Green Paper on the management of bio-waste in the European Union {SEC(2008) 2936}
Date: 2008-12-03
Institutions: European Commission
Subjects: EU environmental policy, environmental law, prevention of pollution, waste management, waste recycling

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COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 3.12.2008 
COM(2008) 811 final 

GREEN PAPER 

On the management of bio-waste in the European Union 

{SEC(2008) 2936} 

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GREEN PAPER 

On the management of bio-waste in the European Union 

1. 

INTRODUCTION 

Growth in the EU is still accompanied by increasing amounts of waste, causing unnecessary 
losses  of  materials  and  energy,  environmental  damage  and  negative  effects  on  health  and 
quality of life. It is a strategic goal of the EU to reduce these negative impacts, turning the EU 
into a resource efficient "Recycling Society"1. 

Waste management is already governed by a substantial body of regulation but there remain 
opportunities for further improving the management of some major waste streams. 

Bio-waste  is  defined  as  biodegradable  garden  and  park  waste,  food  and  kitchen  waste  from 
households,  restaurants,  caterers  and  retail  premises,  and  comparable  waste  from  food 
processing plants. It does not include forestry or agricultural residues, manure, sewage sludge, 
or  other  biodegradable  waste  such  as  natural  textiles,  paper  or  processed  wood.  It  also 
excludes those by-products of food production that never become waste2.  

The total annual arising of bio-waste in the EU is estimated at 76.5-102 Mt food and garden 
waste  included  in  mixed  municipal  solid  waste3  and  up  to  37  Mt  from  the  food  and  drink 
industry. Bio-waste is a putrescible, generally wet waste. There are two major streams – green 
waste from parks, gardens etc. and kitchen waste. The former includes usually 50-60% water 
and more wood (lignocellulosis), the latter contains no wood but up to 80% water. 

Waste  management  options  for  bio-waste  include,  in  addition  to  prevention  at  source, 
collection (separately or with mixed waste), anaerobic digestion and composting, incineration, 
and  landfilling.  The  environmental  and  economic  benefits  of  different  treatment  methods 
depend significantly on local conditions such as population density, infrastructure and climate 
as well as on markets for associated products (energy and composts). 

Today,  very  different  national  policies  apply  to  bio-waste  management,  ranging  from  little 
action  in  some  Member  States  to  ambitious  policies  in  others.  This  can  lead  to  increased 
environmental  impacts  and  can  hamper  or  delay  full  utilisation  of  advanced  bio-waste 
management techniques. It should be investigated whether action on national level would be 
sufficient to ensure proper bio-waste management in the EU, or whether Community action is 
needed.  This  Green  Paper  aims  to  discuss  these  questions  and  prepare  grounds  for  the 
upcoming impact assessment which will also address the subsidiarity issue. 

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See: COM(2001) 264, COM(2005) 670, COM(2005) 666. 
COM(2007) 59. 
Estimation based on Eurostat data on municipal waste (2008). 

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2. 

OBJECTIVES OF THE GREEN PAPER 

The  revised  Waste  Framework  Directive4  calls  upon  the  Commission  to  carry  out  an 
assessment  of  the  management  of  bio-waste,  with  a  view  to  submitting  a  proposal,  if 
appropriate. 

Bio-waste management in the Community has already been discussed in two working papers 
issued  by  the  Commission  between  1999  and  2001.  The  situation  has  since  changed 
substantially: 12 new Member States with specific waste management practices have joined 
the  EU,  technological  progress  and  new  research  results  need  to  be  considered,  new 
orientations (e.g. in soil and energy policy) need to be factored in. 

This Green Paper aims to explore options for the further development of the management of 
bio-waste.  It  summarizes  important  background  information  about  current  policies  on  bio-
waste management and new research findings in the field, presents core issues for debate, and 
invites stakeholders to contribute their knowledge and views on the way forward. It aims to 
prepare  a  debate  on  the  possible  need  for  future  policy  action  ,  seeking  views  on  how  to 
improve  bio-waste  management  in  line  with  the  waste  hierarchy,  possible  economic,  social 
and  environmental  gains,  as  well  as  the  most  efficient  policy  instruments  to  reach  this 
objective. 

It  is  clear  that  major  data  difficulties  and  uncertainties  exist  with  regards  to  bio-waste 
management options, highlighted throughout the Paper. The Commission would therefore like 
to  invite  all  Stakeholders  to  provide  any  data  available  to  facilitate  the  subsequent  Impact 
Assessment of different bio-waste management options. 

3. 

STATE OF PLAY IN BIO-WASTE MANAGEMENT 

3.1. 

Current techniques 

Separate  collection  schemes  function  successfully  in  many  countries  especially  for  green 
waste. The kitchen waste are more often collected and treated as part of the mixed Municipal 
Solid  Waste  (MSW).  The  benefits  of  separate  collection  can  include  diverting  easily 
biodegradable waste from landfills, enhancing the calorific value of the remaining MSW, and 
generating  a  cleaner  bio-waste  fraction  that  allows  to  produce  high  quality  compost  and 
facilitates  biogas  production.  Separate  collection  of  bio-waste  is  also  expected  to  support 
other forms of recycling likely to be available on the market in the near future (e.g. production 
of chemicals in bio-refineries). 

Landfilling, although according to the waste hierarchy the worst option, is still the most used 
MSW disposal method in the EU. Landfills need to be constructed and operated in line with 
the  EU  Landfill  Directive5  (impermeable  barriers,  methane  capturing  equipment)  to  avoid 
environmental damage from the generation of methane and effluent. 

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Revised Waste Framework Directive (2005/0281(COD)). 
Directive 1999/31/EC. 

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Incineration:  bio-waste  is  usually  incinerated  as  part  of  MSW.  Depending  on  its  energy 
efficiency,6 incineration can be regarded as energy recovery or as a disposal. As the efficiency 
of  incineration  is  lowered  by  the  moist  bio-waste,  it  can  be  beneficial  to  remove  bio-waste 
from municipal waste7. On the other hand, incinerated bio-waste is regarded as carbon-neutral 
“renewable”  fuel  in  the  meaning  of  the  renewable  electricity  directive8  and  the  proposed 
Directive on the promotion of the use of energy from renewable sources (RES Directive)9. 

