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Is your plant covered?
- Waste incineration plants: boilers intended for waste incineration, or where mixed municipal waste is incinerated or more than 40 % of the heat comes from hazardous waste (section 6).
- Co-incineration plants: boilers and furnaces whose main purpose is to produce energy or materials but which use waste as fuel – for example a district heating boiler firing recovered wood (section 7). The measurement requirements are the same, the limit values partly different.
- Exempted fuels. The ordinance does not apply to boilers that burn only vegetable waste from agriculture, forestry or the food industry, fibrous waste from pulp and paper production, cork or certain wood waste. The conditions are in section 17.
- Wood waste is exempt, but not when it can be assumed to contain organic halogen compounds or heavy metals from wood preservatives or surface treatment – for example construction and demolition waste. The Swedish Environmental Protection Agency (Naturvårdsverket) assumes that recovered wood chips on the market are covered.
- Boiler by boiler. The rules apply to each boiler where waste is incinerated, and all the waste must be exempt for the boiler to fall outside them. Other boilers may be covered by the rules on medium or large combustion plants.
What must be measured, and how often?
The measurement requirements are in sections 42–44 of the ordinance (SFS 2013:253) and apply to both waste incineration plants and co-incineration plants. The permanently installed measuring systems (automated measuring systems, AMS) must be quality assured according to EN 14181. The reference method is the standard the systems are calibrated against, or the standard the samples are taken with.
| Parameter | Requirement | Exceptions and details | Reference method |
|---|---|---|---|
| Dust | Continuously | – | EN 13284-1 |
| Total organic carbon (TOC) | Continuously | – | EN 12619 |
| Hydrogen chloride (HCl) | Continuously | A permit condition may allow otherwise, if the limit value can under no circumstances be exceeded (section 44) | EN 1911 |
| Hydrogen fluoride (HF) | Continuously or periodically | Periodically, as often as the metals, if the flue gas cleaning ensures that the HCl limit value is complied with | ISO 15713 |
| Sulphur dioxide (SO2) | Continuously | The same exception as for HCl (section 44) | EN 14791 |
| Nitrogen oxides (NOx) | Continuously | – | EN 14792 |
| Carbon monoxide (CO) | Continuously | – | EN 15058 |
| Flue gas temperature, pressure, oxygen content and water vapour | Continuously | Water vapour does not need to be measured if the sample gas is dried before analysis | O2: EN 14789 H2O: EN 14790 |
| Metals: Cd, Tl, Sb, As, Pb, Cr, Co, Cu, Mn, Ni and V | At least twice a year | Every three months during the first twelve months of operation | EN 14385 |
| Mercury (Hg) | At least twice a year | Every three months during the first twelve months of operation | EN 13211 |
| Dioxins and furans | At least twice a year | Every three months during the first twelve months of operation. Samples of 6–8 hours | EN 1948 |
| Residence time, minimum temperature and oxygen content in the combustion | At least once | When the plant is put into operation, under the most unfavourable conditions that can be foreseen | – |
Where the sampling and measurement points are to be placed is decided in the permit or by the supervisory authority (sections 47–48).
Which limit values apply?
The ordinance's limit values for waste incineration plants are in sections 56–66. They are given in mg/Nm3 dry gas at 11 % O2, or 3 % O2 when waste oil is incinerated. For the half-hourly values it is enough to meet one of two alternatives: A, which no half-hourly average may exceed, or B, which 97 % of the year's half-hourly averages must meet. The permit can have stricter conditions, and the wording of the ordinance is what applies.
| Parameter | Limit value | Averaged over | Half hour: A or B |
|---|---|---|---|
| Dust | 10 | a day | 30 (A) or 10 (B) |
| Total organic carbon (TOC) | 10 | a day | 20 (A) or 10 (B) |
| Hydrogen chloride (HCl) | 10 | a day | 60 (A) or 10 (B) |
| Hydrogen fluoride (HF) | 1 | a day | 4 (A) or 2 (B) |
| Sulphur dioxide (SO2) | 50 | a day | 200 (A) or 50 (B) |
| Nitrogen oxides (NOx, as NO2) | 200 | a day | 400 (A) or 200 (B) |
| Carbon monoxide (CO) | 50 | a day – to be met on 97 % of the year's days | 100 for all half hours in a day, or 150 for 95 % of the day's ten-minute values |
| Cadmium and thallium (Cd + Tl) | 0.05 | a sample of 30 minutes to 8 hours | – |
| Mercury (Hg) | 0.05 | a sample of 30 minutes to 8 hours | – |
| Sb + As + Pb + Cr + Co + Cu + Mn + Ni + V | 0.5 | a sample of 30 minutes to 8 hours | – |
| Dioxins and furans | 0.1 ng/Nm3 | a sample of 6–8 hours | – |
NOx: for 2002 plants (section 12) with an incineration capacity of at most 6 tonnes per hour, 400 applies as the daily average, with no half-hourly value.
