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

2. 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

3. 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

4. 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

5. 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

6. 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

7. 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

8. 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.

9. 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.

10. 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

11. 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)

12. 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

13. 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

14. Thank you.
Contact:
JRC Recovered Fertilisers Team
Tel: / 470

15. 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