UK calls for 'adequate time' to adopt End of Waste
22 February 2012
Defra has said it will be arguing for a ‘significant transition period’ to enable operators of AD and composting plants to adapt to EU end of waste criteria for biowaste which are currently being developed.
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- The EU end of waste criteria for biowaste will govern both digestate (above) and compost
The Department has published an information note setting out its best estimate of how the criteria may look. If introduced, the criteria will determine when a product like compost or digestate produced from AD is of a high enough quality to no longer be considered waste.
As the UK is unique in having developed its own end of waste criteria through the WRAP/Environment Agency Quality Protocols project, Defra says it has valuable experience to contribute to the process.
However, the department says it also means this country needs 'adequate time' for an orderly transition between the UK and EU criteria – particularly if the EU criteria are significantly different to ours.
“The UK will be arguing for a significant transition period to enable those operators who are certified under the two existing UK standards (quality protocols incorporating PAS 100 and PAS 110) time to adapt”, the note says.
“A transition period will also be needed for the UK’s certification scheme owners and contracted certification bodies to realign their audits to checking operator compliance with EU EoW criteria. If those schemes and certifiers are also required to be accredited, for example by the UK Accreditation Service, for their certification services aligned to EU EoW criteria, a longer transition time will be needed”.
Proposals
AfOR Conference
To hear more about the EU's proposals for End of Waste for biowaste and its implications for the UK organics recycling sector, come to the Association for Organics Recycling's Annual Conference on March 15 2012, where speakers from both the Commission and Defra will be speaking on the subject. To book your place please call Iona Smith on 020 7 633 4526 or click here.
The proposals for end of waste criteria for biowaste and other materials are being developed by the European Commission’s Joint Research Centre (JRC). Defra explained that the Commission’s intention is that only biodegradable wastes from source-segregated collections will qualify – meaning that sewage sludge or residual wastes that are then subject to treatment such as MBT will be excluded.
The JRC held two meetings with technical experts from member states in 2011. At the second, in October 2011, it presented draft proposals for end of waste criteria.
Commenting on this, Defra said that industry should not assume that the JRC proposals be implemented in their current form and said that past experience suggested it was “very unlikely”, and that it is even possible no criteria will be agreed. However, if they are adopted it stressed that they must reflect UK concerns.
The information note says: “Should such criteria be adopted, it is important they reflect UK concerns, provide high quality materials accepted by the market and are not overly burdensome on industry.”
The JRC proposals cover both digestate and compost. Unlike the UK Quality Protocols, the Commission’s proposals do not specify the uses to which end of waste compost and digestate must be applied.
Compost
With regards to compost, the physical contaminant limit, currently set at 0.25% by weight under the PAS 100 standard for quality compost, would be raised to 0.5% under the JRC proposals. This is significant because many councils have been striving to increase the quality of their compost to ensure it meets the PAS 100 standard, through measures such as stopping the collection of cardboard in with green waste, which some have suggested may not be required under the JRC proposals.
Defra believes that proposals for end of waste standards should allow sufficient flexibility and encompass food waste-fed plants as well as the purpose-grown crop based systems that are currently common in Germany
Another key difference is that there is no plant response test in the proposed EU requirements – something which the UK wants to see added. Defra’s note explains: “The UK believes that a plant response test is important for determining some environmental effects and is also vital for building confidence in the market for such products”.
Digestate
The information notes says there are ‘more issues’ with the Commission’s proposals for digestate, as highlighted by the Renewable Energy Association late last month (see letsrecycle.com story).
Concerns included a proposal for a new minimum organic matter content of 15% and a limit on the amount of organic fatty acids (1500mg per litre) in fully processed digestate – meaning that digestate produced from food waste may find it hard to qualify for end of waste.
Related Links
Defra explains: “This is one area where the commissions proposals seem to be based on digestate from farm-based AD plants rather that food waste ones. Defra believes that proposals for end of waste standards should allow sufficient flexibility and encompass food waste-fed plants as well as the purpose-grown crop based systems that are currently common in Germany. This approach will ensure that the proposals are practicable in the UK”.
Timetable
In January 2012, Defra and WRAP – with the support of the Association for Organics Recycling and UK trade associations – provided further input from the UK to the JRC. The timetable for introduction is still unclear, but Defra’s best estimates are in the table below:
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