A new report from Zero Waste Europe warns the EU Circular Economy Act risks entrenching the use of hazardous waste in construction projects.
The report, ‘A toxic legacy: Bottom ash in Europe’s circular economy’, found that the act could embed hazardous waste in roads, buildings and public infrastructure unless strict safeguards are introduced.
The EU Circular Economy Act (CEA) is set to be implemented in 2026 and aims to accelerate Europe’s transition to a circular economy, reduce dependencies on critical raw materials, and strengthen economic resilience.
The report argues that, without stronger safeguards, the legislation could unintentionally accelerate the spread of toxic substances throughout the built environment.
Zero Waste Europe’s (ZWE) report finds that incinerator bottom ash (IBA) contains hazardous substances, including heavy metals, persistent organic pollutants (POPs), PFAS (‘forever chemicals’), and microplastics, all of which can leach into soil and water over time.
IBA is the solid residue left after burning municipal waste. European municipal waste incineration generates more than 12 million tonnes of IBA every year, according to ZWE.
IBA is already widely used in roads, concrete, cement blocks and other construction applications across Europe.
Janek Vähk, Zero Pollution Policy Manager at ZWE, said that circulating IBA back into the economy through construction materials is a ‘major contradiction’ in the EU’s circular economy agenda.
“If a material contains hazardous substances, it should not be used in roads, buildings or public spaces,” Vähk said. “These residues should be properly contained, not dispersed throughout the environment. At present, controlled landfill remains the safest available option.”
The report’s key recommendations include applying the precautionary principle to incineration residues, and not incentivise the use of IBA.
Other recommendations include establishing EU-wide rules for the classification, testing and long-term monitoring of IBA and ensuring municipal waste incineration is fully included in the EU Emissions Trading Scheme.
