In the latest industry-wide cabin waste initiative, 25 aviation signatories called for an urgent review of ICW regulations – now seen as the biggest block to truly sustainable onboard hospitality. 

The relevant 2002 Animal By-Products legislation classifies ICW as bio-hazardous waste that must be incinerated or sent to deep landfill. This completely undermines sustainability initiatives onboard and is estimated, by IATA, to block recycling or reuse of up to 40% of the 400,000-450,000 tonnes of Category 1 ICW generated each year. 

The collaborative lobbying for an EU review highlights the Hazard Analysis and Critical Control Point (HACCP) food safety protocols used by airline caterers and claims: “Given the sector’s robust food hygiene controls this biohazardous classification seems disproportionate.” 

No risk assessment 

The EU Commission admitted in November that it has not undertaken any quantitative risk assessment of ICW but IATA’s own research showed no evidence that ICW has caused any animal disease outbreak. IATA also identified that the regulations directly prevent airlines from supporting EU ambitions for a circular economy and reduction of single-use plastic (SUP) usage. 

The signatories say: “In line with the EU’s own better regulation principles, it would seem only appropriate to assess whether this 20-year-old regulation is still fit for purpose and takes the EU’s targets for moving towards a fully circular economy properly into consideration.” 

They urge the EU to undertake its own risk assessment with a view to reviewing the regulations. In the interim, they call on EU member states to harmonise their guidance on the reuse and recycling of airline waste. 

Daniela Stange, Sustainability Manager at IATA, says: “The sector stands ready to contribute towards the drafting of this guidance. Industry engagement is high but while inbound waste goes to incineration there is little incentive for change. Smarter ICW regulations would result in less cabin waste, more material recovery, financial benefits and improved customer satisfaction whilst also supporting high animal health status and contributing to the EU’s ambitious circular economy goals. ICW regulations and lack of harmonisation are the main stumbling block to progress.” 

EU contradictions 

It is hoped that if the contradictions in EU regulations can be overcome, US regulations and the entire global environment for waste could improve. 

In line with this lobbying, the Aviation Sustainability Forum (ASF) has appointed international consultancy Stonehaven and its sustainability firm Robertsbridge to help drive plans to reduce cabin waste, standardise materials and improve circularity. 

ASF Founder, Matt Crane says: “If aviation recovers to the predicted growth pre-pandemic and doubles by 2030 there will be 8.58bn passengers annually. If our sector does not successfully introduce strategies to reduce the carbon it generates, aviation’s contribution to the total sweep of CO2 emissions could grow from 2% to 25% by 2050.” 

Beyond the ICW hurdles, collaboration with airports or local authorities to ensure waste management infrastructure will become key. Currently, airports function differently depending on geographic location and local sensitivity to sustainability. There is no harmonisation on developing suitable recycling facilities globally. 

Royal Schiphol Group supports ICW lobbying efforts and has trialled better recycling systems with KLM Catering Services and Suez, a waste recycling and recovery specialist which took recyclables directly from the aircraft for segregation and onward recycling. 

Gatwick Airport has worked with DHL Supply Chain to champion on-site waste management at a dedicated £3.8m plant with a segregation centre. It turns waste, including ICW and packaging, into on-site heating and powers a water recovery system. Prior to the pandemic it treated 2,200 tonnes of Category 1 waste a year, 20% of the airport’s total, but has the capability to process around 10 tonnes a day. 

Defining responsibility 

Clear understanding of which parties are responsible for waste will be vital. Currently, waste management processers may pay a commission for certain waste. And where caterers are paid per tray item, business dynamics can disincentivise waste reduction. 

Anne de Hauw, of IN Air Travel Experience, is working with experts in resource management, circular economy and energy transition to provide the susta.IN consulting service and believes technology has some answers.

Not an easy discussion

She says: “Waste is not an easy discussion, the vested interests within the supply chain do not support fast progress but we have identified some potential areas for positive change. End-of-life material streams, both inside airports and elsewhere, are currently underutilised but may be suited for a thermal/chemical process which would improve environmental performance. We also see opportunities to source plastics for advanced recycling operations to provide ethylene to the suppliers of plastics materials, and have been working with Lufthansa Group caterers, including gategroup, to progress this. We have also identified plastics suppliers and advanced recyclers in Asia who would be suitable for this.”   

The ultimate win-win she believes would be to link waste recycling with Sustainable Aviation Fuel (SAF) made using biosolids, sustainable ethanol or recovered hydro-processed esters and fatty acids (HEFA). She adds: “We have identified opportunities, particularly in North America, to work with our partners to convert lower-margin and under-performing biosolid processing operations (such as composters and surplus ethanol producers) into SAF production facilities.” 

She also sees opportunities to convert end-of-life materials generated at airports, such as solvents and other liquid industrial wastes, to make renewable natural gas or hydrogen for on-site energy, using existing technologies. 

gategroup is developing a range of solutions, including an off-load analysis tool for airlines who want data insights into their waste, and has been investigating and testing new technologies which can process waste into material suitable for other industries such as construction, biogas, farming and composting.  

New Global Head of ESG at gategroup, Yulia Bolotina, says: “We need to look for improvements all along the value chain. Smarter ICW is crucial for our industry’s waste reduction efforts to make a real impact but there are still low-hanging fruits we can tackle locally now – empowering the customer with data and collaborating to maximise the percentage of re- and up-cycled non-Category 1 waste, educating the passenger on how they can help, as well as designing low carbon menus for example. Sustainability needs have triggered the spark of creativity and new solutions will come as we work together. I am excited to see that.” 

Packaging waste

Focused on food packaging waste, deSter points to wider trends as a steer for aviation. Philippe De Naeyer, Director Sustainability at deSter, says: “We are committed to applying circular economy principles and focusing on reusable items that minimise waste. The current shift in food retail and takeaway regulations towards reusables is a clear sign that change is needed.”   

He accepts the need to clean reusable items at airports brings challenges. “Nevertheless, we are confident that change is on the way, and these installations will eventually come into place because food packaging at the airports (on the ground) falls under national rules and regulations, which more and more promote reusables. We’re committed to designing reusables across the system, including matching trolley equipment and reusable lids which optimise weight, space-saving and washing for smooth handling,” says De Naeyer. 

He sees good existing recycling streams for cans and PET bottles but not for SUP food packaging. “This is made of various materials, but only one is suitable for closed-loop recycling (PET). Moreover, single-use plastic food packaging is often contaminated with food, making cleaning a challenge,” he explains. 

As reusables cannot always be implemented yet, his team is also his team is looking into compostable packaging that can be discarded with food waste, so long as proper treatment of organic waste is available. 

While ICW regulations are an obvious obstacle, De Naeyer encourages airlines and operators to focus on national waste regulations too and to look for local solutions. “Some regulations may mean efficient recycling is not always possible but we can still challenge the status quo as there are definitely opportunities today to create international standards and move forward together.”