1. Regulatory barriers for the circular economy
Case study: Nutrient recovery and manure derived products
Author/presenter: Joost van Barneveld, Technopolis Group

2. Overview Manure production: 1381 Mton Processed 110 Mton
N content Mton
P content Mton
Joost (Technopolis) will finalise schemes in more professional style if he receives them by Friday noon (11 March)

3. Detailed overview

4. Regulatory barriers
Fertiliser Regulation covers only inorganic fertilisers
Nitrates directive does recognise qualities of manure derived products
WFD classifiers AD as recovery, can be considered recycling
No End-of-Waste criteria for manure
REACH imposes costs on manure derived products
Animal By-Products Regulation hinders internal market

5. Effects of regulatory barrier
Economic effects:
The market for manure derived products is seriously hindered; only 8% of manure is processed in some way
ABPR and WFD classifications drive demand for small-scale installations to circumvent trade and transport
Value contained in manure as fertiliser over €11b.
Each percent of nutrients wasted amounts to ±€100 m
Manure treatment is labour intensive  expensive but generates local employment
Environmental effects
Processing manure significantly reduces emissions of GHG and nutrients to the environment
Nitrogen destruction associated with <=70 kg CO2 / kg N2

6. Observations on removal of regulatory barrier
Manure derived products can still be pathogenic; ABPR needs to find a delicate balance
Behaviour of manure-derived products in soil not fully known; difficult to set the right targets in the Nitrates Directive
Processing manure with other bio-waste complicates waste stream, implications for EoW criteria and REACH
Fertiliser Regulation is very specific on composition of inorganic fertilisers; the required level of certainty may not be achievable for organic fertilisers or manure derived products