Draft Document on Sludge and Biowaste - Brussels, 18 Dezember 2003

About BGK:

The Federal Compost Quality Assurance Organisation (BGK) is the organisation acknowledged for the implementation of the Quality Assurance for Compost and Digestion products in Germany.
BGK is independent and neutral. It obliges herself only to Quality Assurance and has no other purposes or interests. Members of BGK are more than 500 municipal and private production plants of about 4,000,000 t of compost or digestate per year from source segregated biowaste.

The task of BGK is to assure an effective, continuous and at every time traceable monitoring of the adherence to the quality regulations stipulated by the German Standardisation Organisation RAL and the Biowaste Ordinance. BGK carries out more than 3,000 external compost examinations every year and issues the coherent quality reports and certificates.

The Federal Compost Quality Assurance Organisation of Germany (BGK) appreciates the above mentioned draft document and the objectives contained.

The objectives, however, need a clear guidance. The reuse of biowaste follows the targets of waste management which takes care of resources, soil and environment. These targets have to be accompanied by a legally binding directive for biological waste treatment.

This Directive must - extending the soil protection aspects already discussed at the ad hoc meeting in Brussels - contain and regulate some additional waste aspects as well. So as a next step it is recommended to collect the already existing experiences, ideas and information in the EU in a separate consultation process and thereafter launch a Biowaste Directive which includes both approaches, the waste and the soil protection one. The Working Paper 2nd Draft from 2001 might be a good platform for the discussion, especially because of the short time frame until September.

Source separation of the organic material is the key-element which has to be followed by decision makers and the industry.

The separate collection of biowaste is one of the most successful examples of modern closed loop waste management in Germany. Caused by the relatively high water content of biowastes the material recovery via composting or anaerobic digestion is prioritised compared to incineration.
In Germany around 800 biological waste treatment plants process around 10 million tons of biowaste and produce 5 million tons of compost - all approved as fertilisers. This means that biological waste treatment ranks second in the recycling quota of municipal solid waste after paper and cardboard in Germany.

In Germany, the statutory source segregation and the establishment of high quality standards in combination with the establishment of quality assurance systems led to a sustainable market for compost as fertilisers (8 % substitution potential of the agricultural basic fertilisation), part of growing media (up to 40 % substitution of peat) and valuable soil improvers. High quality compost demands extend the available offers on the market now for years.

We kindly ask to consider our remarks referring to the topics in Annex II of the Draft Document. Some of the waste related aspects are mentioned in the specific contexts.

1. Home Composting

It is true, that waste will be avoided through home composting. Measures to support home composting are therefore correct and important.

In this context the individual actual waste amount will be reduced only, if in the long run additional households can be convinced to do home composting besides such households which already do it now (hobby gardeners).

As far as households have to pay lower disposal fees (tax breaks) on account of home composting the authorities in charge must continuously carry out spot tests about operation of home composting in reality. Otherwise a violation of such a financial incentive cannot be excluded. Reduced waste fees and a random controlling always belong together.

2. Community Composting

Requirements for the approval and monitoring of treatment plants are –as far as they are plants and not home composting- independent from the fact whether the plants are run by communities or privately. Therefore it cannot be assumed that a simplification of the approval and monitoring procedure can be achieved in the case of plants run by communities.

3. Separate Collection of biodegradable Waste

Considering municipal solid wastes (MSW) biowaste is usually the largest fraction. The objectives named in the Draft Document can only be reached if it includes requirements/targets that large quantities will be separately collected, treated and used.

Relevant quantities can only be realised by a separate collection from the households.

Quality composts can only be guaranteed through a treatment of pure and clean biowastes. Therefore separate collection of pure biowastes is a precondition for the production of high quality compost products and their sustainable chances on the market.

4. „Driver effect“

Sustainable waste management needs guidance of legally binding ordinances. Referring to biowastes the fulfilment of the objectives of the Landfill Directive are not the only criteria. Another important point is the reuse of the organic fraction in reality respectively the recovery the valuable material contained in biowastes (closed loop waste management).

