European Compost Network ECN e.V.
ECN
European Compost Network ECN is a collaboration of partners promoting sustainable practices in composting, anaerobic digestion and other treatment procedures for organic waste across Europe.
ID: 26513411360-51
Lobbying Activity
Response to Integrated Nutrient Management Action Plan
25 Apr 2022
ECN welcomes the initiative to set up an integrated nutrient management plan with regard to a comprehensive legsilative approach to become carbon neutral by 2050 and to set up a Circular Economy in Europe. Bio-waste plays a key role in the Circular Economy. Bio-waste can be turned through organic reycling (composting and anaerobic digestion) into high-quality compost and digestate, which are used as organic soil improvers and organic fertilisers on soils. 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. Besides nutrients replacement, 5,3 million tonnes of organic carbon is delivered as stable organic matter to the soils. Organic matter plays a key role in keeping soils healthy. Therefore, the sustainable use of recyled organic fertilsers and soil improvers (like compost and digestate) should be considered in the integrated nutrient management plan in a more prominent way.
Sustainable agriculture and horticulture both rely on healthy soils and nutrient recycling. This is not only common sense, but it also forms the basis of the EU’s Circular Economy Strategy set out in the European Green Deal. However, current agricultural practices have, in many instances, eroded soil, thereby reducing its productivity and resilience. We therefore plea not only to focus on (mineral) nutrient balances, but also to recognise as well the role organic carbon plays in soils. Repeat applications of quality assured compost and stabilised digestate can help improve the health and productivity of agricultural and horticultural soils. Compost does this in a number of different ways. It can:
Increase soil organic matter, helping to store carbon.
Improve soil structure, which reduces compaction.
Increase the soil’s water holding capacity, reducing irrigation and storing water during heavy rainfall events.
Increase the number and diversity of organisms in the soil.
Increase plant nutrient levels, which reduces the need for artificial inorganic chemicals.
Increase the buffering capacity of the soil, helping it to hold onto nutrients for longer.
Recycling nutrients in compost and stabilised digestate and returning them to soil benefits the environment in a number of important ways:
It reduces demand for chemically manufactured nitrogen fertilisers – as the manufacturing process is very energy intensive this significantly reduces greenhouse gas emissions, which are thought to be about 1% of total global emissions.
It reduces emissions to the air and water courses – the organic matter in compost and digestate helps bind plant nutrients, preventing them from being washed into watercourses. In addition, as nitrogen in compost is bound up with other compounds, it is released slowly over time and helps form a nutrient ‘bank’ in the soil so that the nutrients are present for plant growth for a number of years.
It reduces mining of elements, such as phosphorus and potassium, and lime – as phosphorus is an EU Critical Raw Material, recycling P helps conserve this valuable resource within Europe.
For further information, access ECN Status report and the fact sheets on the sustainable use of compost 'Soil fertility and productivity' & soil structire and carbon storag available on our website: www.compostnetwork.info
Read full responseResponse to Technical amendments to the Fertilising Products Regulation
9 Mar 2022
The European Compost Network (ECN) welcomes the initiative of the European Commission to take up requirements for the post-processing of digestate (CMC4 and CNC5) in Annex II of Regulation (EU) 2019/1009.
We fully support the inclusion of post-processing techniques for digestate, but there is a need for clarification on the remaining digestatefrom ammonium stripping (new 3b) and we would like to ask the Commission to take the following proposals for amending the new 3c) as listed in the attached file under consideration.
Read full responseResponse to Measures to reduce microplastic pollution
23 Dec 2021
The initiative recognises that there are knowledge gaps about the presence of MPL in the environment, in drinking water and in food; the European Compost Network (ECN) welcomes initiatives at the National and EU to fill these gaps and specifically about the presence of MPL in food and food residues.
A number of policy options and actions are listed/suggested in the document; among these the possibility to require waste water treatment plants to apply technologies for avoiding MPL to be mixed with sludge; ECN welcomes this proposal, since the avoidance of MPL in input feedstock also for composting and anaerobic digestion appears to be the most effective approach for recycling organic waste and feedstock into quality products. The issue of compost and digestate acting as unintentional carrier of MPL and the commitment of the biowaste recycling sector in minimising the concentration of plastics in these products used on soil has been addressed by the ECN position paper ‘Plastics, Microplastics in Compost and Digestate’ released in July 2021.
