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The EU Taxonomy will classify which economic activities, and when, are considered environmentally sustainable, so eligible for EU Green Deal investment. It may become a key tool for private investors, markets, other public policies. Phosphorus recovery from sewage is one of the 100 activities listed (at the same level as e.g. livestock production, crop production, hotels and accommodation …) but N-recovery or P-recovery from other streams is not cited.

Consultation open to 24th September 2021, 18h00 deadline (not midnight).

The unified EU-wide classification system (“EU Taxonomy”) will establish an operational list of economic activities, with technical screening criteria (TSC), determining in which cases each economic activity makes a ‘substantial contribution’ to an environmental objective. The Taxonomy Regulation (2020/852) defines six eligible environmental objectives: Climate change mitigation, Climate change adaptation, Water and marine resources, Circular economy, Pollution prevention and control, Biodiversity and ecosystems.

The EU has now published a report (over 1 000 pages including the annex) proposing criteria for classifying when a wide range of different industries and activities can thus be considered environmentally friendly, covering (amongst many others) agriculture (both livestock and crop production), sewage treatment, waste management ... The report and its annex propose TSC (Technical Screening Criteria for “substantial contribution” to sustainability) and criteria for DNSH (Do No Significant Harm, under Pollution Prevention and Control).

The consultation, based on the published report draft Taxonomy categories and criteria, enables public comment, for each of the nearly one hundred activities / industries listed, to comment on the description/boundaries of the activity and the proposed criteria (TSC and DNSH): ambition level of criteria, key factors missing from criteria, feasibility of implementation, comparison to state of the art, scientific justification, possible improvements of wording or clarifications.

Phosphorus recovery from waste water is one of nearly one hundred activities for which Technical Screening Criteria are proposed (Annex B, pages 922-927).

However, the proposal is limited, somewhat imprecise and in places confused:

  • It refers only to P-recovery from municipal wastewater (it is under $12: “Sewage”)
  • Only P-recovery, recovery of N or other nutrients or organic carbon are not considered
  • Only two specific routes are considered:
    - P-recovery integrated into the wastewater treatment plant, with recovery of >10% of inflow sewage works P (e.g. struvite)
    - P-recovery from sewage sludge mono-incineration ash by chemical or thermal process, with recovery of > 80% of inflow
  • The text inappropriately compares energy consumption in the above P-recovery routes to that in production of P4
  • It seems to be assumed that all recovered P materials will be used as fertiliser, whereas recovered phosphoric acid can be used in high added-value technical applications
  • Close reference is made to the German P-recovery legislation, but no mention of the Swiss legislation, which is of interest as regards implementation and state-of-the-art even if not in the EU
  • No requirements, or inappropriate, are proposed on contaminant separation in the recovery process, safety and quality of the recovered P product (it is stated that it will be “a material with a real market demand ensuring its reasonable use” but then conformity only to the old EU fertilisers regulation 2003/2003 is specified)

ESPP will input to this consultation addressing the questions above.

ESPP members and other stakeholders reading this eNews are recommended to reply to this EU public consultation, suggesting other technologies for inclusion in this section on “P-recovery”, inclusion of technologies for N-recovery, or suggesting inclusion of nutrient recovery in other sections, e.g. 1.1 Agriculture – animal production; 2.19 – Manufacture of food & beverages – circular economy; 11 - Water supply / desalination; 13.5 – Recovery of bio-waste by AD and/or composting; 13.8 – Material recovery of non-hazardous waste.

For water, the proposed criteria are based on achieving good environmental status of fresh or marine waters (as defined under the Water Framework and Marine Strategy Framework Directives), or preventing deterioration of waters in good status.

For agriculture, proposed criteria for both animal and crop production include limiting nutrient losses, in particular by a farm-gate nitrogen balance and minimum nitrogen use efficiency (NUE). ESPP will input that these criteria should be widened to include phosphorus. A livestock feeding plan, specifying feed nutrient content, and an annual crop nutrient management plan, including soil testing every 3-5 years for N and every 5 years for P, are also indicated under DNSH.

EU public consultation on “Taxonomy”, open to 24th September 18h00 CEST (not midnight). This page includes overview, links to the report and annex with proposed categories and criteria, and link to the public consultation questionnaire: With thanks to EBA for alerting ESPP to this consultation.

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