The objectives of the Landfill Directive can also be achieved through thermal pre-treatment of the waste. However, this does not correspond to the objectives of a sustainable waste management. The incineration of biowastes does not generally implement an energy generation on account of the high water contents. Secondary raw materials (including plant nutrients, alkaline effective materials, humus) will get lost through thermal treatment of biowastes. As a result, an orientation by the objectives of the Landfill Directive alone will not be sufficient.

From the aforementioned reasons the material recovery of biowastes must be treated with priority for both the Landfill Directive and the actual reuse/recycling of the valuable materials. In order to enforce this priority a statutory demand for separate collection and for material recovery of biowastes is indispensable. Corresponding standards should be provided in a Directive on biological waste management with response to the production of high quality compost products for different application ranges.

5. Provisions for process requirements

The requirements referred to in this paragraph (treatment time, temperature, limit values, hygiene) should be given in a Directive on biological waste management too.

6. Recycling proceedings „R3“

The production of high quality composts should be considered as recycling measure in the sense of the procedure R3 of Annex IIB of the Directive 75/442/EEC.

The proof of a "high quality compost" must be delivered by the producer through an independent product certification (external quality control).

Requirements for "high quality composts" and a quality control/assurance should be defined in the frame of a Directive on biological waste management.

7. Digestion residues

As far as high quality digestion residues fulfil the same standards like composts (see no. 5 and 6) their production, too, should be subject to a recycling measure in the sense of the procedure R3 of the Annex IIB of the Directive 75/442/EEC.

The proof of a "high quality digestion residue" must be delivered by the producer through an independent product certification (external quality control).

8. Energy from the combustion of biogas
No comment.

9. Stabilised biowaste

The term "compost" should be reserved only for products from the separate collection of organic wastes. In order to avoid irritations at the marketing of composts the results from mixed waste composting should get another title name (e.g. “stabilised residual waste”). The use of composts from mixed wastes should only be permitted as a soil conditioner in top soils on landfill.

As far as composts from separate collection do not comply with the requirements of "high quality compost"; a labelling with a binding declaration of a corresponding quality stage is reasonable.

Corresponding regulations should be provided in a Directive on biological waste management.

10. MBT treated biowastes to be landfilled

As the material recovery of biowastes must be treated preferentially (see no. 4, utilisation of the valuable material contained in biowastes) only a landfilling of residual wastes treated by mechanical biological treatment MBT should be admitted (i.e. of the residual waste which remains in the bins after the separate collection of biowastes). These wastes must fulfil the suitable requirements for stability.

If the landfilling of entire municipal mixed solid waste treated MBT (i.e. without preliminary source separation of biowaste) would be allowed the incentives to collect separately and to compost biowastes would be damaged considerably. This is not compatible with the objective of a closed loop management that takes care of the resources.

11. Permit
Plant permits (emissions etc) in an EU Directive should only give a frame for the obligatory component in national permits for biological waste treatment plants. The Member States should be responsible for the detailed requirements in order to consider local circumstances.

12. European-wide quality requirements

The establishment of common EU quality standards make sense. The standards have to assure the usefulness and the harmlessness of products. The usefulness depends on the content of valuable ingredients (main nutrients, micronutrients, sulphur, alkaline material, humus) and the recommended application rates. The harmlessness depends on the content of undesired ingredients (pollutants, impurities, germs). Harmless contents of undesired ingredients should be guaranteed by suitable limit values.

The determination of suitable limit values should not only include a guarantee for an environmentally harmless utilisation in the long run. It should also include that the level of the limit values do not overstrain the system of separate collection, treatment and application of biowastes.

