Local authority strategists urge Dutch Parliament to rethink RDF tax

The Association of Directors of Environment, Economy, Planning and Transport (ADEPT) has called on the Dutch Government to rethink its decision to introduce a tax on the import of refuse derived fuel (RDF).

The local government body has sent a position paper to the Dutch Parliament regarding the proposal of a €32 per tonne tax on the import of RDF from 1 January 2020.

ADEPT represents the strategic tier of local government across England, representing county, unitary and metropolitan borough councils.

The position paper argues that the proposed tax would be ‘counterproductive environmentally and economically’, as the lack of energy-from-waste (EfW) infrastructure in the UK would mean that waste would be diverted to landfill.

Baled RDFADEPT also suggests that any increase in available Dutch EfW capacity, occurring as a result of losing imported material, would make the Netherlands’ own recycling efforts less economical, impacting the country’s recycling targets.

Steve Read, Director of Environment and Public Protection at West Sussex County Council, leads on this issue for the ADEPT waste panel. Commenting on ADEPT’s position paper, Read said: “We completely understand and share the objectives of reducing carbon emissions, but this proposal could have the opposite effect.

“It would increase landfill in the UK, stepping hundreds of thousands of tonnes of sorted waste material down the waste hierarchy from energy recovery into landfill.

“We have also urged the Commission [on Climate and Energy] to consider the impacts on recycling levels within the Netherlands. The proposal will create a surplus of energy from waste capacity which could tip the economics of domestic recycling similarly down the hierarchy.”

“The underlying issue is the lack of waste disposal capacity in the UK. While market forces – and increased recycling – are expected to continue to correct this over the next few years, export of RDF has provided a solution with a significantly lower carbon impact than landfill also benefiting the Dutch economy and energy supply network.

“My own authority – West Sussex County Council – exports around 90,000 tonnes of RDF a year roughly equally between the Netherlands and Germany. The economics of RDF export over landfill are marginal and we don’t have sufficient UK capacity to switch into domestic energy from waste facilities.

“ADEPT’s position statement notes that climate change is a transboundary issue. We’ve called on Members of Parliament to consider the overall impact of this proposal from a global perspective and, at the very least, pause the process for full Environmental and Financial Impact Assessments to be made.

“If these changes are implemented, we’ve urged that longer notice is given so that alternative arrangements can be made which can mitigate these very real impacts.”

Uncertainty for waste exports

Lacking the infrastructure to deal with residual waste domestically, the UK and Republic of Ireland are reliant on sending residual waste to mainland Europe, with 3.6 million tonnes of RDF exported every year, 1.3 million tonnes of which were sent to the Netherlands in 2018.

However, after the Netherlands agreed to achieving a 49 per cent reduction in CO2 emissions by 2030 compared to 1999, the Dutch Government announced its proposed import taxes in June, planning to impose an RDF tax of €32 per tonne and a CO2 tax of €30 per tonne of CO2.

These proposals have already faced significant criticism – although the Dutch Government believes that a tax on the import of foreign waste will reduce its carbon impact, the RDF Industry Group has called for the tax to be scrapped, stating that the diversion of RDF to landfill in the UK will in fact result in increased greenhouse gas emissions – the Group estimates that 370,000 tonnes of CO2e were saved in 2018 through the export of RDF from the UK to the Netherlands.

Contingency plans will need to be put in place by councils in the event that the tax does come in, which could lead to negative environmental outcomes such as sending the waste to landfill, depending on a council’s residual waste disposal contract. A spokesperson for ADEPT said: “Contingency plans will depend on the contractual position with off-takers. If councils are obliged to provide a minimum tonnage into a contract and no alternative outlets can be found by the off-taker, councils may have to pay the tax in the short term, however colleagues affected agree the most likely scenario for their authority is reversion to UK landfill.”

Anxiety over the proposed Dutch RDF tax is compounded by the lingering uncertainty over Brexit and the ease with which waste will be able to be exported to the continent following the UK’s withdrawal from the EU.

The Department for Environment, Food and Rural Affairs (Defra) has now confirmed that the frictionless trade of waste materials will continue following the UK’s departure from the EU – deals have been secured with EU member states to maintain 100 per cent of the UK’s notified waste shipments in the event of a ‘no deal’ Brexit.

However, although the legal aspects of waste exports will remain unchanged in the event of a ‘no-deal’ Brexit, it is likely that waste exporters will experience delays at container ports. With 15 per cent of the 3.6 million tonnes of RDF the UK sends to mainland Europe every year travelling through the Port of Dover, changes and disruptions to border controls will cause significant backlogs at the port.

The government has advised waste exporters to take precautionary measures, such as identifying alternative storage facilities or alternative export routes to avoid disrupted ports.

You can read the full position paper on the ADEPT website

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