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REA writes to Commission about Animal By-Products rules

Timescale and big picture relevant to composts and digestates

By 23rd March 2016, the European Commission aims to finalise its proposals for revision of the EU Fertilisers Regulation.  The remaining legislative process will include the proposal's consideration under a co-decision procedure involving the European Council (of EU Member States) and the European Parliament. 

The proposal is likely to include 'organic fertiliser' (in liquid and solid forms) and 'organic soil improver' (in solid form) products made from specified types of source separated biodegradable wastes, manures and energy crops.  EU-level 'end of waste' criteria are expected to be included for these product categories (because the products tend to be made from controlled wastes) and it seems likely that all relevant revised and amended legislation will, in effect, allow UK compost and digestate product producers to decide which set of end of waste rules they wish to comply with, i.e. the revised EU Fertilisers Regulation or the relevant PAS and Quality Protocol (or Additional Scheme Rules for Scotland for digestate product placed on the market in Scotland).   

REA concerns about ABP rules when making an EU Fertiliser product

Having read a communication between relevant Commission directorates and their Fertilisers Working Group and minutes and EU trade association feedback from an FWG meeting in December 2014, the REA became concerned that the treatment process for producing composts and digestates made from Animal By-Products would be restricted to the Standard Transformation Parameters laid down in the EU ABP Implementing Regulation (No. 142/2011).  These parameters are; minimum 70 oC for a minimum of 1 hour and particle size not exceeding 12 mm.  

The REA then reviewed publically available information about premises in the UK approved for composting and digesting ABPs and invited members to provide feedback about transformation parameters they were using and potential impacts of the Commission's intentions.

REA's letter to the Commission

The REA has recently sent a letter to the Commission that calls for additional acceptance of the ‘Alternative Transformation Parameters’ that EU ABP Implementing Regulation allows.  Under this option, the producer’s choice of transformation parameters is evaluated by the competent authority.  Validation evidence must demonstrate adequate reduction of pathogens and show that concentrations of Salmonella and E. coli (or Enterococcaceae if E. coli are not tested) are sufficiently low in the ABP-treated material.  These ‘low concentration’ criteria in the EU ABP Implementing Regulation are also applicable to material which has been treated according to the Standard Transformation Parameters.  This regulation allows ABP derived composts and digestates produced according to the Standard or the Alternative Transformation Parameters to be placed on the EU market.

The ABP issues are less of a concern than they were a year ago because it seems that producers in any EU Member State which has its own end of waste rules will be allowed to choose between complying with those or the revised EU Fertilisers Regulation, if they want to place their product on the market within the EU.  The REA wrote to the Commission because we believe that some UK producers may prefer to comply with the EU Fertilisers Regulation in future and would not want to be prevented from achieving this if they are treating ABPs using treatment parameters that are not the standard ones.     

Please contact Emily Nichols (emily@r-e-a.net, 07771 556231) if you want to discuss the issues.

Article published: 11/03/2016. 
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