The upcoming EU Circular Economy Act (CEA)[1] must not create pathways for hazardous waste to be circulated into roads, buildings, and public infrastructure under the label of “circularity.”
A new report (https://zerowasteeurope.eu/wp-content/uploads/2026/05/ZWE_May26_IBA-report.pdf ) by Zero Waste Europe warns that incinerator bottom ash (IBA) — the residue left after burning municipal waste — contains hazardous substances including heavy metals, PFAS, persistent organic pollutants (POPs), and microplastics that can leach into soil and water over time.
This highlights a fundamental challenge for Europe’s circular economy transition: circularity cannot be reduced to keeping materials in economic circulation at all costs. Materials containing hazardous chemicals should not be simply redistributed into new applications and infrastructure.
A truly sustainable circular economy must:
• prioritise prevention and reuse over waste generation and incineration
• integrate chemical, product, and waste policies
• ensure transparency and traceability of chemicals throughout value chains
• prevent the spread of hazardous substances in recycled materials
• support a toxic-free circular economy aligned with health and environmental protection goals
This debate is especially important as the EU develops the Circular Economy Act and expands policies on secondary raw materials, construction materials, and recycled content requirements.
Without strong safeguards, we risk embedding toxic substances into the built environment for decades to come.
The report is an important reminder that waste incineration does not eliminate hazardous chemicals — it often concentrates and redistributes them.
Read the report and press release here: https://zerowasteeurope.eu/library/a-toxic-legacy-bottom-ash-in-europes-circular-economy/
[1] The EU Circular Economy Act is a legislative proposal from the European Commission. Slated for adoption in late 2026 as a cornerstone of the Clean Industrial Deal, it aims to establish a unified single market for secondary raw materials and boost demand for recycled and refurbished products across the bloc.