Co-incineration: the daily value is derived with the mixing rule (section 71), in which the flue gas flow from the waste is weighted with the values in the table and the flue gas flow from the other fuel with a process limit value from the ordinance or the permit. The values for metals and dioxins apply without a mixing calculation in energy plants, at 6 % O2 for solid and 3 % O2 for liquid fuel; cement kilns and industrial plants have their own rules (sections 67–70 and 97–99).
The BAT conclusions: lower values since December 2023
Waste incineration plants that are industrial emissions activities (covered by the Industrial Emissions Directive) – more than 3 tonnes of non-hazardous waste per hour or 18,000 tonnes per calendar year, or more than 10 tonnes of hazardous waste per day or 2,500 tonnes per calendar year – must also follow the BAT conclusions for waste incineration, (EU) 2019/2010. The BAT-AELs have applied as limit values during normal operation since 3 December 2023 where waste incineration is the main activity, under chapter 1, section 8 of the Swedish Industrial Emissions Ordinance (SFS 2013:250). It is the upper value of the range that may not be exceeded. The values are given in mg/Nm3 at 11 % O2, as the daily average for the continuously measured parameters. According to the Swedish EPA, most co-incineration plants are instead covered by the BAT conclusions for large combustion plants.
| Parameter | The ordinance | BAT-AEL: existing (new) | Monitoring under BAT 4 |
|---|---|---|---|
| Dust | 10 | < 2–5 | Continuously |
| TOC (TVOC in the BAT conclusions) | 10 | < 3–10 | Continuously |
| HCl | 10 | < 2–8 (< 2–6) | Continuously |
| HF | 1 | < 1 | Continuously, or every six months if the HCl levels are sufficiently stable |
| SO2 | 50 | 5–40 (5–30) | Continuously |
| NOx | 200 | 50–150 (50–120) | Continuously |
| CO | 50 | 10–50 | Continuously |
| NH3 | – | 2–10 | Continuously when SNCR or SCR is used |
| N2O | – | – | Once a year with a fluidised bed boiler or SNCR with urea |
| Mercury (Hg) | 50 µg/Nm3 | < 5–20 µg/Nm3 | Continuously. Long-term sampling or measurement every six months only when the waste has a proven low and stable mercury content |
| Cd + Tl | 0.05 | 0.005–0.02 | Every six months |
| Sb + As + Pb + Cr + Co + Cu + Mn + Ni + V | 0.5 | 0.01–0.3 | Every six months |
| Dioxins and furans (PCDD/F) | 0.1 ng/Nm3 | < 0.01–0.06 (< 0.01–0.04) ng I-TEQ/Nm3 | Short-term sampling every six months. Long-term sampling every month, unless the emissions have been shown to be sufficiently stable |
Footnotes for existing plants: NOx 180 where SCR is not applicable, NH3 15 with SNCR without wet cleaning, dust 7 at the incineration of hazardous waste where a bag filter is not applicable. Instead of PCDD/F, the sum of PCDD/F and dioxin-like PCB may be applied: < 0.01–0.08 (new: < 0.01–0.06) ng WHO-TEQ/Nm3. At long-term sampling the upper value for dioxins is 0.02 ng higher, and for mercury 1–10 µg/Nm3 applies.
Periodic values refer to the average of three consecutive measurements of at least 30 minutes, for dioxins a sample of 6–8 hours. BAT 4 and BAT 7 also specify: dioxin-like PCB as for the dioxins (not if the emissions are proven to be below 0.01 ng WHO-TEQ/Nm3), PBDD/F every six months with waste containing brominated flame retardants or continuous bromine injection, benzo(a)pyrene once a year, loss on ignition or TOC in slag and bottom ash every three months.
The measurement year at a waste incineration plant
Establish what applies to the boiler
First decide whether the fuel brings the boiler under the ordinance, and whether the plant is also covered by the BAT conclusions. The ordinance applies on top of the conditions in the permit (section 19), so the monitoring programme needs to cover both. If the position of the measurement points is not set in the permit, you propose a position to the supervisory authority (section 47).
Continuous measurement and ongoing control
The permanently installed measuring systems measure all the time, and the plant's emission data system converts the values to dry gas at standard conditions and the reference oxygen content and validates them. Between our visits you run the ongoing control according to EN 14181 (QAL3), with zero and span checks.
AST every year
Automated measuring systems must be checked at least once a year by parallel measurements with reference methods (section 40). According to EN 14181 the check is done as an AST, with a functional test of the measuring system and at least five parallel measurements. We do the parallel measurement, normally in one day.
QAL2 at least every five years
The ordinance sets no interval of its own for the calibration. EN 14181 requires a QAL2 when the measuring system is new, then at least every five years and after major changes to the plant or the measuring system. We measure in parallel at least 15 times over at least three days and establish the calibration function – read more about QAL2 and AST.
Periodic sampling at least twice a year
We sample metals, mercury, dioxins and furans – and HF if it is not measured continuously. During the first twelve months of operation the measurement is made every three months. We are accredited for the sampling, and the samples are analysed by an accredited laboratory. Coordinate it with an AST or a QAL2 if you can.
