Response to the EC consultation on the assessment study of the options to improve the management of Biowaste in the EU

EUREAU Members are producers of sewage sludge. It’s clear that sludge is excluded from the scope of the “biowastes”, but we would like to take the opportunity of this consultation on the management of biowastes in the EU to emphasize that treatment routes and use of sewage sludge is very similar to that of biowaste.

Recycling sewage sludge on land is an important outlet in Europe and for most of EUREAU members. Composting is also an increasing route for sludge, mostly in association with biowaste (green waste plus sometimes food waste); biowaste and sludge composts are used in the same market. In agriculture also manure is commonly used. Treatment of these fractions can sometimes be combined with anaerobic digestion, and the exclusion of sludge form the scope of biowaste on one hand creates uncertainty around the regulatory regimes for controlling the recycling of any co-digested products, and on the other hand, there is a risk in having inconsistent standards for similar materials.