European Compost Network ECN e.V.
ECN
The European Compost Network (ECN) is a European non-profit membership organisation promoting sustainable recycling practices in composting, anaerobic digestion and other biological treatment processes of organic resources.
ID: 509941347594-30
Lobbying Activity
Response to Circular Economy Act
6 Nov 2025
The European Compost Network (ECN), the European umbrella organisation representing the bio-waste recycling sector, welcomes the Commission's intention to amend several pieces of European waste legislation and is pleased that the Commission appears to recognise the need to further implement existing legislation on the collection and use of bio-waste. In this context, the ECN proposes 12 key measures to support a more ambitious policy. Please find attached our detailed feedback.
Read full responseResponse to Food and Feed Safety Simplification Omnibus
14 Oct 2025
The European Compost Network (ECN), the European umbrella organisation representing the bio-waste recycling sector, welcomes the Commissions initiative to reduce unnecessary regulatory burdens in order to improve competitiveness and resilience of EU food and feed systems while maintaining high standards for food and feed safety, for human health, and for environmental protection. However, the ECN believes that it is also essential to consider the circularity of EU food and feed systems, particularly with regard to the recycling of separately collected food waste containing animal by-products (ABP) into organic fertilisers and soil improvers, such as compost and digestate. Please find attached our detailed feedback.
Read full responseResponse to Evaluation of the Fertilising Products Regulation
17 Sept 2025
ECN Feedback on the Evaluation of the EU Fertilising Products Regulation (EU FPR) The ECN, which represents the circular bioeconomy in Europe and produces quality compost and digestate from over 48 million tonnes of separately collected biowaste per year in more than 4,500 composting and anaerobic digestion plants across Europe, welcomes the initiative to evaluate the EU Fertilising Products Regulation, which came into force on 16 July 2022. The ECN has welcomed and supported the development of a harmonised regulation for fertilising products, with the aim of boosting the market for circular recycled products in particular bio-waste materials such as compost and digestate. This Regulation established European-wide end-of-waste criteria for compost and digestate being used as fertilising products (i.e. organic fertilisers, soil improvers, growing media). However, there are currently no significant amounts of compost- or digestate-derived CE fertilising products available on the European market. Adjustments, changes, simplification and coherence are needed! Compost and digestate have been used as organic soil improvers and fertilisers on national markets for decades. On average, 50% of produced compost and 93% of produced digestate is used in agriculture. The requirements for these materials derived from waste are set out in national waste regulations (e.g. biowaste and compost ordinances) and national fertiliser regulations. As these are well-established products on national markets where coherent waste/product regulations are in place and/or where external quality assurance is required, manufacturers have little incentive to obtain a CE mark. Fulfilling the EU FPR requirements, particularly with regard to the requested conformity assessment, will impose an additional burden and cost on manufacturers The main bottlenecks, which hinder the placing of compost- and digestate-derived fertilising products on the European market are listed here: Accreditation requirements of the conformity assessment procedure according to Module D1 for waste-derived components materials in fertilising products or for waste-derived fertilising products Legislative incoherence and inconsistency (EU FPR/Waste Framework Directive/Animal By-Products Regulation - Delegated Act on determining end points in the manufacturing chain of certain organic fertilisers and soil improvers) Exclusion of valuable input materials for composting and anaerobic digestion from the food/feed and bio-based processing industry Unsuitable transformation parameters for composting of ABP-derived materials Lack of harmonised CEN standards for compost and digestate-derived EU fertilising products Unsuitable parameters for compost and digestate which does not fit to material specific properties The above-mentioned bottlenecks are explained in detail in the Feedback from ECN, which can be accessed in the attached file.
Read full responseResponse to Commission Implementing Regulation on the list for the purposes of Article 26 of Regulation (EU) 2024/1252
18 Jul 2025
The European Compost Network (ECN), the European umbrella organisation representing the biowaste recycling sector, welcomes that digestate or compost from separately collected biowaste are considered by the Commission as having a relevant critical raw materials recovery potential within the meaning of the Critical Raw Materials Act (Regulation 2024/1252). It is a major step forward for the scaling-up of the biowaste recycling sector. You will find attached our detailed feedback.
Read full response8 Jul 2025
The European Compost Network (ECN), the European umbrella organisation representing the bio-waste recycling sector, urges the Commission not to include composting and anaerobic digestion under the EU ETS, as this would be counterproductive and would undermine the effective transition to a circular economy. Please see attached our detailed feedback.