The Initiative mentions the presence of MPL in sludge from WWTP and the need to prevent/reduce their concentration; the Initiative states that it will develop in coordination with ongoing procedures revising the sewage sludge directive. The specific focus on sludge from WWTPs is likely to include additional evaluations by the EU Commission on the recycling of sludge and it is therefore recommendable that ECN feeds back to the “call for evidence” by:
• Underlining the need for a holistic approach to consider sludge (in connection with restoring soil organic carbon (SOC) by producing quality products such as compost and digestate; thus, the option of organic recycling of sludge from WWTPs shall always be possible and preferable compared to energy recycling (i.e. incineration) and decision of acceptance to recycling shall depend on the quality of the sludge.
Read full responseResponse to European Bioeconomy Policy: Stocktaking and future developments
23 Jul 2021
The European Compost Network supports the further development of the EU Bioeconomy Strategy and to align this with the European Green Deal.
There is a need to set concrete actions and targets within the European Bioeconomy policies to achieve the European Green Deal aim to become climate-neutral by 2020.
Referring to the 14 key actions of the Bioeconomy Strategy Action Plan we would like to call the Commission to strengthen the role of bio-waste in a circular bioeconomy in Europe. Bio-waste, as the main waste stream of municipal solid waste, plays an important role, but there is still a need to strengthen the implementation of separate collection of bio-waste across Europe.
Investments into the biological waste management sector are needed as well as to build of markets for recycled quality products like compost and digestate. We call up on the Commission to recognise the values of quality assured compost and digestate products for the agricultural and horticultural sector and to take up these products into the new initiatives of the European Commission (EU Biodiversity, Farm to Fork, Soil Strategy) and as well in the revision of the EU Common Agriculture Policy. Maintaining and improving the ecological status of soil is key. Therefore, we call that the use of quality recycled organic materials should be supported in carbon farming schemes.
Still in 2018 we have organised together with the Urban Agenda for the EU on Circular Economy, EuroCities and Municipal Waste Europe a policy workshop ‘The Road to an Urban Bioeconomy: Barriers and Solutions to Closing the Loop of Bio-Resources’ with the aim to discuss the challenges and opportunities the mandatory separate collection of bio-waste, to be implemented in all member states by 2023. As an outcome of this workshop the organisations identified 9 recommendations to achieve the new agreed bio-waste targets. Please find these joint recommendations of the European Compost Network, the Urban Agenda for the EU on Circular Economy, EuroCities and Municipal Waste Europe for further consideration attached.
Read full responseResponse to Agriculture - List of products and substances authorised in organic production
22 Apr 2021
ECN Draft Feedback on Annex II of Article 24 (1) of Regulation (EU) 2018/848
Annex II Authorised Fertilisers, Soil Conditioners and Nutrients referred in Point (b) of Article 24 (1) of Regualtion (EU) 2018/848
The European Compost Network welcomes the proposal of the European Commission on ‘implementing (EU) .../... of XXX authorising certain products and substances for use in organic production and ethablishing their lists’.
In Article 2 ‘Fertilisers, soil conditioners and nutrients’ it is expressed that ‘only the products and substances listed in Annex II of this Regulation may be used in organic production as fertilisers, soil conditioners and nutrients for plant nutrition, litter improvement and enrichment, ..., provided that they are compliant with, , the relevant applicable Articles of Regulation (EU) 2019/1009, ..., Regulation (EC) No 1069/2009, ..., and Commission Regulation (EU) No 142/2011 and, where applicable, in accordance with national provisions based on Union Law.’
With regard to the above quoted Article 2, we fear that besides national rules the restrictions and speciifcations set in the horizontal legislations on fertilising products (Regulation (EU) 2019/1009) and on animal by-products (Regulation (EC) No 1069/2009, COM (EU) No 142/2011) for compost and digestate from bio-waste must be met. If this is the case, that would hinder the use of compost and digestate from bio-waste under organic farming practices, as it is common practise today under national rules in several European countries.
