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End-of-waste criteria - our thoughts on updated proposals

16 Jan 2012

Second working document on the development of EU-wide "end-of-waste" criteria for compost and digestate

compost hand full 275184(1)The European Commission has updated their working document on the development of end-of-waste (EoW) criteria for biodegradable waste subject to biological treatment (compost and digestate).  End of waste criteria define the point at which a waste can cease to be regarded as a waste, and will no longer be subject to waste regulatory controls (i.e. Environmental Permitting Regulations, Duty of Care Regulations).  The working document can be viewed by downloading "EoW 2nd Document" available under "Related Documents".

The proposal for EU-wide end-of-waste criteria originates from revisions to the Waste Framework Directive (WFD) which introduced a new procedure for defining EoW criteria for materials that have undergone a recovery operation.  In England and Wales, the Quality Protocols for compost and anaerobic digestate defining this point are already in place, with PAS100 and PAS110 providing the technical specification for compost and digestate.  It is understood that EU-wide criteria would replace nationally-derived criteria and it is on this basis that our response was formed.

In our response we highlighted the following points:

  • It is not possible or appropriate to make decisions based on very limited datasets such as the one presented in the working document.
  • The limit values are more precautionary that those that could be developed at the Member State-level since they would be based on local conditions and more easily risk assessed.
  • It is clear that the proposals in their current form would add extra burden on compost and digestate producers in the UK who are already meeting, or are working towards meeting existing UK end-of-waste criteria.
  • EU-level criteria will be more burdensome for operators and more difficult to update than Member State-level criteria would be.

The NFU's full response to the document is now available to download by clicking under "Related Documents". 

 

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