Biological  treatment  (including  composting  and  anaerobic  digestion)  may  be  classified  as 
recycling when compost (or digestate) is used on land or for the production of growing media. 
If  no  such  use  is  envisaged  it  should  be  classified  as  pre-treatment  before  landfilling  or 
incineration. In addition, anaerobic digestion (producing biogas for energy purposes) should 
be seen as energy recovery. 

Composting is the most common biological treatment option (some 95% of current biological 
treatment  operations10).  It  is  best  suited  for  green  waste  and  woody  material.  There  are 
different  methods  of  which  the  "closed  methods"  are  more  expensive  but  less  space-
demanding, faster, and stricter in terms of process emissions control (odours, bio-aerosols). 

Anaerobic  digestion  is  especially  suitable  for  treating  wet  bio-waste,  including  fat  (e.g. 
kitchen waste). It produces a gas mixture (mainly methane - 50 to 75% - and carbon dioxide) 
in controlled reactors.  

Biogas can reduce greenhouse gas (GHG) emissions most significantly if used as a biofuel for 
transport  or  directly  injected  into  the  gas  distribution  grid.  Its  use  as  biofuel  could  result  in 
significant  reductions  of  GHG  emissions,  showing  a  net  advantage  with  respect  to  other 
transport fuels11. 

The residue from the process, the digestate, can be composted and use for similar purpose as 
compost, thus improving overall resource recovery from waste.  

If not stated otherwise, the term "compost" in this document refers both to compost directly 
produced from biowaste as well as composted digestate.  

Mechanical-Biological  Treatment  (MBT)  describes  techniques  which  combine  biological 
treatment  with  mechanical  treatment  (sorting).  In  this  paper  the  term  refers  only  to  the  pre-
treatment of mixed waste with the objective to produce either a more stable input to landfills 
or a product with improved combustion properties. However, MBT using anaerobic digestion 
generates biogas and thus can also be an energy recovery process. Combustible waste sorted 
out in MBT processes may be further incinerated because of its energy recovery potential. 

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According  to  Annex  II  of  the  Waste  Framework  Directive,  incineration  facilities  dedicated  to  the 
processing of MSW are regarded as recovery operation only where their energy efficiency is equal to or 
above 0.60 for installations in operation before 1 January 2009 and 0.65 for installations permitted after 
31 December 2008.  
The pre-treated waste fraction for incineration is often referred to as RDF (refuse derived fuel).  
Directive 2001/77/EC. 
COM(2008) 19. 
ORBIT/ECN, 2008. 
In 2007, the largest European centre for biogas as biofuel opened in Lille. Based on the treatment of the 
separated organic waste collected by this municipality of 1.1 million people, it will produce 4 million 
Nm³ of biogas per year converted to transport-grade fuel, serving a fleet of 150 buses of the municipal 
transport system. 

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3.2. 

Current management in EU Member States 

There are large differences between Member States in MSW and bio-waste management. The 
report of the European Environment Agency12 distinguishes three main approaches: 

•  Countries relying heavily on incineration to divert waste from landfills, accompanied by a 
high  level  of  material  recovery  and  often  advanced  strategies  promoting  biological 
treatment of waste: DK, SE, BE (Flanders), NL, LU, FR. 

•  Countries  with  high  material  recovery  rates  but  relatively  low  incineration:  DE,  AT,  ES, 
IT,  some  achieving  the  highest  composting  rates  in  the  EU  (DE,  AT),  others  quickly 
developing their composting and MBT capacities. 

•  Countries  relying  on  landfills,  where  landfill  diversion  remains  a  major  challenge  due  to 

lack of capacity: a number of new Member States. 

Candidate and potential candidate countries also rely mainly on landfilling and in their case 
diversion of biodegradable waste from landfills will be a major challenge. 

Landfilling: In the EU bio-waste constitutes usually between 30% and 40% (but ranges from 
18%  up  to  60%)  of  MSW,13  most  of  which  is  treated  by  options  ranking  low  in  the  waste 
hierarchy. On average  41%  of MSW is landfilled,14 while in some Member States  (e.g. PL, 
LT) this percentage exceeds 90%. However, as a result of national policies and the Landfill 
Directive  which  requires  diversion  of  bio-waste  from  landfills,  the  EU  average  amount  of 
landfilled MSW has dropped from 288 to 213 kg/capita/year (from 55 to 41%) since the year 
2000. 

Incineration  reaches  a  share  of  47%  in  Sweden  and  55%  in  Denmark15.  In  both  countries, 
incineration  of  bio-waste  that  is  not  separately  collected  is  usually  carried  out  by  means  of 
cogeneration of electricity and heat and with flue gas condensation, leading to high efficiency 
and high net energy recovery.  

Mechanical-Biological Treatment has been used across the EU over the last 10 years as pre-
treatment  to  comply  with  landfill  acceptance  criteria  or  to  enhance  the  calorific  value  for 
incineration. In 2005, not less that 80 large facilities existed of a combined capacity of more 
than 8.5 million tonnes, most in DE, ES and IT16. 

For biological treatment of organic waste in general (not only for bio-waste) a total of 6 000 
installations have been identified, including 3 500 composting and 2 500 anaerobic digestion 
(AD) facilities (mostly small scale on-farm units). 124 AD installation for treatment of bio-
waste and/or municipal waste (including AD-based MBT installations) with a total capacity of 
3.9 million tonnes, were operational in 2006 and this number is expected to grow17. 

Recycling  is  supported  by  separate  collection  in  certain  Member  States  (AT,  NL,  DE,  SE 
and parts of BE (Flanders), ES (Catalonia) and IT (northern regions), while others (CZ, DK, 

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EEA, 2007 (1). 
See ACR+, 2008 and JRC, 2007. 
This and further data on landfilling – Eurostat, 2008. 
Eurostat, 2008. 
Juniper, 2005. 
L.de Baere, 2008. 