Report and annual environmental report
You receive a report from every measurement. All measurement results must be recorded, processed and presented so that the supervisory authority can check that the ordinance and the permit are complied with (section 49). In the annual environmental report the averages are stated before validation (section 106).
How the measured values are compared with the limit values
The half-hourly and ten-minute averages from the permanently installed measuring systems are validated for measurement uncertainty before they are compared with the ordinance's limit values. The measured value is multiplied by 0.90 for CO, 0.80 for SO2 and NOx, 0.70 for dust and TOC and 0.60 for HCl and HF (section 51). The deductions correspond to the largest measurement uncertainty the measuring systems may have at the daily limit value: 10, 20, 30 and 40 % respectively, as a 95 % confidence interval (section 41). The daily averages are then calculated from the validated half-hourly values.
A daily average is invalid if more than five half-hourly averages during the day have been discarded because the measuring system was faulty or under maintenance. At most ten daily averages per year may be discarded for the same reason (sections 52–53). Periodic measurements are not validated. According to the Swedish EPA, no standard deduction is made either when measured values are compared with the BAT-AELs.
If the flue gas cleaning or the measuring system breaks down
If a limit value is exceeded, the incineration of waste may never continue uninterrupted for longer than four hours, and the total time with an exceedance may be at most 60 hours per year (section 29). After a breakdown, operation must be reduced or stopped as soon as practicable. The plant must also have an automatic system that prevents waste from being fed in when the continuous measurements show an exceedance caused by disturbances or faults in the flue gas cleaning (section 28).
In a waste incineration plant the dust concentration may never exceed 150 mg/Nm3 as a half-hourly average during such periods, and the half-hourly values for TOC and CO may not be exceeded then either (section 34). The permit must state the longest time the emissions may exceed the values during technically unavoidable stoppages, disturbances or faults in the cleaning or measuring equipment (chapter 22, section 25 b of the Swedish Environmental Code). If a BAT-AEL is not met, you must inform the supervisory authority immediately (chapter 1, section 9 of the Swedish Industrial Emissions Ordinance).
What do waste incineration measurements cost?
The price depends on how many measuring systems and parameters are to be checked, whether it is a QAL2 with at least three measurement days or an AST, how many periodic samples and analyses are included, the conditions at the measurement site and the travel distance. If you coordinate the AST or QAL2 with the sampling of metals and dioxins, you save travel and measurement days. Request a quote – we reply within two working days. Approximate prices for the most common measurements are in the price guide.
Frequently asked questions about measurement requirements for waste incineration
Does recovered wood (recovered wood chips) count as waste under the ordinance?
The starting point is yes. Wood waste is exempt only if it cannot be assumed to contain organic halogen compounds or heavy metals from wood preservatives or surface treatment (section 17). The Swedish EPA assumes that recovered wood chips on the market are covered. If you fire recovered wood chips in a boiler outside the ordinance, you must make sure that the chips contain no such wood.
How often must metals and dioxins be measured?
At least twice a year, and at least once every three months during the plant's first twelve months of operation (section 43). The requirement covers mercury, cadmium, thallium, antimony, arsenic, lead, chromium, cobalt, copper, manganese, nickel, vanadium, dioxins and furans.
How often must QAL2 and AST be done?
An AST every year: the ordinance requires an annual check by parallel measurements with reference methods (section 40). A QAL2 is done when the measuring system is new, then at least every five years according to EN 14181 and after major changes to the plant or the measuring system. The permit or the monitoring programme can require more frequent calibration.
May the measurement uncertainty be deducted from the measured value?
For the ordinance's limit values a standard deduction is made: the continuous measured values are validated with the factors in section 51. Periodic measurements are not validated. When values are compared with the BAT-AELs, according to the Swedish EPA, no standard deduction is made, and an exceedance must be reported to the supervisory authority without validation.
Do the requirements apply even when we are not burning waste?
Yes, in a co-incineration plant the rules apply even when waste is temporarily not being incinerated, according to the Swedish EPA and case law from the Environmental Court of Appeal. Start-up and shut-down periods, on the other hand, are included in the averages only if waste is incinerated during them (section 51).
Who may do the measurements?
According to EN 14181, the reference measurements at QAL2 and AST must be made by a laboratory accredited for the task according to ISO/IEC 17025. Sampling, analysis and reference measurements must follow CEN standards (section 39). METLAB is accredited by Swedac for emission measurements and for QAL2 and AST according to EN 14181.
Are new measurement requirements on the way?
The EU amended the Industrial Emissions Directive in 2024, through Directive (EU) 2024/1785. Under it, emissions to air from waste incineration are to be checked outside normal operation too, and the emissions at start-up and shut-down estimated with measurement campaigns, for example every three years. The changes were to be transposed by 1 July 2026, but the ordinance's measurement provisions have not yet been changed (October 2026).