Tackling industrial waste Cement kilns versus Incinerators - An environmental comparison


About this Life Cycle Assessment

  1. Three Levels of Information
  2. Rationale – change in taxation on secondary fuels
  3. Publication History

1. Three Levels of Information

The Level 3 texts correspond to the full text of the Life Cycle Assessment
 "LCA of thermal treatment of waste streams in cement clinker kilns in Belgium Comparison to alternative treatment options" a report published in October 2007 by TNO (the Netherlands Organisation for Applied Scientific Research).

The Level 1 is a short summary for non-expert readers of the above assessment and the Level 2 a more detailed summary. Because these summaries are directed to the general public, the results of the environmental comparison are presented separately for each type of environmental impact, in accordance with ISO 14044 – the international standard that specifies requirements and provides guidelines for Life Cycle Assessments.

For experts and decision makers weighed results expressed in artificial monetary terms and underlying assumptions are available in the full report presented in Level 3.

2. Rationale – change in taxation on secondary fuels

The context of the study is the contestation by Febelcem of a decree of the Flemish Region (decreet van 22 december 2006 houdende bepalingen tot begeleiding van de begroting 2007).

This decree modified the taxation rate on waste according to their final treatment. For the first time the tax on waste going to co-incineration is equal to the tax on waste going to incineration plants. From the Febelcem point of view this is in contradiction with the European legislation (waste hierarchy: co-incineration is a recovery operation and has to be preferred to incineration, that is a disposal operation). In addition a tax should be an incentive that favours the best treatment (from an environmental point of view).

However, the Flemish Region (OVAM) argued that incineration and co-incineration present similar environmental impacts (argumentation principally based on the fact that both waste treatment are submit to the same directive on incineration and co-incineration (2000/76/CE)).

The study has been commissioned in order to tackle this controversy and now proves that co-incineration is to be preferred to incineration.

FEBELCEM now feels that the Flemish Region has to revise the taxation rates.

3. Publication History

The Life Cycle Assessment was conducted at the request of Febelcem.


The assessment was authored by a team of experts of the Science and Industry department of TNO: Suzanne de Vos, Jochen Görtzen, Evert Mulder, Tom Ligthart, and Wilfrid Hesseling.

It started in February 2007 and was finalised in June 2007.

Expert panel

The assessment was conducted in cooperation with an expert panel, consisting of

VITO Katleen Briffaerts
Ministère de la Région Wallonne Philippe Decornet (chairman)
OVAM (representing the Flemish authority) Luk Umans and Dries Gommers
Febelcem Benoit Lussis and Michel Calozet
CCB/Italcimenti Eric Derycke (Chef de Département Développement Environnement)
CBR/Heidelberger Cement Fabrice Foucart and Gaetan de Maere (Environmental Affairs Managers)
Geocycle/Holcim Olivier Barbery (Director)
Neosys Jürg Liechti (reviewer)

Comments were provided by the reviewer and several panel members and addressed by TNO.

Final report

The  final report was published in October 2007 and comprised:

Summaries and online publication

The Level 1 and 2 summaries were written in November 2007 by GreenFacts, working under contract with TNO. They were posted online in mid December 2007 in GreenFacts' copyrighted Three-Level Structure.


Translations into French and Dutch of the Level 1 summary will be available by mid-December 2007.

The Three-Level Structure used to communicate this Life Cycle Assessment is copyrighted by GreenFacts asbl/vzw