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FR)  focus  on  composting  green  waste  and  collect  kitchen  waste  with  MSW.  In  all  regions 
where separate collection has been introduced it is regarded a successful waste management 
option18. 

for  separately  collected  bio-waste 

The  overall  potential 
to 
150kg/inhabitant/year, including kitchen and garden waste from households, park and garden 
waste from public estates, and waste from the food industry19 (80 Mt for EU27). About 30% 
of this potential (24 Mt) are currently collected separately and treated biologically.20 The total 
production of compost was 13.2 Mt in 2005. Most of it was produced from bio-waste (4.8 Mt) 
and  green  waste  (5.7  Mt),  the  rest  from  sewage  sludge  (1.4  Mt)  and  mixed  waste  (1.4  Mt). 
The potential of compost production from most valuable inputs (bio-waste and green waste) is 
estimated at 35 to 40 Mt21. 

is  estimated  at  up 

Compost is used in agriculture (about 50%), for landscaping (up to 20%), to produce growing 
media (blends) and manufactured soil (around 20%), and by private consumers (up to 25%)22. 
Countries  which  produce  compost  predominantly  from  mixed  waste  and  have  undeveloped 
compost markets tend to use it in agriculture (ES, FR) or for land restoration or landfill cover 
(FI, IE, PL23). 

The demand for compost varies in Europe depending mostly on soil improvement needs, and 
consumer  confidence.  EU  soil  policy  calling  on  the  Commission  and  the  Parliament  to  act 
against the degradation of soil24 as well as increasing consumer confidence in relation to the 
safe use of composts from waste could enhance demand significantly. 

However, the use of compost and digestate from waste have limited capacity to solve the soil 
quality problem in the EU as at a typical compost application rate of 10 tonnes of compost per 
hectare and year only 3.2% of agricultural land could be upgraded even if all bio-waste was 
composted and used25, while significant long-distance transport with its negative implications 
on cost and environmental burdens would be necessary. 

3.3. 

EU legal instruments regulating the treatment of bio-waste 

A number of EU legal instruments address the issue of treatment of bio-waste. General waste 
management requirements such as environmental and human health protection during  waste 
treatment  and  priority  for  waste  recycling  are  laid  down  in  the  revised  Waste  Framework 
Directive which also  contains  specific  bio-waste related elements  (new  recycling  targets  for 
household  waste,  which  can  include  bio-waste)  and  a  mechanism  allowing  setting  quality 
criteria  for  compost.  Landfilling  of  bio-waste  is  addressed  in  the  landfill  Directive  which 
requires  the  diversion  of  biodegradable  municipal  waste  from  landfills.  The  revised  IPPC 
Directive  laying  down  the  main  principles  for  the  permitting  and  control  of  bio-waste 
treatment installations will cover all biological treatment of organic waste above a capacity of 
50 tonnes/day. The incineration of bio-waste is regulated in the Waste Incineration Directive 
while  the  health  rules  for  composting  and  biogas  plants  which  treat  animal  by-products  are 

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see e.g. http://ec.europa.eu/environment/waste/publications/compost_success_stories.htm. 
ORBIT/ECN, 2008. 
ORBIT/ECN, 2008. 
Every tonne of bio-waste results in the production of about 350-400 kg of compost. 
ORBIT/ECN, 2008 – due to very general data no sum up to 100%. 
In PL, 100% of compost is used for land restoration or covering landfills due to poor compost quality. 
COM(2006) 231 and 2006/2293(INI). 
ORBIT/ECN, 2008. 

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laid down in the Animal By-products Regulation. The proposed RES Directive also contains 
measures  on  how  bio-wastes  are  to  be  counted  towards  renewable  energy  targets.EU 
legislation  does  not  limit  Member  States'  choices  of  bio-waste  treatment  options  as  long  as 
they  respect  certain  framework  conditions,  notably  those  set  by  the  Waste  Framework 
Directive. The choice of treatment options needs to be explained and justified in national or 
regional Waste Management Plans and Prevention Programmes. Together with a definition of 
waste  which,  before  the  revision  of  the  Waste  Framework  Directive  did  not  set  clear 
boundaries for when a waste has been adequately treated and should be considered a product, 
this has led to a wide variety of policies and treatment methods in the EU, including different 
interpretations  of  Member  States  as  to  when  treated  bio-waste  may  cease  to  be  waste  and 
become a product that can move freely on the internal market or be exported from the EU.  

3.4. 

EU legal instruments regulating the use of bio-waste 

Compost:  Standards  on  the  use  and  quality  of  compost  exist  in  most  Member  States,  but 
differ substantially, partly due to differences in soil policies. While there is no comprehensive 
Community legislation, certain rules regulate specific aspects of bio-waste treatment, biogas 
production and compost use. 
The  Organic  Farming  Regulation26  lays  down  conditions  for  the  use  of  compost  in  organic 
farming. 

The eco-labels for soil improvers27 and for growing media28 specify limits for contaminants 
and require that the compost be of waste origin only. 
The  Thematic  Strategy  for  Soil  Protection29  calls  for  the  use  of  compost  as  one  of  the  best 
sources of stable organic matter from which new humus can be formed in degraded soils. An 
estimated  45%  of  European  soils  have  low  organic  matter  content,  principally  in  southern 
Europe but also in areas of France, the UK and Germany. 

Energy  recovery:  Based  on  a  Community-wide  commitment  to  reaching  a  target  of  20% 
share of renewable energy in final energy consumption by 202030, the European Commission 
proposed  a  RES  Directive  to  replace  existing  Directives  on  the  promotion  of  renewable 
electricity  (Directive  2001/77/EC)  and  biofuels  (Directive  2003/30/EC).31  The  proposal 
strongly  supports  the  use  of  all  types  of  biomass,  including  bio-waste  for  energy  purposes, 
and requires Member States to develop National Action Plans to outline national policies to 
develop existing biomass resources and mobilise new biomass resources for different uses.  

The Renewable Energy Road Map32 projected that around 195 million tonnes of oil equivalent 
(Mtoe) of biomass will be used in 2020 to achieve the 20% renewable energy target. A report 
by  the  European  Environment  Agency33  found  that  the  potential  for  bio-energy  from  the 
MSW  is  20  Mtoe  –  which  would  account  for  around  7%  of  all  renewable  energy  in  2020), 
assuming  that  all  wastes  which  are  currently  landfilled  would  become  available  for 

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Regulations 2092/91/EEC (until 31.12.2008) and 834/2007/EC (as from 1.1.2009). 
Decision 2006/799/EC. 
Decision 2007/64/EC. 
COM(2006) 231. 
Brussels European Council of March 2007. 
The  RES  Directive  is  currently  negotiated  under  a  co-decision  procedure  between  the  European 
Parliament and the Council. 
COM(2006) 848. 
EEA, 2006. 

