High quality compost under threat

Everyone agrees that end-of-waste criteria will boost separate collection and treatment of organic residual waste streams in Europe as well as consolidating market confidence in quality compost. But including municipal residual waste and sewage sludge as input materials will put the end-of-waste status for compost on a disaster course, say a number of critical EU countries.

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Mounting criticism of draft end-of-waste criteria

High quality compost under threat

Everyone agrees that end-of-waste criteria will boost separate collection and treatment of organic residual waste streams in Europe as well as consolidating market confidence in quality compost. But including municipal residual waste and sewage sludge as input materials will put the end-of-waste status for compost on a disaster course, say a number of critical EU countries.

By Pieter van den Brand ©copyright

For three years the European Commission has been working on the end-of-waste criteria for compost. These criteria should clarify, for numerous residual streams, when a substance is still a waste material or – after treatment – has become a raw material. The underlying idea is that carefully compiled, harmonised European end-of-waste criteria will raise the marketability and use of secondary materials; the product status will encourage high quality recycling and bolster confidence among consumers and customers. For biowaste, it not only paves the way to high quality compost, but also opens the door to green electricity production.

Each year an estimated 76 to 100 million tonnes of vegetable garden and fruit (VGF) waste are produced in Europe, along with 37 million tonnes of organic waste from industry. In many member states enormous quantities of this biowaste end up in landfills, but other EU countries are following the Dutch example of treating clean, separately collected VGF waste. For example, in January 2015 Germany will introduce compulsory separate collection of VGF waste. This waste stream produces a high quality compost which enjoys widespread market recognition.

‘It is only logical that high quality compost is given product status’, says Arjen Brinkmann, director of the Association of Dutch Greenwaste Composting Plants (BVOR). For years the BVOR and the Dutch Waste Management Association (DWMA) have been scrutinising the development of the end-of-waste criteria for compost and they lobby jointly on the topic. They had their first meetings with Dutch government departments and various European organisations, such as the European Commission’s Joint Research Centre (JRC), as long ago as 2006.

At first, all went well. The European exercise was based on the principle of producing high quality compost from separately collected VGF waste, backed by process and quality control systems. The first two JRC reports were therefore supported by the Dutch biowaste industry. But the tide changed in the third report. Published in August this year, it caused a considerable stir in the Netherlands. The response by the DWMA filled no less than 22 pages, with a covering letter signed jointly with the BVOR. The sticking point is mechanical biological treatment (MBT). ‘MBT technology was included in the document at the request of the French environment ministry’, explains John van Haeff, bioconversion manager at Attero. ‘France has a long history of separately collecting green garden waste, but not household food waste. About 85 per cent of French household kitchen waste goes directly to landfill or incineration. Of the remainder, 5 per cent is separately collected and 10 per cent is treated in MBT facilities, where the organic fraction, about a third of the total, is separated from the mixed grey waste to produce a stabilised composted material. If it meets the required standards, under French regulations it becomes a product and is no longer waste. As a consequence, this final organic material may be used in agriculture. This is not permitted in any other European country.’


The inclusion of MBT technology in the end-of-waste criteria is a thorn in Van Haeff’s side. It poses a threat to the quality and image of compost, he asserts. ‘MBT stabilate is not comparable with the high quality compost produced by Dutch composters’, he says. ‘It is not only full of physical contaminants, although these could be removed by some sort of ingenious separation technique, but heavy metals cannot be extracted during the MBT process at all. Even researchers at Wageningen University have failed to find a way.’ According to the third JRC report, sample analyses confirm that MBT stabilate presents ‘too high a risk’ to be considered as end of waste. Nevertheless, the MTB compost samples from France destined for agricultural use have been given the benefit of the doubt, because in the same analyses ‘some parameters come close to the proposed standards’. This cleared the way for the recommendation to add ‘mixed municipal solid waste’ to the Positive List of input materials. To cover the risks, the JRC report proposes additional measures for monitoring the quality of the final product.

The Dutch composting companies have major reservations about this line of reasoning. ‘In effect, what is being said is that you cannot always be sure that the final compost is safe. To cover that risk, the back door been put under close surveillance. It’s nonsense. If you use household waste as an input material, you cannot exclude any type of risk at all, because this waste contains all conceivable forms of contamination. In effect, every stage in quality control can only give a false sense of security because you would have to measure countless numbers of parameters’, says Brinkman, adding: ‘The sampling costs alone would be unacceptably high.’ A crucial step in the treatment of VGF is the visual inspection at the gate. ‘And that is also useless for mixed waste’, says Van Haeff, who argues for a restrictive list of input streams. ‘Broadening the scope by adding mixed contaminated streams, such as grey residual waste, is undesirable. Source separation gives the best input material, producing an end product of the highest quality.’