Compost and digestate from bio-waste are products which are mainly used locally and the market for our products used in organic farming increased over the last years. Based on the market survey of the German Compost Quality Assurance Organistion (BGK) in 2019 more than 5 % of certified compost was used in organic farming in Germany (which is equal to 375.000 tonnes of separately collected bio-waste). In Flanders a small part of the compost is used in agriculture: only 18%. But the use of compost in organic farming increased in 2019 from 0,2% till almost 1%. This is about 4,5% of the compost used in agriculture.
Please find further aspects for consideration in the uploaded ECN response.
Read full responseResponse to Evaluation of the Sewage Sludge Directive 86/278/EEC
24 Aug 2020
Please find attached the feedback of the European Compost Network ECN.
Read full responseResponse to A new Circular Economy Action Plan
20 Jan 2020
The European Compost Network (ECN) welcomes the initiative of the European Commission to adopt a new Circular Economy Action Plan with the objective to boost the circular economy model in the EU and abroad. ECN welcomes the planning of new measures to establish a functioning and competitive integrated market for secondary raw materials and recommends that circularity of biological loops is fully addressed by
I. Providing legal certainty to downstream operators
II. Enforcing the development of high-quality separate collection schemes of biowaste and other recyclables
III. Promoting the use of organic soil improving products over mineral fertilizers
Anaerobic digestion (AD) and composting are the most suitable processes of biowaste
They employ safe and easy-to-replicate technology, from small to large scale
They provide local jobs in all EU countries, especially in rural areas, and can be built and operated at relatively low cost, compared to incineration plants
AD contributes to offset fossil fuels by generating renewable energy
Compost and digestate will provide sustainable organic supply of nutrients to agriculture, including phosphorus which is a critical raw material.
As up to 50 % of municipal solid waste is organic, bio-waste plays an important role in recycling and the circular economy. There is big room for improvement as only about 40 % is currently recycled into high quality compost and digestate.
ECN welcomes the objective to reduce waste generation and strongly supports to update certain waste laws so that they further contribute to the circular economy. ECN warmly recommend the Commission to
I. Adopt EU End-of-Waste criteria for compost and digestate;
II. Prevent landfilling bio-waste;
III. Enforce mandatory separate collection of bio-waste – e.g. by adopting targets for separate collection;
IV. Remove unnecessary regulatory barriers to safe treatment of animal by-products – e.g. digestate from farm fertilizer – and derived products.
ECN strongly advocate in favour of closing organic cycles for biological materials. There is the need to develop a comprehensive strategy to build up organic matter in soils. Compost and digestate have optimal fertilizing properties. They are organic fertilizers which supply nutrients to the plants and build up soil organic matter in soils, once applied regularly. Organic matter will help maintaining and restoring soil quality, structure and its much-needed water retention capacity. This means that soils will not dry out quickly in summer months, when water is scarce but also that the likelihood of flooding in winter is reduced.
A healthy soil also works as a huge carbon sink and therefore it can sequester even more carbon. Once applied to soils, organic matter, e.g. compost and digestate, which is rich in organic carbon, ensures carbon storage for many decades.
ECN warmly agrees to involve the consumers to realize the circular economy. ECN knows the importance of consumers’ participation in management of commons – e.g. participation in municipal waste separate collection schemes. ECN understands that when overwhelmed with information, users and consumers struggle to understand how to make the right choice that would allow them to respect the environment and mitigate climate change. ECN welcomes the planned sustainable product policy and recommends the minimum requirements on products to be easy to understand and effective, and to include organic fertilizing and soil improving products under their scope.
ECN warmly invites the Commission to support stakeholders dialogue by enhancing the role and resources of the European Circular Economy Stakeholder Platform. As an important tool that contributes to efficient policy making, ECN also recommends improving Eurostat waste statistics by including, for example, separate collection figures for municipal bio-waste and commercial/industrial bio-waste.
Read full responseMeeting with Jyrki Katainen (Vice-President) and European Biogas Association and
16 Nov 2015 · Circular Economy