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incineration with energy recovery and waste which are composted will be subject to anaerobic 
digestion first and then composted.  

4. 

ENVIRONMENTAL,  ECONOMIC  AND  SOCIAL  ISSUES  RELATED  TO  BIO-WASTE 
MANAGEMENT 

4.1. 

Environmental impacts 

Landfilling:  Biodegradable  waste  decomposes  in  landfills  to  produce  landfill  gas  and 
leachate. The landfill gas, if not captured, contributes considerably to the greenhouse effect as 
it consists mainly of methane, which is 23 times more powerful than carbon dioxide in terms 
of climate change effects in the 100-years time horizon considered by the Intergovernmental 
Panel  on  Climate  Change  (IPCC).34  Before  adoption  of  the  Landfill  Directive,  methane 
emissions from landfills accounted for 30% of the global anthropogenic emissions of methane 
into the atmosphere.35 Assuming that all countries comply with the Landfill Directive, even if 
the  total  amount  of  MSW  increases,  by  2020  the  expected  emissions  of  methane  in  CO2 
equivalents will be 10 Mt lower than in 2000.36 The leachate, if not collected in accordance 
with  the  Landfill  Directive,  can  contaminate  groundwater  and  soil.  Landfills  may  also  be  a 
source  of  nuisance  for  neighbouring  areas  as  they  generate  bio-aerosols,  odours,  and  visual 
disturbance.  Yet  another  negative  impact  of  landfilling  is  the  area  of  land  used,  which  is 
bigger  than  for  other  waste  management  methods.  There  are  hardly  any  positive  aspects  of 
landfilling  biodegradable  with  the  possible  exception  of  "storage"  capacity  for  carbon 
sequestrated in pre-treated waste37 and very limited energy production from collected landfill 
gas if landfill is carefully managed. The main negative impacts of landfilling will be reduced 
by  adhering  to  the  EU  Landfill  Directive,  but  not  eliminated.  Also,  landfilling  means 
irrecoverable  loss  of  resources  and  land,  in  the  medium  to  long  term  it  is  not  considered  a 
sustainable waste management solution and is not favoured. 

Incineration of bio-waste as a part of mixed municipal waste may be used to recover energy 
from a carbon-neutral source, providing an alternative to e.g. fossil fuels and contributing to 
climate  change.  However,  the  energy  efficiency  of  current  MSW  incinerators  varies 
considerably, depending mainly on whether an incineration plant delivers heat, electricity, or 
both  in  combined  heat  and  power  plants38  as  well  as  technology  used  (e.g.  flue  gas 
condensation  allows  to  achieve  higher  efficiency).  The  revised  Waste  Framework  Directive 
encourages a shift to highly efficient new plants. 

The  European  Commission  has  launched  a  public  consultation  about  developing  a 
sustainability scheme for biomass, where the end-use efficiency of converting biomass to heat 
and electricity is a central issue39. 

The environmental impacts of incinerating MSW containing biodegradable waste are mainly 
related to airborne emissions  from incinerators, including greenhouse gas emissions, loss of 
organic  matter  and  other  resources  contained  in  biomass.  Compliance  with  the  Waste 

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www.ipcc.ch 
COM(96) 557. 
EEA, 2007 (2) (fig. 6.24). 
AEA, 2001. 
Eunomia (2002) assumed that representative (for EU15) incinerator producing only electricity achieves 
21% energy efficiency and CHP plants generate energy at 75% efficiency. 
http://ec.europa.eu/energy/res/consultation/uses_biomass_en.htm 

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Incineration  Directive  limits  emissions  of  selected  heavy  metals  and  a  range  of  other 
emissions  including  dioxins  as  far  as  practicable  and  requires  reduction  of  any  health  risks. 
Nevertheless, some emissions will occur. There will also be some environmental burden from 
the disposal of ashes and slags, for example the flue gas cleaning residues, which often have 
to be disposed of as hazardous waste. 

The  emissions  from  MSW  incineration  are  reduced  to  the  minimum  by  the  Incineration 
Directive.  The  overall  environmental  performance  of  incineration  of  MSW,  including  bio-
waste, depends on many factors (especially fuel quality, energy efficiency of installations and 
source of replaced energy). 

Biological treatment: Composting, anaerobic digestion and mechanical-biological treatment 
also produce emissions (including greenhouse gases CH4, N2O and CO2). After stabilisation 
through  biological  treatment,  the  resulting  material  binds  short  cycle  carbon  for  a  limited 
time:  it  is  estimated  that  in  the  100-year  horizon  about  8%  of  the  organic  matter  present  in 
compost will stay as humus in the soil40. 

The use of compost and digestate as soil improvers and fertilizers offers agronomic benefits41 
such  as  improvement  of  soil  structure,  moisture  infiltration,  water-holding  capacity,  soil 
microorganisms and supply with nutrients (on average, compost from kitchen waste contains 
about 1% N, 0.7% P2O5 and 6.5% K2O). In particular the recycling of phosphorous can reduce 
the need to import mineral fertilizer while replacement of peat shall reduce damage to wetland 
eco-systems.  

Increased  water  retention  capacity  improves  workability  of  soils,  thereby  reducing  energy 
consumption when ploughing them. Better water retention (soil organic matter can absorb up 
to  20  times  its  weight  in  water)  can  help  to  counteract  the  desertification  of  European  soils 
and prevent flooding. 

Finally, the use of compost contributes to counteracting the steady loss of soil organic matter 
across temperate regions. 

Environmental impact of composting is mainly limited to some greenhouse gas emissions and 
volatile  organic  compounds.  The  impact  on  climate  change  due  carbon  sequestration  is 
limited and mostly temporary. The agricultural benefits of compost use are evident but there 
is  debate  about  their  proper  quantification  (e.g.  by  comparison  to  other  sources  of  soil 
improvers),  while  the  main  risk  is  soil  pollution  from  bad  quality  compost.  As  bio-waste 
easily  gets  contaminated  during  mixed  waste  collection,  its  use  on  soil  can  lead  to 
accumulation  of  hazardous  substances  in  soil  and  plants.  Typical  contaminants  of  compost 
include  heavy  metals  and  impurities  (e.g.  broken  glass),  but  there  is  also  a  potential  risk  of 
contamination by persistent organic substances such as PCDD/F, PCB or PAHs. 

