in the European Union. Up to now, the EU have stopped funding any new incinerators but falls short of an outright ban. These organizations are pushing for an outright ban and WasteServ want to build two huge incinerators in Malta!! The Civil Society Organizations are not making this request on conjecture but on scientifically proven evidence.

I have highlighted in bold letters the most alarming part of the letter that confirms once again that even legally compliant facilities contribute to repeated, long-term, and cumulative toxic exposures that threaten public health. Considering our small geography and prevailing winds, this exposure applies to the whole island of Malta. WasteServ said EIA studies found no health risk to residents. Could all these organizations be wrong, and WasteServ in Malta be right? Are we prepared to take that risk? I don't think so. 

Apart from the health hazards, waste incineration goes against all efforts towards climate neutrality (a balance between emitting greenhouse gases and removing them from the atmosphere). Malta is committed under the EU Green Deal to comply with the EU target to achieve climate neutrality by 2050. Building incinerators will effectively torpedo any chances of Malta meeting our climate targets because it will commit the country to high greenhouse gas emissions for decades.

A lot of words have been said about implementing a circular economy in Malta. We even have an entity called Circular Economy Malta set up by the Government in 2018 under the Environment Protection Act. This entity should have set up a circular economy infrastructure to implement waste prevention, reuse, and recycling. The harsh reality is that only 17% of municipal waste in Malta is currently recycled against a legally binding target with the EU of recycling 55% of municipal waste by 2025. So, the time is up and we will probably be facing the usual fines for noncompliance. Whilst being a total failure, it also presents us with an opportunity. It means that a huge amount of waste can still be recycled, and this must be done before any incineration is even considered.

Where are our EU credentials? We are proud to be part of Europe but at the same time we make a mockery of their environmental policies. This incineration madness must be stopped before it is too late. Our Minister for the Environment received the above letter. What is she going to do about it? WasteServ must be made to listen and act accordingly. The Minister must set a waste management strategy that is aligned with the direction that the EU has chosen to take. We must stop this cherry picking and stand up to be counted. 

1The case for a moratorium on incineration (2023)

2 Debunking Efficient Recovery: The Performance of EU Incineration Facilities (2023)

3 Waste Incineration and the Environment (2024),

4 Biomonitoring report in Zubieta, Spain (2025),

5 Biomonitoring report in Paris, France