Towards the possible inclusion of recovered phosphate salts, ash-based materials and pyrolysis materials in the EU Fertiliser Regulation

criteria development: evaluation of impacts: JRC STRUBIAS sub-group two tasks to be run in parellel criteria development: recovered phosphate salts ash-based materials pyrolysis materials STRUBIAS materials should meet quality requirements so that they can be used directly without any further processing other than normal industrial practice. evaluation of impacts: substitution of mined P-fertilisers by fertilisers derived from STRUBIAS agronomic efficiency impacts of production and use of STRUBIAS materials upon environment, human health and the internal market possible inclusion in Revised EU Fertiliser Regulation

Why do STRUBIAS CMCs require a specific approach CMC criteria should focus on source and process-specific risks; eligible input materials for STRUBIAS include waste materials Producers have to pay for primary raw materials, but might receive financial compensation when using waste as input material It should be avoided that operators might turn waste into CE products, and seek disposal options for wastes in Europe that do not provide added value and are not in line with the protection of the environment and human health reasonably be expected that producers will reduce materials not of interest, as these are associated to a production/extraction cost "tempting" for untrustworthy producers not to remove a share of the invaluable elements from the end-material

STRUBIAS CMCs do not receive CE status Implies that the principles of the Waste Framework Directive (2008/98/EC) hold for STRUBIAS materials derived from waste

Approach and criteria mandated by the STRUBIAS sub-group Nutrient recovery rules must guarantee that STRUBIAS materials can become high quality fertilising products with a sufficient agronomic efficiency and comply with environmental and human health protection standards. Requirements shall be set in a sufficiently flexible manner to encourage industry to undertake nutrient recycling actions that will contribute to achieving the policy goals set in the framework of the circular economy. Nutrient recovery rules shall, in principle, apply a neutral stance towards existing and future technological systems operating on the market and input materials available (technologically neutral nutrient recovery rules). Nutrient recovery rules have to be clear, concise and enforceable, in order to clearly delimit the scope of the CMC, lead to reasonable compliance costs, and facilitate straightforward conformity assessments. A lack of consideration of these aspects may also reduce farmers' confidence and create low market acceptance for innovative fertilisers, ultimately undermining the objective of nutrient recycling. Such an approach stimulates competition and technological innovation, and takes into consideration that process conditions and technologies for nutrient recovery on the emergent STRUBIAS market might require further adjustments

very strict very lenient + fully technology neutral - lack of technoscientific data and consensus to derive limits - high compliance costs & complex testing schemes + flexible + fully technology neutral - possibly limiting emerging techniques and input materials + simple and straightforward, clear benchmark for industry + reasonable compliance cost Safety aspects are on top of the agenda

Nutrient recovery rules minimum nutrient content, maximal heavy metal content, etc. direct product quality require-ments Nutrient recovery rules Input material require-ments product quality human health environ-mental aspects Production process require-ments Indirect require-ments labelling

Recovered phosphate salt Ca2+ pH regulator Mg2+ Recovered phosphate salts (STRU in STRUBIAS) A phosphate fertiliser; recovered phosphate salts provide an avenue to recover P from waste streams Most recovered phosphates are low in organic C and have low levels of metals/metalloids No thermal disinfection and contaminant removal process Concerns on the heterogeneous group of organic pollutants, including emerging ones: PAH, biological pathogens, pesticides (agriculture), pharmaceutics and personal care products, disinfection by-products, etc.

Trade-offs between approaches for recovered phosphate salts do not limit organic C, but test for all individual potentially hazardous compounds limiting organic C and setting indirect limits on purity - possibly limiting some materials + direct use as a fertiliser and in a blend + low compliance costs + simple and straightforward, clear benchmark for industry - lack of technoscientific data to derive safe limits - high compliance costs & complex testing schemes - reduced cross-border market and consumer acceptance + fully technology neutral Trade-offs between approaches for recovered phosphate salts Where is the dissipated phosphorus? -> Positive input material list: municipal waste waters and sludges, specific industrial waste waters, category 2 (manures) and category 3 animal by-products, bio-wastes.

Ash-based materials (AS in STRUBIAS) ash-based materials, include thermal oxidation materials and their derivates no criteria apply to ashes that are used as intermediate in a post-incineration manufacturing process Incineration (IED) of non-hazardous materials -> effective way to remove organic pollutants De novo formation of persistent organic pollutants: PAH, PCB, PCDD/F Possible inorganic contaminants (metals/metalloids) can become concentrated in the ashes

Approach for ash-based materials (AS in STRUBIAS) PAH, PCDD/Fs and PCBs can be formed during incineration Approach enables a negative input list excluding only hazardous waste, MSW, cat 1 ABP + testing scheme focused on metals/metalloids and PAH/PCB/PCDD/F Organic pollutants not an issue for the targeted non-hazardous waste streams Metals/metalloids are a major concern as indicated by the "soil screening values" derived by EU Member States (action required if exceeded) Measuring metals/metalloids is straightforward (ICP, AAS)

Pyrolysis materials (BI in STRUBIAS) Input materials were indicated to be "uncontaminated" biomass (STRUBIAS sub-group and voluntary industry standards) Different production process techniques along the pyrolysis spectrum, C-and nutrient-rich Focus on C-stability due to its relation to material properties beneficial for agriculture and temperature-time profile for contaminant removal De novo formation of persistent organic pollutants: PAH, PCB, PCDD/F, but negligible risk for existing organic contaminants derived from selected input materials Possible inorganic contaminants (metals/metalloids) can become concentrated in the pyrolysis material

Approach for pyrolysis materials (BI in STRUBIAS) PAH, PCDD/Fs and PCBs can be formed during pyrolysis, other organic pollutants not an issue for the targeted non-hazardous waste streams Approach based on positive input materials as proposed by industry + testing scheme focused on metals/metalloids and PAH/PCB/PCDD/F No interest to include contaminated input materials due to a lack of metal/metalloid removal during pyrolysis Measuring metals/metalloids is straightforward (ICP, AAS) Metals/metalloids are a major concern as indicated by the "soil screening values" derived by Member States (action required if exceeded) labelling

Thank you. Contact: JRC Recovered Fertilisers Team Tel: + 34 9544 88 349 / 470 E-mail: JRC-IPTS-FERTILISERS@ec.europa.eu

Provisional time line JRC STRUBIAS work Project start Final Report Nov, 2015 Provisional time line Background Document Kick-off Meeting 6-7 July, 2016 Feedback sub-group Sept, 2016 Interim report with proposal for criteria * May, 2017 Interim report on impact assessment * February 2018 Final Meeting May, 2018 …. Final Report * followed by written consultation of the sub-group Project progress December 2018