In 2024 the Netherlands paid € 235 million to the European Union as a plastic own-resource — a levy of € 0.80 per kilogram of non-recycled plastic packaging waste, introduced in 2021 as the EU budget's fourth own resource. The underlying volume: roughly 294,000 tonnes of plastic packaging that does not end up in the recycling stream. For that volume the Netherlands receives a fiscal penalty.

The inverted world of the EU plastic levy

The penalty rests on the assumption that non-recycled plastic is by definition an environmental problem. That assumption holds as long as the plastic is incinerated, which in the Netherlands is currently the fate of some 500 kilotonnes of plastic per year in waste-to-energy plants. Incineration converts 78 per cent of the carbon-in-plastic directly into atmospheric CO₂: 2.64 kg CO₂ per kg plastic, according to the standardised LCA calculations of CE Delft (2021).

For the Netherlands this amounts to roughly 1.32 megatonnes of fossil CO₂ per year from the plastic fraction of incineration alone — a figure that fits within the broader waste-to-energy emissions of 7.2 Mt CO₂ of which 2.7 Mt is fossil, as the government's 2030 Waste Incineration Policy Vision confirms.

But here the problem arises: the levy does not penalise incineration. It penalises "not recycling". And with that, the EU entangles itself in a fundamental logical error, because there is a third option the levy does not recognise — an option that is climatically superior to both recycling and incineration.

The incineration doctrine the EU itself contradicts

As set out earlier in The Brussels Consequence Map — BiCRS version, Europe incinerates around 25 million tonnes of plastic waste per year in waste-to-energy plants. This releases 2.86 kg CO₂ per kilogram of plastic — a total of 71.5 megatonnes of CO₂ per year, equal to roughly 2.4 per cent of total EU emissions.

For comparison: the same amount of heat energy generated from natural gas in a modern CHP installation would produce about one third of that CO₂ emission. Plastic incineration is per delivered kilowatt-hour some 3.7 times more climate-damaging than natural gas combustion for the same energy. This is not a matter of energy content — plastic in fact has a high calorific value. It is a matter of carbon density: fossil plastic contains more carbon per joule than gas.

The consequence: the Netherlands has, over recent decades, built a waste-to-energy infrastructure that is critical for district heating and electricity, but that structurally produces more CO₂ than the gas installations it replaces. And on those emissions we have been paying twice since 2021: once via the national CO₂ tax and EU ETS for waste-to-energy plants (mandatory since 2024), and once via the plastic own-resource levy to Brussels.

What plastic actually is: an above-ground carbon store

On a timescale of five hundred to five thousand years, plastic without UV exposure is non-degrading. Polyethylene films from the 1950s found in soils are still structurally intact. Polymer chains break down only under the influence of photons (UV), oxygen radicals, or enzymatic processes that at room temperature and without catalysis require hundreds of generations.

This makes plastic, in a UV-free, chemically inert environment — for example at two hundred metres depth in a sealed lignite pit — one of the most stable carbon-storage forms humans know. More stable than biochar (which slowly decays), comparable to coal and gas (which are geologically stable for hundreds of millions of years), and with one crucial advantage: there is no economic temptation to dig it back up. Who would want to recover what we deliberately shielded away?

The EU itself has recognised this principle in the Carbon Removals Certification Framework (CRCF), which since 2024 certifies permanent carbon removal (>1,000 years) as a tradeable carbon credit. Bio-CCS, DAC storage and biochar are explicitly in the framework. Structurally stable plastic in geological storage is not.

That is not a physical question. It is a political one.

The arithmetic for the Netherlands

If the EU applied its own CRCF logic consistently to the plastic fraction that today disappears into Dutch waste-to-energy plants, the balance sheet would look as follows:

Fiscal reversal: € 433 million per year. From net payer, the Netherlands becomes a net producer of climate performance — for the same plastic stream, only with a different final destination.

At the ETS prices expected for 2030 (€ 100-130 per tonne CO₂ per the European Commission Impact Assessment 2024) the reversal rises to € 500-600 million per year.

At EU-27 level, with the 25 megatonnes of plastic that annually vanish into waste-to-energy plants: € 5.4 billion per year in potential carbon-credit value, against current plastic-levy revenue of roughly € 6.4 billion. For two thirds of that amount, the EU could eliminate its entire plastic perverse incentive.

What the money should do: biobased polymers that do not decay

The reversed money stream should serve one purpose: the development and market scale-up of biobased permanent polymers.