Proper  control  of  input  material  coupled  with  the  monitoring  of  compost  quality  is  crucial. 
Only  a  few  Member  States  allow  compost  production  from  mixed  waste.  Most  require 
separate  collection  of  bio-waste,  often  in  the  form  of  a  positive  list  of  waste  which  may  be 
composted.  This  approach  limits  the  risk  and  reduces  the  cost  of  compliance  testing  by 
allowing less extensive monitoring of production and use of compost. 

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AEA, 2001, Table A5.46, p.140. 
Brussels, 2001. 

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Home  composting  is  sometimes  regarded  as  the  environmentally  most  beneficial  way  of 
handling domestic biodegradable waste, as it saves on transport emissions and costs, assures 
careful input control and increases the environmental awareness of the users. 

As  anaerobic  digestion  is  conducted  in  closed  reactors  the  emissions  to  the  air  are 
significantly lower and easier to control than from composting42. Every tonne of biowaste sent 
to biological treatment can deliver between 100-200 m3 of biogas. Due to the energy recovery 
potential  from  biogas  coupled  with  the  soil  improvement  potential  of  residues  (especially 
when treating separately collected biowaste) it may often represents the environmentally and 
economically most beneficial treatment technique43. 

As most emissions from Mechanical-Biological Treatment operations result from biological 
treatment  of  biodegradable  waste,  the  emissions  into  air  are  similar  to  composting  or  AD. 
However  the  end  product  is  usually  contaminated  to  a  level  which  hinders  its  further  use. 
Nevertheless,  these  techniques  have  the  advantage  of  purifying  the  combustible  fraction  for 
incineration with energy recovery. 

Comparison of bio-waste management options 

As  the  bio-waste  is  new  concept  in  legislation  –  most  studies  refer  to  management  of 
biodegradable waste. The difference is that bio-waste does not include paper and has higher 
moisture  content,  which  may  have  impact  especially  for  comparison  of  options  including 
thermal treatment of waste.  

For the management of biodegradable waste that is diverted from landfills, there seems to be 
no  single  environmentally  best  option.  The  environmental  balance  of  the  various  options 
available  for  the  management  of  this  waste  depends  on  a  number  of  local  factors,  inter  alia 
collection systems, waste composition and quality, climatic conditions, the potential of use of 
various  waste  derived  products  such  as  electricity,  heat,  methane-rich  gas  or  compost. 
Therefore  strategies  for  management  of  this  waste  should  be  determined  at  an  appropriate 
scale based on a structured and comprehensive approach like Life Cycle Thinking (LCT) and 
the associated tool of Life Cycle Assessment (LCA)44 to avoid overlooking relevant aspects 
and any bias. 

The  situation  is  of  course  dependant  on  the  varying  conditions  in  the  countries.  A  range  of 
Life  Cycle  Assessment  (LCA)  based  studies  have  been  conducted  on  national  and  regional 
scales45.  Also  recently,  on  behalf  of  the  Commission,  Life  Cycle  Assessments  for  MSW 
management in new member states have been conducted46. 

Whilst  arriving  at  different  results  depending  on  local  conditions,  they  largely  show  the 
common  pattern  that  the  benefits  of  the  chosen  waste  management  system  for  biowaste 
significantly depend on: 

•  The amount of  energy that can be recovered - is a crucial  parameter, giving  high  energy 
efficient options a clear advantage. E.g. incineration may be justified in Denmark47 while 

42 
43 
44 
45 
46 
47 

Vito, 2007. 
JRC, 2007. 
See: http://lca.jrc.ec.europa.eu/waste/. 
JRC, 2007 and JRC, 2009. 
JRC, 2007. 
Copenhagen, 2007. 

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combined anaerobic digestion with composting of the digestate performs environmentally 
better  than  incineration  with  energy  recovery  in  Malta48.  It  is  due  to  better  energy 
utilisation of wet biodegradable wastes by anaerobic digestion than by incineration. 

•  The source of the energy which is replaced by the recovered energy - if the replaced energy 
is  mainly  based  on  fossil  fuels,  the  benefits  of  a  high  energy  recovery  of  the  biowaste 
system become more important. However, if the replaced energy is largely based on low 
emission  sources,  e.g.  hydro  energy,  energy  recovered  from  biowaste  is  obviously 
associated with significantly less environmental benefits.  

•  The amount, quality and use of the recycled compost and the products which are replaced 
by  using  compost  -  If  the  compost  is  used  in  landscaping  or  landfill  cover  any 
environmental benefits will be very limited. However, if high quality compost is replacing 
industrial fertilizers, the benefits usually will be significant49. Also the replacement of peat 
yields high environmental benefits. 

•  The  emission  profile  of  biological  treatment  plants  -  plants  can  have  very  different 
emission  patterns  which  lead  to  more  or  less  environmental  impacts.  The  studies  show 
especially importance of emissions of N2O and NH3

50

. 

The  Commission  is  currently  working  on  developing  guidelines  on  the  use  of  life-cycle 
thinking in biodegradable waste management51. 

4.2. 

Economic impacts 

The  capital  and  operating  costs  of  MSW  management  and  biological  treatment  of  waste 
depend  on  multiple  factors  and  vary  regionally  and  locally,  hence  it  is  difficult  to  arrive  at 
meaningful average values or make comparisons. The most important variables for such costs 
include the plant's size, technology used, geological conditions (for landfills), costs of locally 
available  energy,  type  of  waste  available,  transport  costs  and  others.  This  excludes  indirect 
costs on the environment and health. 

Landfilling is usually considered the cheapest option, especially if the price of land is low, or 
where the environmental costs of landfilling and future costs of landfill closure and aftercare 
have  not  yet  been  internalised  in  the  gate  fee  (especially  in  the  new  Member  States).  The 
increase  of  costs  due  to  the  Landfill  Directive  will  possibly  change  this  situation  combined 
with rising awareness of the “real” long term costs of landfills. Equally, revenues from energy 
recovery and products can at least partly offset the costs of other management options. These 
then  can  even  come  close  to  break  even,  making  them  economically  more  interesting  than 
landfilling. 

