EU Integrated Nutrient Management Action Plan (INMAP) The European Commission has announced that it will prepare in 2021 an Integrated Nutrient Management Action Plan (INMAP). After wide consultation of our members and network of stakeholders, ESPP has prepared and submitted to the European Commission proposals for the objectives, content and implementation tools of such an Action Plan.
ESPP input to EU consultation on INMAP (open to 26 August 2022)
EU new Circular Economy Action Plan, COM(2020)98, 11_3_ 2020 For information: input (from seven Masters students), I. Stammes, T. Maassen, F. Miller Kerins, G. Votano, D. Palma Munguia, Z. Yuan, M. Gereadts, Amsterdam University, 30_6_2020
Taxonomy (sustainable finance criteria)
ESPP input to EU consultation on Taxonomy criteria 3_5_2023
New EU Fertilising Products Regulation (FPR)
ESPP comments on DG GROW proposals for Animal By-Products amendment of CMC10 (deadline 2_12_2022)
ESPP input to public consultation on Animal By-Products in EU Fertilising Products Regulation 24_10_22
ESPP input to survey on possible additional materials for inclusion in FPR CMCs 16_9_2022
Legal Opinion on ‘End of Waste’ and use of Cat 1 ABP (Animal ByProducts) incineration ash as fertiliser (Barry Love) 13_9_22
ESPP letter to DG SANTE concerning nutrient recycling from Cat1 ABP ashes 13_9_22 and European Commission reply 18_10_22
ESPP letter to European Commission on Animal By-Product ash in fertiliser (esp. Cat1 ABP ash) 25_4_22 and DG SANTE reply 31_5_22
Joint letter requesting inclusion of waste water in the priority streams for End-of-Waste status under the Circular Economy Action Plan, 3_4_2021 – further signatories welcome (contact )
DG ENVI studies on contaminants in composts, digestates, fertilisers
AMEC study carried out in 2019 for DG ENVI on possible bans or REACH “Restrictions” on composts and digestates (Ramboll – Peter Fisk – WOOD ref. 40039CL00313, 8_2_2019)
Joint letter criticising the study and requesting its withdrawal (11_2_2020)
Currently ongoing study into risks of contaminants in fertilisers
Nitrates Directive / recycled nutrient products from manure (SAFEMANURE) The EU Nitrates Directive specifies lower application limits for manure “even in a processed form” than for mineral fertilisers. Depending on application by Member States/Regions, this can discriminate against recycled nutrient products made from or partly from manure in Nitrates Vulnerable Zones. The European Commission has commissioned a study to JRC (“SAFEManure”) to assess the agronomic performance and environmental impacts of recycled nutrient products produced (partly or wholly) from manures, and input is invited to this (relevant data, publications …).
Composts and digestates: REACH and proposed "restrictions"
ESPP comments on the AMEC study on composts and digestates (11_2_2020)
European Commission (DG ENVI) study on possible "restrictions" on composts and digestates (AMEC 8_2_2019)
Exemption of digestate from REACH regulation: published 10_10_2019
Best available techniques (BAT) BREFs (Industrial Emissions Directive):
BAT for waste incineration – objective: take into account the recovery of phosphorus from ashes, including inciting separative incineration of high-P streams to generate ash with P-recovery potential (mono-incineration of sewage sludge, not mixing with industrial sludge or municipal solid wastes)
The finalised BAT BREF for the “Food, Drink and Milk” industries (FDM) published 12/2019 specifies that “Phosphorus recovery as struvite” is BAT for “waste water streams with … high total phosphorus content ..." and also specifies anaerobic digestion, appropriate use of residues in animal feed, appropriate use of wastewater in agriculture to valorise nutrients and/or water.
Best management practices (BEMPs): EMAS (EU Eco-Management and Audit Scheme Regulation) “agriculture” – see SCOPE Newsletter n° 116 (14_9_2015)
EU Critical Raw Materials (CRM)
ESPP input EU consultation on Critical Raw Materials policy, 25_11_22
ISO 275/TC (International Technical Committee) “Sludge recovery, recycling, treatment and disposal” including a specific working group on “Inorganics & nutrients recovery” see SCOPE newsletter 112 (12_4_2015)