AADO secures clarification of Partial Harmonisation proposed by the European Commission for biofertiliser
The Association of Anaerobic Digestion Operators (AADO) has secured confirmation of the Partial Harmonisation methodology, proposed by the European Commission for the management of digestate.
The confirmation comes prior to the announcement of the amendment to the EU Fertilisers Regulation due under the Circular Economy review later this year.
Since autumn 2014, concerns have been raised by AADO and the wider AD industry over the proposed inclusion of organic fertilisers, notably biofertiliser (as product status digestate is known), in the EU Fertilisers Regulation for the first time.
The industry argues that proposals to include minimum nutrient content requirements for organic fertilisers and organic soil improvers are unnecessary, and UK digestates would not be able to attain these minimum requirements as they were far in excess of UK AD operational limits and biofertiliser content.
Additionally, the inclusion of biofertiliser within the Fertilisers Regulation would render obsolete the UK’s End of Waste scheme for digestate from AD, which has been successfully operating for several years.
AADO representatives met in October with a representative from the Directorate-General for the Internal Market, Industry, Entrepreneurship, and SMEs to request further detail surrounding the proposed methodology.
Subsequently, confirmation of the following Partial Harmonisation methodology to be implemented following the introduction of the new EU Fertilisers Regulation has been issued:
It was confirmed that the UK could continue to use the PAS110 standard, associated Quality Protocol, and BCS (or any equivalent scheme) as method for demonstrating End of Waste, providing biofertiliser is to be marketed solely within the UK.
If biofertiliser is to be marketed across EU borders, there are two options:
A. To attain the CE mark as a European Organic Fertiliser or European Organic Soil Improver, by demonstrating the requirements set out in the EU Fertilisers Regulation; or
B. To reach a position of Mutual Recognition with another Member State (MS) to agree End of Waste principles based on different parameters to those set out in the EU Fertilisers Regulation.
This confirmation secures the continued operation of the PAS110 scheme and the ability of operators meeting that scheme’s requirements to manage their digestate as product, not waste.
The commensurate saving to operators by avoiding a return to waste status and the use of deployments, and to the Environment Agency in managing such deployments is considerable.
Kristy Blakeborough-Wesson, technical adviser to AADO, comments: ‘The partial harmonisation proposal from the EC has come as a result of sustained pressure from the UK, after initial EU Fertilisers Regulation proposals presented in autumn 2014 were recognised as completely unworkable by AADO members.
‘AADO has worked with REA and ADBA and has presented a coherent and scientifically valid alternative to the “one size fits all” EU proposal, and is delighted to have secured the biofertiliser industry in the UK for the foreseeable future.’