Incineration requires  higher investment but can offer good economies of scale and does not 
require changes to existing MSW collection schemes for landfilling, while brining in revenues 
from  energy  recovery  especially  when  the  efficiency  is  maximised  by  using  waste  in  high 
efficiency cogeneration units for the production of both electricity and heat. 

48 
49 
50 
51 

JRC, 2007. 
Heidelberg, 2002. 
JRC, 2007. 
http://viso.jrc.ec.europa.eu/lca-biowaste and http://lca.jrc.ec.europa.eu/waste/  

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With  a  diverse  range  of  biological  treatment  technologies,  it  is  more  difficult  to  provide  a 
single  cost  for  such  treatment  and  this  will  also  depend  on  the  market  for  the  products.  As 
biological treatment must be applied to waste of sufficient quality to deliver safe compost, the 
costs  of  separate  collection  of  bio-waste  must  be  added  to  the  treatment  process.  Selling 
compost may be a source of additional revenues and again, energy recovery using anaerobic 
digestion can provide further revenues. 

In  the  study  for  European  Commission52  the  following  financial  cost  estimates  of 
management of biowaste were proposed as assumptions representative for the EU-15 (2002): 

–  Separate collection of bio-waste followed by composting: 35 to 75 €/tonne; 

–  Separate collection of bio-waste followed by anaerobic digestion: 80 to125 €/tonne; 

–  Landfill of mixed waste: 55 €/tonne; 

–  Incineration of mixed waste: 90 €/tonne. 

Eunomia  estimates  the  additional  costs  of  separate  collection  at  0-15  €/tonne,  while 
optimisation of the separate collection systems (e.g. by increasing periods between collection 
of  non-biodegradable  waste)  could  decrease  these  costs  below  zero  making  collection 
profitable. On the other hand, COWI (2004) gives examples of much higher costs of separate 
collection of 37-135 €/tonne and es timates it possible to achieve net benefits of separate bio-
waste  collection,  even  if  small  and  depending  on  a  number  of  factors  (cost  of  separate 
collection, energy efficiency of an alternative incinerator, type of energy displaced by energy 
from the alternative incinerator). 

Investment costs of biological treatment plants vary, depending on the type of installation, the 
emission  reduction  techniques  used,  and  the  product  quality  requirements.  Study  supporting 
the  Impact  Assessment  for  the  revision  of  IPPC  directive  quotes  60-150  €/tonne  for  open 
composting  and  350-500  €/tonne  for  closed  co mposting  and  digestion  in  large-scale 
installations53. 

Market  prices  for  compost  are  closely  linked  to  the  public  perception  and  customer 
confidence in a product. Usually, compost for use in agriculture is sold for a symbolic price 
(e.g. 1 €/tonne, the price may even include tran sport and spreading). However, well marketed 
compost  of  recognised  quality  may  reach  14  €/tonne,  while  for  small  amounts  of  packed 
compost or blends including compost the price may even reach 150-300 €/tonne. The prices 
are higher at well developed compost markets (see Chapter 3.2). 

Due  to  high  transport  prices  and  low  market  value,  compost  is  usually  used  close  to  the 
composting  site  and  presently  long-distance  transport  and  international  trade  are  limited 
which limits impact from the Internal Market on the competitiveness of this product. 

There  is  no  problem  with  the  market  for  biogas  or  landfill  gas.  It  can  be  burnt  on  site  to 
generate  heat  and/or  electricity  or  cleaned  and  upgraded  to  reach  the  quality  of  automotive 
fuel  or  natural  gas  pumped  into  the  grid.  These  uses  would  maximise  the  potential  of 

52 
53 

Eunomia, 2002. 
Vito, 2007. 

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anaerobic digestion for reducing GHG emissions, helping to achieve both the Kyoto and the 
RES Directive's targets. 

Separate  collection  schemes  can  help  in  diverting  biodegradable  waste  from  landfills, 
providing  quality  input  to  bio-waste  recycling  and  improving  the  efficiency  of  energy 
recovery.  However,  setting  up  separate  collection  schemes  is  not  without  challenges, 
including: 

•  The  need  to  re-design  waste  collection  systems  and  change  of  citizens'  habits.  While 
properly  designed  separate  collection  systems  are  not  necessarily  more  expensive54,  their 
proper design and management require higher effort than mixed waste collection systems. 

•  Difficulties in identifying areas suitable for separate collection. In densely populated areas 
it is problematic to guarantee the necessary purity of the input. In scarcely populated areas 
separate collection may be too expensive and home composting may be a better solution. 

•  Problems of matching the waste arising with the use of recycled material – due to transport 
costs and low prices the use of compost is often confined to locations near the treatment 
plant. This may pose problems in densely populated areas. 

•  Hygiene and odour issues – especially in warm and hot climate. 

4.3. 

Social and health impacts 

Increased recycling of bio-waste is expected to have limited positive impacts on employment. 
New  jobs  may  be  created  in  waste  collection  and  in  small  composting  plants.  Separate 
collection  of  bio-waste  may  be  three  times  more  labour-intensive  than  collecting  mixed 
waste55. It is also likely that inhabitants of areas covered by separate collection will have to 
change their waste separation habits; however, there are no data for assessing the societal cost 
of separate collection. 

There  is  a  general  lack  of  quality  data  on  the  health  impacts  of  various  waste  management 
options  based  on  epidemiologic  studies.  A  study  by  DEFRA56  did  not  reveal  any  apparent 
health effects for people living near MSW management facilities. Further to this study, in the 
future additional research could be required to ascertain the absence of risks to human health 
from such facilities. However, it identified small risks of birth defects in families living near 
landfill sites and of bronchitis and minor ailments for residents living nearby (especially open) 
composting  plants  though.  No  apparent  health  effects  have  been  identified  for  incineration 
plants. 

54 

55 
56 

Optimized separate collection systems may substantially reduce the frequency of collection of residual 
waste, also savings on disposal may be considerable. See e.g. Favoino, 2002. 
Eunomia cited by COWI, 2004. 
DEFRA, 2004. 

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5. 

ISSUES FOR DISCUSSION 

5.1. 

