Incineration in Scotland has increased by 354% since 2011

Scotland’s environmental watchdog is calling for urgent action to prevent an overcapacity of waste incineration that campaigners warn threatens climate goals, public health and the circular economy.

Environmental Standards Scotland (ESS) has reached a formal agreement with the government, which has committed to implementing a series of remedial measures. This follows an ESS investigation triggered by concerns from environmental groups over the government’s failure to act on a key 2022 review recommendation.

The core issue is “incineration lock-in” – a risk of becoming overly reliant on burning waste, undermining recycling and Scotland’s net-zero ambitions.

The ESS report states that reducing overcapacity ‘would support Scotland’s climate objectives, contribute to the development of the circular economy, and prevent unnecessary risk of environmental and human health impacts.’

New figures reveal the scale of the problem: incineration in Scotland has skyrocketed by 354% since 2011, with over 1.86 million tonnes of waste burned in 2024 alone.

Environmental groups, who first raised the alarm in 2023, highlighted that five new incinerators have recently started operations, increasing capacity by almost 1 million tonnes, with several more plants in development. 

Kim Pratt, Senior Circular Economy Campaigner at Friends of the Earth Scotland said: ‘This report is a clear warning that Ministers must take immediate action to halt incineration growth which can harm both people and nature.

‘For years, every decision which the Scottish Government could have used to reduced capacity has been used to expand it instead. Communities in Aberdeen, Fife, Grangemouth, Irvine and Glasgow must now live with these waste burning monsters on their doorsteps, belching out pollution for decades to come.

‘The report from ESS is yet another warning to the Scottish Government that they must close the loopholes in its incinerator moratorium now, before it is too late.”

‘The expansion has happened despite Scottish Government’s 2022 independent review on incineration which concluded that ‘…given the risks that incineration poses to human health and the environment, and the risk of lock-in, Scotland should not construct more capacity than it needs and only some of the currently planned capacity should be built.’

‘Incineration of waste is expensive, emits harmful pollution, contributes to climate change, and prevents effective reuse and recycling.’

Under the agreement, the government must now publish an updated forecast of incineration needs, develop a national “indicative cap” on waste treatment, and integrate this cap into the environmental permitting process. The ESS will monitor progress and is prepared to take further steps if necessary.

In response to the concerns raised by ESS’ investigation, the Scottish Government has agreed to implement the following measures 

• publish an updated forecast of incineration capacity in Scotland
• develop an indicative residual waste treatment cap through the forthcoming Residual Waste Plan (due in 2027)
• integrate the national indicative cap into the Scottish Environment Protection Agency’s permitting framework, ensuring that national capacity is considered when assessing all environmental authorisation applications for capacity changes

Shlomo Dowen, UK Without Incineration Network’s National Coordinator added: ‘Far too much of what is currently incinerated is material that could and should be recycled or composted. Diverting this from incinerators would help improve resource efficiency, enhance soil quality by returning nutrients to the earth, reduce harmful climate emissions, and promote the circular economy. We need to better monitor and restrict access to existing incinerators rather than making things worse by continuing to allow yet more capacity to be permitted.

‘It is therefore very welcome that the ESS has made it clear that they have now undertaken to monitor the Government’s implementation of the Indicative Cap on Incineration Capacity, as well as being poised to take additional steps to ensure delivery where necessary.’