Genanvend Biomasse
GB
’Keep the organic resources in the loop’ står vi som forening sammen om ønsket om at recirkulere mere, recirkulere bedre og recirkulere sikkert.
ID: 160724647389-94
Lobbying Activity
Response to European Critical Raw Materials Act
25 Nov 2022
Genanvend Biomasse welcomes this initiative from the Commission. It is important to point out that much more should be done to secure and reuse the valuable resource in organic waste and in biomass in general. We support the ECN's considerations and proposals for this consultation, which were submitted on 10 October. With regard to CRM and organic waste, the focus will be on the recycling of phosphorus. The main source of phosphorus in fertilizers is phosphate rock, which has been on the CRM list since 2014. The EU's need to import phosphate rock and derived products could be significantly reduced if resources, including phosphorus, in organic waste and biomass were more available for recycling. One of the central conditions that determines the availability of organic waste and biomass for recycling is that the recycling to the soil-plant system must not pose a threat to human and animal health or the environment. It is therefore of crucial importance that waste water and other biowaste and biomasses are "clean", e.g. is kept free of harmful substances in quantities that can be harmful to human and animal health or to the environment. The focus should be on the input side to avoid the need to implement expensive and complicated end-of-pipe solutions. But at the same time, it is important to be aware of possible legislative obstacles, which can inadvertently lead to excessively restrictive regulation of biomass recycling and lead to less efficient recycling. It is therefore very important that a regulation on CRM is in accordance with existing legislation, where the directive on the treatment of urban waste water, the sewage sludge directive, the by-product regulation and the fertilizer regulation are central parts of the regulatory framework. (This answer has been submitted in collaboration with The Danish Agriculture and Food Council,TR number 1634450483)
Read full response