The German Environmental Agency and the German Compost Quality Assurance Organisation BGK in Germany issued a detailed study in 2003 with reference to this topic. The study points out to which extent limit values for heavy metals in compost can be lowered at the maximum without questioning the system of the separate collection of biowastes. Limit values below these "system"; cannot be guaranteed safely by the compost producers. As a result of this study, the limit values of the German Biowaste Ordinance were confirmed.

In fact limit values below the "system limits" are counterproductive, because they cannot be managed safely by the plants, therefore irritate the consumer and destabilise the markets.

The establishment of common EU quality standards should be carried out in the frame of a Directive on biological waste management.

13. Compost Quality

A classification of different compost qualities is only reasonable in the sense of no. 9 (“high quality compost” or not). It is not reasonable for "high quality composts" (see no. 6).

"High quality composts" should only be differentiated according to their range of application. These, however, are not quality differences (better or inferior composts) but just questions of special properties (e.g. grain size, maturity stage..), declaration and recommendations for the application.

Differing concentrations of plant nutrients are not suitable for a definition of quality differences between composts. In fact is it correct that composts may have very different nutrient contents depending on the raw material. Relevant for fertilisation is, however, always the application rate.

Declaration of the compost properties and application recommendations are of a decisive importance for the safe and successful use of composts. If used in wrong application ranges or with wrong application rates even high quality composts can cause damages. The quality assurance of "high quality composts", recommended in no. 6, should therefore include independent quality controls of the product and consider the aspects of declaration, information about suitable application areas and of application rates according to good agricultural or fertilising practice.

Such an "integrated quality assurance" is suitable for creating highest benefit of the compost use in the various application ranges, and suitable for consumers and the markets to build up confidence for the product and to maintain it in the long run. This being important as consumer and markets are extra sensible towards products based on wastes.

Therefore it is recommended to create incentives, in the frame of a Directive on biological waste management, which are suitable to support self-obligatory measures of the producers considering the guarantee of "an integrated quality assurance" for "high quality composts". Such an incentive might be given when the definition of a "high quality compost" as a product would be combined with the label for an" integrated quality assurance". Following from such a measure compost would become a product (and will no longer be waste) if it is subject to such an "integrated quality assurance" and fulfils the corresponding standards.

Former considerations to bind the product status of compost only to the fulfilment of certain limit values for pollutants are either not appropriate to characterise composts as a high quality product nor appropriate to support their application according to good fertilising practice.

14. Labelling

As already explained in no. 13, ware declaration of the compost properties and application recommendations as part of a labelling procedure are of a special importance.

The information required for ware declaration and for application recommendation should be determined uniformly in the frame of a Directive for biological waste management.

15. Standardisation

The endeavours for a standardisation of the methods of sample taking and analyses of compost, sewage sludge and soils on a European level are welcomed.

Dependent on the differences of the corresponding material groups and on account of the differences between the relevant quality standards of the individual material groups is it possible that single methods are not equally suitable for each material group or that several methods are suitable for the one material group and may lead to comparable results.

These aspects should be considered in the project HORIZONTAL insofar as parallel to the statement of suitable methods for all material groups information for alternative methods should be given, if necessary limited to single material groups or quality parameter.

16. Encouraging the use of compost
No comment

17. Labelling for biodegradable packaging

Biologically degradable polymers (BAW) cannot be processed in all composting plants. The processing time for the degradation of BAW is often too short in compost plants where fresh compost is produced. Smaller compost plants often do not possess sufficient technical implements required for the preparation of BAW.

This is the reason why a labelling of a BAW package as "biologically degradable" means not automatically that the user can put the packaging material into the biobin. Hence it must be assured that he does this only in the cases where the regional waste management concept for the catchment area of the plant allows the collection of BAW together with biowastes in the biobin.

As far as an label is accepted or created for BAW-packaging material as being "biologically degradable" it must simultaneously be assured that the BAW-packages will only be collected together with the biowastes if this is explicitly allowed according to the regional waste management concept (e.g. if BAW-packages are listed in the positive list of suitable raw materials for the biobin)

Quelle: H&K 04-02-10

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