Read full responseResponse to Towards a Circular, Regenerative and Competitive Bioeconomy
19 Jun 2025
The European Compost Network (ECN), the European umbrella organisation representing the bio-waste recycling sector, welcomes the initiative of the Commission to update its 2012 Bioeconomy Strategy to promote a more circular, regenerative and competitive bioeconomy. As the recycling of bio-waste into fertilising products (i.e., compost and digestate) is essential to achieving a circular economy and generates new market opportunities, the ECN believes it should be recognised as a truly bioeconomy activity. Please find our detailed feedback attached. For more comprehensive data, we invite you to refer to the relevant studies below: - Brambilla V., Confalonieri A., Krutova I., Lopez E., Giavini M. & Ricci M. (2024). LIFE BIOBEST D3.1 Guidelines on the separate collection of bio-waste, https://zerowasteeurope.eu/library/guideline-on-the-separate-collection-of-bio-waste/ - LIFE BIOBEST D5.2 Policy brief including the regulatory barriers, https://zerowasteeurope.eu/library/policy-brief-including-the-regulatory-barriers-for-bio-waste-separate-collection-and-treatment/ - Jourdan M., Favoino E., LIFE BIOBEST D5.4 Comprehensive Guidance for effective bio-waste management in the EU, https://zerowasteeurope.eu/library/comprehensive-guidance-for-effective-bio-waste-management-in-the-eu/ - Nohales, G. & Stinavage, M. (2024). LIFE BIOBEST D3.2 - Guideline on governance and economic incentives, https://zerowasteeurope.eu/library/guideline-on-governance-and-economic-incentives/ - ECN Data Report 2022, https://www.compostnetwork.info/ecn-data-report/
Read full responseResponse to COMMISSION DELEGATED REGULATION on extending the scope of traceability of the Union database
7 Nov 2024
The European Compost Network welcomes the Commissions draft delegated regulation implementing the Renewable Energy Directive (EU) 2018/2001 aiming to increase the use of renewable energy from renewable sources, including biogas and biomethane produced from bio-waste. However, we would like to highlight some significant concerns regarding the proposed provisions. You will find attached our detailed position.
Read full responseMeeting with Maria Noichl (Member of the European Parliament, Rapporteur for opinion) and European Biogas Association
15 Nov 2023 · Soil health
Meeting with Beatrice Covassi (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and
15 Nov 2023 · Public Hearing - Soil Monitoring Law
Response to Waste Framework review to reduce waste and the environmental impact of waste management
2 Nov 2023
The European Compost Network ECN welcomes the opportunity to provide feedback on the Commissions public consultation concerning the new proposal for a revised waste framework directive (WFD), focusing on food and textiles aspect. Food waste is an important fraction of bio-waste and its generation its mismanagement must be addressed properly. In fact, according to the last revision of the WFD in 2018, EU countries shall set up no later than 31 December 2023 a separate collection system for municipal bio-waste which includes food residues from households and commercial activities as well to curb the amount of bio-waste currently sent to incineration and/or landfills. Yet, as the Early Warning Report (EWR) published by the EC in July suggests, separate collection and recycling of bio-waste is still underperformed in many Member States, resulting in the impossibility to reach the targets for recycling set in art. 11 of the WFD. As the EWR indicates, action must also include a focus on the treatment of bio-waste, as this separately collected waste stream represents more than one third of total municipal solid waste. Due to its high share in the total amount of municipal waste generated, a proper management system for bio-waste is a pre-condition if recycling targets are to be achieved. Against this background, and while supporting the inclusion of food waste reduction targets in the various steps of the supply chain from processing/manufacturing to consumption, the ECN would like to highlight two other important targets that are missing in the new Commissions proposal: Recycling target for non-municipal bio-waste (food waste from industries) Reduction target of food waste (bio-waste) in residual municipal
Read full responseResponse to Soil Health Law – protecting, sustainably managing and restoring EU soils
2 Nov 2023
The European Compost Network ECN welcomes the opportunity to provide feedbacks on the Commissions public consultation concerning the new proposal for a directive on soil monitoring and resilience. Being the association representing the bio-waste recycling sector at European level, the ECN has been a strong advocate for sustainable management of soils since its creation in the early 2000s. In fact, bio-waste recovery through composting and anaerobic digestion produces organic soil improvers and fertilisers compost and digestate whose application is nowadays all the more important since degraded soils account for 60-70 % of European land. High-quality compost and digestate improve soil health and productivity in many different ways, by increasing soil organic matter and soil biodiversity, reducing soil compaction, improving water holding capacity and by being sources of recycled nutrients which are held in the soil longer thanks to the positive effect of the increased organic matter on soil buffering capacity, thus requiring fewer mineral fertilisers. Against this background, the ECN supports the general objectives of the initiative from the European Commission, since the lack of a dedicated legislation on soil has had - and could still have - a negative effect on soil protection and governance. Despite this, we think there is room for changes and improvement on certain aspects addressed by the Soil Monitoring Law (SML), above all those which can highlight the need and foster the utilisation of organic materials for the benefit of soil in a circular economy perspective. Please find more details in the ECN contribution to the consultation attached.