Better prevention of waste 

The  amount  of  bio-waste,  although  stabilized  in  recent  years,  has  the  potential  to  increase 
(especially in  EU12)57. This may necessitate  the strengthening  of  waste  prevention  policies. 
UK research58 estimates that 6.7 million tonnes of food are wasted by households each year in 
the UK alone. Prevention of this waste could save at least 15 million tonnes of CO2 equivalent 
emissions each year from disposal. 

There are no easy administrative solutions however, as possible actions are generally linked to 
changing  consumer  behaviour  and  retail  policies.  Under  the  revised  WFD,  Member  States 
will  have  to  draw  national  prevention  programmes,  which  will  also  address  this  issue. 
Moreover, the implementation of SCP/SIP Action Plan will also contribute to this objective59. 

Question  1:  Waste  prevention  is  at  the  top  of  the  EU's  waste  treatment  hierarchy.  From 
your experience, what could be specific bio-waste prevention action at EU level? 

5.2. 

Limiting landfilling 

As  discussed  in  Sections  3  and  4,  landfilling  of  bio-waste  is  in  general  the  least  desirable 
waste management solution and should be minimized. Still, in many Member States increased 
implementation  efforts  and  additional  enforcement  measures  may  be  necessary  for  many 
years to fully implement the Landfill Directive. 

It  could  therefore  be  useful  to  evaluate  whether  strengthening  the  current  regulatory 
framework would bring additional environmental benefits. This could involve further action 
at  EU  level  on  the  enforcement  of  the  current  provisions  or,  if  necessary,  strengthening  the 
Directive.  Equally,  greater  awareness  of  the  alternatives  and  the  associated  revenues  could 
promote a shift, especially if changes in infrastructure are financially supported. 

Question  2:  Do  you  see  benefits  or  disadvantages  of  further  restricting  the  amount  of 
biodegradable  waste  that  is  allowed  on  landfills  beyond  the  targets  already  set  in  the  EU 
Landfill  Directive?  If  yes,  should  this  be  done  on  EU  level  or  left  to  decide  by  Member 
States? 

5.3. 

Treatment options for biowaste diverted from landfill 

Once diverted from landfills, bio-waste can go through several treatment options as described 
in Sections 3 and 4. It is difficult to decide on the one single environmentally most beneficial 
bio-waste management option under all circumstances due to a large number of variables and 
local  considerations  that  need  to  be  taken  into  account.  Management  of  diverted  bio-waste 
should be addressed by additional measures supporting a move from simple pre-treatment for 
landfill and incineration with little or no energy recovery into incineration with high energy 
recovery, anaerobic digestion with biogas production and recycling of bio-waste. In addition 
to assessments to highlight the benefits, it could be further strengthened with targets for the 
maximum allowed amount of residual waste for disposal (landfilling or incineration without 

57 
58 
59 

EEA CSI-16. 
WRAP, 2008. 
COM(2008) 397. 

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energy  recovery)  or  other  measures  in  order  to  direct  more  bio-waste  towards  material  and 
energy recovery. 

Question 3: Which options for the treatment of bio-waste diverted from landfills would you 
prefer  to  see  strengthened  and  what  would  you  see  as  their  main  benefits?  Do  you  think 
that the choice of the treatment of bio-waste diverted from landfills should benefit from a 
wider and more consistent use of life-cycle assessment studies? 

5.4. 

Improving energy recovery 

To help reach renewable energy targets, energy recovery could be significantly enhanced by 
developments  in  the  area  of  anaerobic  digestion  for  production  of  biogas  and  by  improving 
the efficiency of waste incineration, for example by using cogeneration of electricity and heat. 

Every  tonne  of  bio-waste  sent  to  biological  treatment  can  deliver  between  100-200  m3  of 
biogas which could be upgraded to natural gas standards using 3-6% of its energy. Anaerobic 
digestion  of  mixed  waste  brings  similar  energy  gains  but  makes  further  use  of  residues  on 
land difficult. 

Most  of  the  energy  gained  via  incineration  of  MSW  results  from  burning  highly  calorific 
fractions  such  as  paper,  plastics,  tyres,  and  synthetic  textiles  while  the  "wet  fraction"  of 
biodegradable waste reduces overall energy efficiency60. However, the biodegradable fraction 
of municipal waste (but including paper) still delivers about 50% of energy coming from an 
incineration  plant  and  increased  recycling  of  bio-waste  could  limit  the  amount  of  bio-waste 
available for incineration. 

Question  4:  Do  you  think  that  energy  recovery  from  bio-waste  can  make  a  valuable 
contribution  to  sustainable  resource  and  waste  management  in  the  EU  and  meeting  the 
EU's renewable energy targets in a sustainable way and, if so, under which conditions? 

5.5. 

Increasing recycling 

As discussed in chapter 4 the recycling of bio-waste (e.g. compost being used on soil and for 
the  production  of  growing  media)  can  result  in  some  environmental  benefits,  notably  with 
regards to the improvement of carbon-depleted soils. In addition to assessments, new action to 
strengthen  the  recycling  of  bio-waste  could  therefore  comprise  three  inter-related  issues: 
recycling targets, rules for the quality and use of compost and supporting action in the shape 
of separate collection. 

5.5.1.  Common bio-waste recycling targets 

In principle, such targets could be introduced either in separate bio-waste legislation or in the 
2014  review  of  the  recycling  targets  in  the  Waste  Framework  Directive.  Due  to  differences 
between  the  Member  States  concerning  demand  for  compost  and  energy,  waste  generation, 
population  density,  etc.  it  may  be  difficult  or  inappropriate  to  set  a  "one-size-fits-all"  target 
while  avoiding  adverse  environmental,  economic  and  administrative  effects  and  it  might  be 
necessary to leave room for national flexibility to identify the best waste management option 
for each situation. 

60 

AEA, 2001, Tables A3.36 and A3.37, p. 118. 

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5.5.2.  National bio-waste recycling targets 

This option would be a variant of a general bio-waste recycling target set at Community level. 
Member  States  would  be  allowed  to  propose  their  national  targets  at  the  optimum  level  for 
each country taking into account the waste management hierarchy and Life Cycle Thinking. . 
Such targets would act as drivers for the national stakeholders and set clear lines for national 
and regional bio-waste policies. There would however be a risk that targets are set at a low 
level of ambition. The possibility of setting national targets in EU legislation would also be 
reviewed. 