Stefanie Siebert, director of the European Compost Network, stresses the risk of only measuring the quality of the final product. ‘It throws the door wide open to mixing with contaminated streams. The number of samples analysed is in practice always small, and it will be very difficult indeed to obtain sufficient proof of illegal practices. The origin of household waste simply cannot be traced.’ Siebert also condemns the presence of sewage sludge on the Positive List. She believes there is a high chance that heavily contaminated sludge will be submitted to composting facilities to sidestep more expensive treatment options. The contamination of sewage sludge with heavy metals or organic compounds cannot be detected by visual inspection alone, says Siebert.

Siebert also fears the economic consequences. ‘Producing quality compost is the only way to maintain the confidence of the market. This proposal will seriously damage compost sales.’ BVOR director Brinkman shares this concern: ‘The biggest danger is from confusion about the product compost in the minds of buyers. It took us a long time to build up the good image compost now has in the Dutch market. Its reputation is excellent, but vulnerable. If these plans go ahead, we will be right back where we were before.’


Yves Coppin, an innovation specialist at the French company Veolia Environnement, is in favour of MBT technology. He says the problem of heavy metals has been solved by improvements to the MTB process. He represents those who back the inclusion of household waste as an input material. ‘The organic fraction from the old MBT facilities built in the 1980s is of poor quality. Since then, substantial improvements to initial separation steps in the process have considerably reduced contamination percentages. The heavy metals are not found in the organic fraction, but remain in the residual fraction. If you efficiently separate out impurities, the final quality is acceptable. I reject the criticisms of so-called experts who maintain the opposite. The majority of experts in the Technical Working Group have never visited an “MBT compost” plant, but only have the MBT stabilate in mind. That’s one of the reasons they don’t understand the current document and reject MBT compost. In principle, separate collection does produce the best compost, but not always. Sometimes MBT compost is better. The tests show this. That’s why the final inspection is so important.’ France has 31 MBT plants from different suppliers. Fifteen of them are new designs, says Coppin. ‘The compost they produce has to meet high standards. The organic streams from the older plants are landfilled.’ But Attero’s John van Haeff remains sceptical about the French MBT plants, including the newest. ‘Technology can accomplish a lot, but you are still left with heavy metals in the compost.’


Coppin calls all the fuss about sample analyses hypocritical. ‘For the second technical report, just five samples were analysed. No-one complained then. Now there are more than a hundred and suddenly there is all this criticism. It has nothing to do with substance, and all to do with purely political motives. For us it would be a nightmare if MBT compost lost its product status in France, and not only for the loss of image; as a waste, it would also be subject to a plethora of rules. For example, before it could be used on agricultural land, the population of all the municipalities concerned would have to give their consent at a public hearing. And no prizes for guessing what the answer would be: No.’ Van Haeff: ‘France does not have to worry about the loss of its product status. This can be retained at national level.’

If all goes to schedule, the technical report will go to the European Commission at the end of November. Until then, the JRC spokesperson Elena Gonzales says they have no comment to make on the criticism expressed in several countries. ‘The document has not been finalised. We are reviewing all the submissions, but it is too early yet to draw any conclusions.’ Everyone is waiting for the European Commission’s legislative proposal, which will then first be discussed in the EC’s Technical Adaptation Committee (TAC). It will then go to the Council and the European Parliament. ECN director Siebert hopes that either the European Commission itself will reconsider the addition of grey residual waste and sewage sludge as input materials, or the member states will intervene. She expects the majority of EU countries will vote against the current plans: ‘I’m sure of it.’

More EU countries reject MBT compost

Not only the Netherlands, but also other EU countries in the technical working group on end-of-waste criteria for compost reject the text of the document. For Italy the JRC proposal is unacceptable, says Giulia Sagnotti, a senior civil servant at the environment ministry in Rome. According to Sagnotti, the sample analyses carried out by JRC were way too inadequate. ‘Only a small number of samples were used. The composition of municipal waste is highly variable and also changes over the course of the year, but the samples took no account of this. We think the organic residual fraction from MBT must be landfilled or incinerated, because the stabilised material contains too much contamination and poses health risks.’ Sagnotti argues that this means the results of JRC’s analyses do not justify classifying household waste as an input stream. She is equally critical of the extra monitoring requirements. ‘This just adds to the costs. It will make compost more expensive and so less attractive to buyers.’

Arjen Brinkmann (BVOR):"If these plans go ahead, we will be right back where we were before."
Yves Coppin (Veolia Environnement):"Sometimes MBT compost is better."
Stefanie Siebert (European Compost Network):"This proposal will seriously damage compost sales."
John van Haeff (Attero):"MBT stabilate is not comparable with the high quality compost produced by Dutch composters."

Vision DWMA

DWMA believes that European end-of-waste criteria for compost could have two possible benefits – if the right standards are upheld. First, harmonisation of standards across the EU may increase the opportunities for cross-border trade by creating the necessary confidence that compost produced in other Member States can be used safely. Second, European end-of-waste criteria would provide a clear incentive to Member States that still landfill much of their biowaste to move towards cost-effective and beneficial recycling of clean (source-separated) input streams of biowaste.

A precondition for these benefits is the introduction of high and easily enforceable standards. They are the key to reaping these benefits and gaining the long-term trust of our customers.