Read full responseResponse to Initiative on EU taxonomy - environmental objective
3 May 2023
The ECN welcomes the opportunity to comment on the Commissions proposal for an Environmental Delegated Act in the framework of the EU Taxonomy Regulation, which establishes a classification system for environmentally sustainable economic activities. Specifically, the ECN would like to submit its feedback on ANNEX II of the draft delegated act focusing on determining the conditions under which an economic activity qualifies as contributing substantially to the transition to a circular economy. As representatives of the biowaste recycling sector and promoters of sustainable resource use through the application of high-quality compost and digestate in agriculture, horticulture, and landscaping, ECN fully supports the shift towards a circular model generating benefits to all three dimensions of sustainability. Composting and anaerobic digestion processes create multiple positive environmental effects that help achieve different objectives and targets set by the European Green Deal, thus we first and foremost welcome the recognition of their contribution to these goals with their inclusion in the list of environmentally sustainable economic activities. Please find our feedback on the draft delegated act attached!
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
13 Feb 2023
The European Compost Network (ECN) welcomes the opportunity to comment on the Commissions public consultation on the revision of the packaging and packaging waste directive. First of all, the ECN acknowledges the efforts of the Commission in addressing the increase of packaging and packaging waste generation and tackling the limited competitiveness of secondary raw materials. Taking action towards a shift to a full circular economy that prioritises reuse and recycling is key to reaching resource efficiency and contributing crucially to the goals set in the EU Green Deal and Zero Pollution Action Plan to make Europe climate neutral and toxic-free by 2050. In principle, the ECN underpins the decision of the Commission to implement harmonised rules in the form of a Regulation, since the present situation clearly highlights the shortcomings and regulatory failures of the current Directive. The ECN supports the circular economy. The organisation and its members are committed to increasing separate collection and recycling of bio-waste and are engaged in producing quality compost and digestate to be used in growing media, as well as organic fertilisers and soil improvers applied in agriculture, horticulture and landscaping. First and foremost, we would like to emphasize that ECN does not consider biological treatment (composting and anaerobic digestion) as the generally preferred option for the recycling of any packaging item. In light of this, as representatives of the bio-waste recycling sector, we would like to raise concerns and make remarks specifically on Article 8 of the proposed legislation, which regulates the production and marketing of a specific and limited group of compostable packaging material. Our main concern is related to the title Compostable Packaging as this does not cover all biological waste treatment techniques, like anaerobic digestion, which is a common biological waste treatment technology for the recycling of separately collected biowaste into quality products, like digestate. Biodegradation under anaerobic condition shall be considered under Article 8 and especially the listed items in paragraph 1 shall degrade under all industrially controlled conditions in bio-waste treatment facilities. Also, the definition compostable packaging given under Article 3 (41) does not explicitly refer to anaerobic digestion. There is a need to respect as well as refer to the anaerobic treatment of bio-waste, which is described as one of the best available techniques (BAT) for waste treatment under the Industry Emission Directive 2010/75/EU. Especially when potentially compostable packaging ends up with separately collected bio-waste in anaerobic digestion plants. In general, it has to be respected that automatic and unconditional access of compostable materials to biowaste recycling facilities cannot be granted, as the technical suitability depends on the composting practices and infrastructure present in a particular situation. Thus, there is a need for a phased implementation, considering particular regional or national situations. Please find the ECN's full response attached!
Read full response21 Oct 2022
ECN welcomes the draft ‘Commission delegated regulation supplementing Regulation (EC) No 1069/2009 of the European Parliament and of the Council as regards the determination of end points in the manufacturing chain of certain organic fertilisers and soil improvers’, in order to make them available on the market of EU fertiliser products as referred to in Article 42(5) of Regulation (EU) 2019/1009 of the European Parliament and of the Council.