This is a materially different direction from the prevailing policy, which focuses on compostable bioplastics (PLA, PHA, starch derivatives) — polymers that do decay, and thereby return their stored carbon to the atmosphere within years to decades. For carbon storage, compostability is a defect, not a feature.

What matters are three categories:

1. Bio-PE, bio-PP, bio-PET — chemically identical to their fossil equivalents, but with carbon derived from atmospheric CO₂ via biomass (sugarcane, corn, C4 grasses). Braskem already produces bio-PE commercially in Brazil. Price is currently € 2,500-3,500 per tonne against € 1,200 for fossil PE.

2. PEF (polyethylene furanoate) — Avantium's 100 per cent biobased successor to PET, piloted in Delfzijl, with superior barrier properties. Current price premium is a factor of 2-3 against fossil PET.

3. New classes: bio-nylons, biobased PU, and the third generation in which the sugar-to-monomer route runs no longer via fermentation but via direct catalytic conversion.

With the freed-up € 334 million per year the price premium (€ 1,500/t) can be bridged on some 223,000 tonnes of biobased substitution — well over three quarters of the current Dutch non-recycled packaging volume. With European scale advantages, price parity with fossil polymers should be achievable within ten years.

And crucially: every tonne of biobased polymer that is permanently stored removes 2.86 tonnes of atmospheric CO₂ for good. The whole Carbon-Alert chain that Het Open Vizier has described elsewhere — equatorial biomass via C4 grasses into ethanol and polymers — closes in this model: carbon is drawn out of the air, passes through a productive use cycle, and ends in geological storage in former lignite pits.

The storage infrastructure Europe is already dismantling

The German lignite pits Hambach, Garzweiler and Inden — together more than 23 billion cubic metres of empty volume after their planned closure around 2038 — are the most obvious storage location. They lie in a country that is already planning tens of billions in post-mining rehabilitation, they are deep enough (>100m) to guarantee absence of UV, and they have existing transport and security infrastructure.

For scale: the entire Dutch annual plastic output of about 300,000 cubic metres would fit in one ten-thousandth of the Hambach pit alone. For the full EU output of 25 million tonnes per year, that is one thirtieth. A single lignite pit can absorb more than a century of European plastic production.

The alternatives — Polish salt mines, depleted Dutch gas fields, British coal mines — are comparable in scale and already considered for CO₂ storage under the CCUS Directive 2024. For plastic storage the requirements are in fact simpler: no pressure vessels, no gas leakage monitoring, no risk of groundwater acidification. Solid plastic that is inert stays where it lies.

Three policy proposals

One — CRCF extension for plastic storage

The Netherlands must argue in Brussels for the explicit recognition of structurally stable plastic (fossil and biobased) in geological storage as certified carbon removal under the CRCF. The technical criteria are available; this is a political step.

Two — differentiation of the plastic levy

The current € 0.80/kg levy penalises all non-recycled plastic equally. Restructuring: incinerated plastic keeps the levy (or higher); plastic disposed of in certified permanent storage receives levy exemption and a carbon credit. This is fiscally budget-neutral for Brussels but reverses the incentive.

Three — national biobased polymer fund

The freed resources (€ 235 mn levy + € 99 mn avoided ETS = € 334 mn/year minimum) are earmarked for three purposes: price compensation on biobased permanent polymers for product packaging, R&D into direct catalytic conversion (biomass-to-monomer without fermentation), and the construction of certified geological plastic storage facilities.

The deeper logic

The current plastic levy regime is a classic example of policy that attacks symptoms rather than systems. Plastic is not inherently bad; incinerating plastic is bad. Dumping plastic on open landfill is bad. But plastic itself — as a molecular structure — is precisely what you want when you wish to take carbon out of the atmosphere and do something useful with it before setting it aside.

The EU framework does not make that distinction. It treats "plastic in incinerator chimney" and "plastic in geological storage" identically. That is not sloppiness, it is a political choice from a time when the recycling lobby was more dominant than the climate lobby. Now that the urgency of direct carbon removal is an official EU objective (minus 55 per cent net in 2030, climate-neutral in 2050), that choice is no longer defensible.

The Netherlands has the infrastructure (the port of Rotterdam for logistics), the industry (Chemelot, Delfzijl, Sittard-Geleen), the knowledge (Avantium, DSM, TNO) and the need (2030 climate goals that are unattainable without direct CO₂ removal) to lead this direction. The fiscal swing of € 334 million per year is not small but not enormous either — it is precisely enough to finance an industrial pivot without additional tax burden.

One thing is missing: the recognition that we today pay € 235 million for something we ought to be paid for. And the nerve to say so in Brussels.