SEPA publish consultation on Food Waste Management and Review of SEPA’s regulatory position on the use of compost and anaerobic digestate without waste management regulatory controls.

This consultation is now closed.

SEPA is seeking responses to a consultation on proposed new guidance which sets out obligations along the chain of food waste management in order to achieve high quality recycling. This chain of management includes the waste producer, collection service provider, food waste treatment facility and final user of the food waste derived compost and / or anaerobic digestate.

Only food waste managed in accordance with the Guidance will fulfil the duty to segregate food waste, demonstrate compliance with duty of care as regards quality requirements and fulfil proposed waste acceptance criteria at food waste treatment facilities regulated by SEPA in Scotland. They intend to include standard permit conditions in all food waste treatment facility permits under a SEPA initiated variation to support the guidance.

They are also seeking feedback on SEPA’s revised regulatory positions for the Regulation of Outputs from Composting and Anaerobic Digestion Processes.  These revisions set out limits (by weight) of physical contaminants (including plastic) to 50% of those specified in PAS 100 and 8% of those specified in PAS110 standards (for compost and anaerobic digestate respectively).

This will align SEPA physical contamination limits with Quality Meat Scotland (QMS) standards.

SEPA appreciate that achieving these limits may be challenging for some operators and are proposing a phased implementation presented below.

Table: Proposed phased implementation of physical contaminant (including plastic) limits




1st April 2017

66% of PAS 100 levels

50% of PAS110

1st April 2018

50% of PAS 100 levels

25% of PAS110

1st April 2019


8% of PAS110

Compost or digestate which exceeds these revised limits for physical contaminants will be regulated as a waste and SEPA’s presumption will be that such material is not be suitable for application to agricultural land under an exemption from waste management licensing.

Consultation in full can be found HERE

The consultation runs until 29th June and ORG will be responding on behalf of our members, please forward comments to Jenny Grant ( by 22nd June for inclusion in our response.

ORG submitted a response to this consultation, please find it here. Thanks to all members who provided comments.

Published: 23/05/2016. Updated: 04/07/16

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