ECN generally agrees that the end point in the manufacturing chain is reached at the end of the composting and anaerobic digestion process on an approved plant in accordance with Article 24 (1) of the Regulation (EC) 1069/2009 after the necessary sanitation has been proved and where the compost and digestate are placed on the market as organic fertiliser or soil improver. The end point is always reached after compost and digestate have been tested for pathogens and when the test results comply with the limit values outlined in the ABP Regulations. As compost and digestate as component materials are produced in approved plants in accordance with Article 24 (1), point (g) of the Regulation (EC) 1069/2009, we ask to include this in Article 5 of the draft delegated regulation as well.
But with regard to Annex V of Regulation (EU) 142/2011 (required transformation parameters) we see an inconsistency between the possibility to place compost or digestate on the market according to the Fertilising Products Regulation (EU) 2019/1009 and the Animal by-products Regulation (EC) 1069/2009.
According to Annex V of Regulation (EU) 142/2011 Section 2, point 4,’Operators may place on the market digestion residues and compost, which have been produced according to parameters which have been authorised by the competent authority:
(a) in accordance with point 1;
(b) in accordance with points 2 and 3, only within the Member State where those parameters have been authorised.
That means in case (a), which refers to point 1 of Section 2 where alternative transformation parameters for biogas and composting plants can be validated according to the harmonised model and authorised by the competent authority, the trade of compost/digestate is not limited to the Member State itself, which signifies that the same level of safety is acquired than the standard transformation parameters. The inconsistency lies within the fact that (treated) animal by-products within the scope of ABPR are allowed as fertilising products on the entire European market in terms of safety, but they are ruled out by the EU FPR because the possible treatment parameters are narrowed down.
Therefore, we call the Commission to allow alternative treatment processes with comparable conditions than the standard treatment parameters to prevent risks to public and animal health which are validated and allowed by the competent authority by adding Section 2, point 1 of Chapter III of Annex V of Regulation (EU) No 142/2011 to Article 3 (b) and (c) of this delegated regulation.
Read full responseResponse to European Critical Raw Materials Act
10 Oct 2022
The European Compost Network ECN welcomes the opportunity to give its feedback on the Commission’s public consultation on a European Critical Materials Act. Undoubtedly, the EU needs to strengthen circularity of raw materials and foster research and innovation, to better face potential shortcomings and supply deficits provoked by geopolitical instability and growing demand.
ECN would like to stress that critical raw materials also play a key role in sectors like agriculture and food security, whose reference is missing from Commission’s proposed initiative. We all have witnessed the repercussions that the Russian invasion of Ukraine provoked to the energy sector, with skyrocketing prices for mineral fertilisers, nitrogen and phosphorus more specifically. Earth’s phosphorus is especially important, as it is included in the CRM list of the EU and it is depleted at an alarming rate. At current consumption levels, we will run out of known phosphorus reserves in around 80 years, but the demand is growing constantly and so is consumption.
Consequently, ECN believes that the bio-waste sector could represent a valuable and sustainable alternative resource, bringing essential nutrient back to soil for food and crop production. Indeed, Bio-waste recycling would lead to multiple benefits: high quality compost and digestate resulting from the correct sorting and recycling of bio-waste have been proven to work effectively as organic soil improvers and fertilisers, by enhancing and maintain overall soil quality. Today 15,8 million tonnes of compost and digestate are recycled form biowaste, which can replace 129 thousand tonnes of nitrogen and 42 thousand tonnes of phosphates per year. This not only would reduce or suppress the need to apply mineral fertilisers to plants and soils, but it would also improve circularity by closing the nutrient cycle, which in turn would reduce the EU dependency to unstable supply sources of these critical materials and limit the overexploitation and mining of finite resources.
Despite not being listed as CRM, we are the opinion that peat is also crucial in the fight against climate change and should therefore be addressed in this initiative. In this regard, compost can replace this natural material and prevent peat extraction, which is known for being one of the practices contributing the most to GHG emissions. This would help restoration processes involving peatlands and wetlands across Europe while dramatically lessen the amount of CO2 released into the atmosphere.
Bottlenecks still exist with regard to bio-waste derived organic soil improvers and organic fertilizers’ presence on the EU market, consequently hampering as well the proper nutrient recycling and contributing to resource inefficiency. As the roadmap highlights, EU legislation must be expanded in order to better incentivise and facilitate the recovery of critical raw materials from the different waste streams, prioritizing bio-waste recycling for nutrient and organic matter recovery.
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