5.5.3. 

Separate collection obligation  

Strengthening the supply of “clean” bio-waste could encourage investment in composting and 
biogas facilities. It would require organising national, regional or local separate collection of 
(selected)  bio-waste  possibly  accompanied  by  targets  for  measuring  progress  requiring  new 
reporting  and  enforcement  obligations  for  waste  managers  and  authorities,  and  thus  create 
additional costs and administrative burdens for enterprises and public administrations, which 
should be considered in balance with environmental benefits. 

Question 5: Do you see a need for promoting bio-waste recycling (i.e. compost production 
or  use  on  land  of  composted  material)  and,  if  so,  how  ?  How  can  synergies  be  achieved 
between bio-waste recycling and energy recovery? Please provide the necessary evidence.  

5.6. 

Contributing to Soil Improvement 

As shown in detail in Section 4, bio-waste management could improve EU soils by delivering 
safe compost although the overall potential is limited (even a maximum increase of recycling 
of  bio-waste  across  the  EU  could  supply  no  more  than  3.2%  of  agricultural  land). 
Nevertheless,  to  avoid  the  risk  of  soil  pollution  and  strengthen  user  confidence,  it  could  be 
necessary to introduce common standards on bio-waste treatment and compost quality. 

5.6.1.  EU Standards for high-quality compost 

Setting  common  EU  standards  would  clarify  when  material  produced  from  bio-waste  has 
completed  the  recovery  process  and  can  be  regarded  as  a  product  rather  than  waste  thus 
strengthening  environmental  and  health  protection  and  improving  the  market  by  increasing 
user confidence and facilitating cross-border trade. There are plans to set such standards in the 
near future under the Waste Framework Directive ("end-of-waste criteria"). 

5.6.2.  EU Standards for treated bio-waste of lower quality 

Common  EU  rules  could  also  be  set  for  the  use  of  treated  bio-waste,  such  as  low  quality 
compost, which would remain subject to waste  legislation, similarly to the requirements for 
spreading  sewage  sludge  on  agricultural  land.  Such  rules  could  include  quality  criteria  and 
total  allowable  load  of  heavy  metals  and  other  pollutants  in  compost  and  soil.  "Waste 
composts" could be further sub-divided according to their potential application. "Compost" of 
even lower quality would have to be disposed of. 

5.6.3.  Rules set at national level 

As  an  alternative  to  EU  common  rules  it  could  be  required  that  Member  States  set  national 
rules within a common framework, allowing them to adapt detailed rules in line with regional 

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or local considerations on environmental and health protection, and soil management choices. 
The  downside  of  this  approach  would  be  continued  uncertainty  on  the  internal  market,  its 
likely fragmentation, complications for shipments, and administrative burden for operators. It 
could also jeopardise the  realisation  of  the  agreed  policy goal of stronger  recycling  markets 
for a European Recycling Society. 

Question 6: In order to strengthen the use of compost/digestate: 

–  Should  quality  standards  be  set  for  compost  as  a  product  only  or  also  for  compost  of 
lower  quality  still  covered  by  the  waste  regime  (e.g.  for  applications  not  linked  to  food 
production)? 

–  Should  rules  for  the  use  of  compost/digestate (e.g.  limits  on  pollutant  concentration  in 

compost/digestate and land on which compost/digestate is applied) be set ? 

–  Which pollutants and concentrations should these standards be based on? 

–  What are the arguments for/against the use of compost (digestate) from mixed waste? 

5.6.4.  Operational (treatment) standards for small plants 

Plants treating over 50 tonnes of bio-waste per day (most composting and digestion capacity) 
would  be  covered  by  the  revised  IPPC  Directive.  Covering  plants  treating  below  50  tonnes 
was  found  disproportionate61.  The  relevant  BAT  Reference  Document62  covers  anaerobic 
digestion and mechanical biological treatment, but not composting. 

It will have to be decided whether composting plants which do not fall under the Animal By-
Products Regulation should have to meet certain sanitation and monitoring requirements as a 
benchmark for licensing and to guarantee that compost used on land is safe. 

Question 7: Is there any evidence of gaps in the existing regulatory framework concerning 
the operational standards for plants which do not fall under the IPPC scope and if so, how 
should this be addressed?  

5.7. 

Other uses of bio-waste 

Many  planned  and  ongoing  research  activities  aim  at  developing  alternative  means  of 
exploiting residual biomass and bio-waste to address the climate change issue and soil quality 
deterioration.  Further  bio-waste  treatment  options  are  being  explored  at  research  level  (e.g. 
biochar)63. 

Question 8: What are the advantages and disadvantages of the abovementioned bio-waste 
the  further 
techniques?  Do  you  see  regulatory  obstacle  preventing 
management 
developments and introduction of these techniques? 

61 
62 
63 

Impact Assessment on the Proposal of Directive on Industrial Emission. 
BREF Waste Treatment. 
E.g. Fowles, 2007 and Lehmann, 2007. 

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Contributions  to  this  consultation  process  should  be  sent  to  the  Commission  by  15  March 
2009, by email to the address “ENV-BIOWASTE@ec.europa.eu”, or by post to the following 
address: 

European Commission 

Directorate-general Environment 

Unit G.4 “Sustainable production and consumption” 

B-1049 Brussels 

This Green Paper will be published on the Commission’s website. The received contributions 
will be published, unless the author objects to publication of the personal data on the grounds 
that such publication would harm his or her legitimate interests. In this case the contribution 
may be published in anonymous form. Otherwise the contribution will not be published nor 
will, in principle, its content be taken into account. 

Furthermore,  since  the  launch  in  June  2008  of  the  Register  for  Interest  Representatives 
(lobbyists)  as  part  of  the  European  Transparency  Initiative,  organisations  are  invited  to  use 
this Register to provide the Commission and the public at large with information about their 
objectives,  funding  and  structures64.  It  is  Commission  policy  that  submissions  will  be 
considered as individual contributions, unless organisations register65. 

In late 2009, the Commission intends to present its analysis of the responses received together 
with, if appropriate, its proposals and/or initiatives for an EU strategy on the management of 
bio-waste. 

64 
65 

www.ec.europa.eu/transparency/regrin 
COM(2007)127. 

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