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The JRC ‘STRUBIAS’ proposed criteria for integrating ashes (as recycled nutrient fertilisers) into the revised EU Fertiliser Regulation effectively exclude sewage sludge incineration ash. The JRC proposals target only the use of ash directly on fields (e.g. after granulation or blending) but do not cover the use of ash as an input ingredient into a chemical / industrial process. The JRC proposals therefore fix contaminant limits and nutrient plant availability requirements which are appropriate for ash being used directly on fields, but are irrelevant if the ash is being chemically processed (contaminants can be removed, nutrients transformed into different forms). However, fertilisers using ashes as a production ingredient are currently excluded from the revised Fertilisers Regulations (CMC1 excludes wastes as inputs). ESPP has therefore developed proposed criteria for “ash as a process ingredient” to propose to the EU Fertiliser Regulation process. These raise questions concerning End-of-Waste, REACH, fate of removed contaminants and intermediates (e.g. phosphoric acid is recovered from ash, then re-processed to produce fertiliser). Input and comments to these ESPP proposals are invited by email:

JRC proposed Fertiliser Regulation criteria (“nutrient recovery rules”) for struvite (and other phosphate precipitates), biochars and ash (STRUBIAS) and ESPP proposals for “ash-as-an-ingredient” in the revised EU Fertilisers Regulations, for comment www.phosphorusplatform.eu/regulatory

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