Public consultation on digestate and other adjustments
Open to 9th March 2022, EU public consultation on conditions for authorising “post-processed” digestate, including after nitrogen recovery, in the Fertilising Products Regulation, and on various other technical adjustments. For digestates (CMC4 and CMC5) the proposed amendment, which follows from questions and proposals submitted to the European Commission by ESPP and EBA (European Biogas Association) enables certain post-processing of digestates (treatments after the anaerobic digester itself), that is, the use in CE-fertilisers of digestates conform to CMC4 or CMC5 criteria after:
- ·Mechanical solid - liquid separation, with use of up to 5% additives necessary for the solid-liquid separation, e.g. coagulants or polymers (subject to REACH registration of the additive where appropriate)
- ·Physical processing to remove water (where the process does not chemically modify the digestate)
- ·Removal of soluble ammonium to recover nitrogen
ESPP notes that (to our understanding):
- Recovered nitrogen products (resulting from the ammonia removal above) are expected to be covered by the proposed new CMC15 (see ESPP eNews n°63) subject to purity and other requirements.
- Mechanical conditioning of digestate (fractions), such as drying (low or ambient temperature, solar), compacting, pelletising or granulation, removal of fibres … are not cited in the proposed amendments. ESPP will request that the eligibility of such processes, which are standard fertilising product conditioning processes, be clarified in the European Commission’s “Frequently Answered Questions” (FAQ).
- Addition of a chemical to adjust the pH of digestate is considered to be a combination of two CMCs (digestate fraction, pH additive), that is the chemical itself must be CMC (e.g. CMC1).
- Chemical post-processing of digestate, such as ion removal by precipitation, ion exchange, adsorption, plasma treatment, electrostatic separation … are NOT covered by the amendments, and digestate (fractions) after such chemical processing cannot be included in CE-fertilisers
ESPP notes that post-processing of composts CMC3 (e.g. dewatering) is NOT covered by the proposed amendments, presumably because the compost industry did not indicate that such processes could be relevant for placing composts on the market.
The other adjustments include text clarifications concerning nitrification inhibitors and specifying how efficiency is tested for such products (which aim to reduce nitrate leaching risk) and adjustments to ensure coherence with other existing EU texts or of the FPR itself: registration requirements for magnesia and for polymers, PCB limits in pyrolysis and gasification materials, conformity assessment of biostimulants.
EU public consultation open to 9th March 2022 “Fertilising products - technical amendments to the rules” HERE.