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Miljø- og Planlægningsudvalget 2008-09
KOM (2008) 0811 Bilag 3
Offentligt

J.nr.

Ref.

March 10 2009

Consultation response by the Danish Government to the European

Commission Green Paper on the management of bio-waste in the Eu-

ropean Union

Denmark welcomes the Commission’s Green Paper. Denmark agrees with

the Commission’s view that due to differences between the Member States,

it may be difficult or not very appropriate to set common bio-waste recycling

targets while also avoiding adverse environmental, economic and adminis-

trative effects.

Consequently Denmark finds it necessary that sufficient flexibility is ensured

to allow Member States to choose the best way to manage bio-waste either

by prevention, recycling or incineration with energy recovery.

It is of great importance to Denmark that the current high Danish level of

protection of the environment, including groundwater and soil, as well as

health can be maintained, and consequently Denmark proposes that only

minimum requirements for compost and its use are established at the EU

level, so that Denmark is able to set more stringent requirements necessary

to maintain the current level of protection.

Denmark calls on the Commission to incorporate occupational health and

safety issues in the social and health impact assessment, as there is a gen-

eral lack of solid data based on epidemiological studies of the health and

safety effects of the various waste management solutions

Denmark also calls on the Commission to take initiatives on joint European

approaches to waste prevention, where joint European efforts are appropri-

ate. Additionally Denmark calls on the Commission to incorporate bio-waste

in its work on creating a system for sharing information on best practise re-

garding waste prevention and in developing guidelines in order to assist the

Member States in preparation of prevention programmes in accordance with

article 29, paragraph 5 of the Waste Framework Directive.

Furthermore Denmark calls on the Commission to increase its focus on the

development of new bio-waste treatment technologies.

Finally Denmark takes the position that the limit on the amount of biode-

gradable waste that is allowed on landfills could advantageously be lowered

at EU level.

Ministry of the Environment • Højbro Plads 4 • DK-1200 København K Denmark

Tel +45 72 54 60 00 • Fax +45 33 32 22 27 • CVR 12854358 • EAN 5798000862005 • [email protected] • www.mim.dk

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Please find below the Danish positions on the specific subjects raised by

the Commission in the Green Paper.

Subject 1: Better Waste prevention

In Denmark there have previously been campaigns encouraging house-

holds to compost garden waste and the vegetable part of food waste. By so

doing waste collection is minimized and treatment and the resources in the

waste are utilized in the garden. The decision on home composting or simi-

lar initiatives should be taken at Member States level and not at the EU lev-

el.

An effort for waste prevention should to be focused on those areas where

the greatest benefits can be achieved. For this purpose knowledge of con-

sumers’, industry’s and retailers management and use of food is necessary.

Several Member States have conducted a range of studies, most recently

the UK study on the amount of food wasted in the households.

Denmark would encourage the Commission to take the lead in collecting

existing knowledge from Member States, and to identify, on the basis of this

knowledge, those areas that would benefit the most from concrete initia-

tives. This could be dealt with in connection with carrying out the new Waste

Framework Directive’s article 29 (5), according to which the Commission

must provide a system for exchanging information on best practice regard-

ing waste prevention and prepare guidelines to assist Member States in

creating the programs.

In addition, Denmark calls on the Commission to initiate initiatives on joint

European approaches to waste prevention, where a joint European effort is

appropriate. This could be in the area of packaging of foods.

Subject 2: Further restrictions on the amount of biodegradable waste

that is allowed on landfills

Denmark has worked actively, for many years, on reducing the amount of

biodegradable waste sent to landfill facilities, and since 1997 it has not been

permitted to landfill biodegradable waste, which can be recycled or inciner-

ated.

The Danish position is that, with considerations of both safety; environment

and climate, the limit on the amount of biodegradable waste that is permit-

ted on landfills could advantageously be lowered at EU level.

Subject 3: Options for treatment of bio-waste diverted from landfills

The choice of bio-waste treatment should be made on the basis of the

waste hierarchy and the option should exist to depart from the hierarchy in

those cases where it can be justified by life-cycle thinking concerning the

overall impacts of the generation and management of the specific type of

waste.

In Denmark more than 90 percent of garden and park waste is composted.

More than 90 percent of organic waste from industry (with the exception of

animal waste and food waste from industrial kitchens) is recycled either by

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substituting raw materials, through anaerobic digestion of bio-waste, or as

fertilizer for agricultural purposes. Retail bio-waste is collected separately in

some cases but is also collected as mixed waste and incinerated with ener-

gy recovery. The allocation of the retail bio-waste between the mixed waste

and the separately collected is not available, as the fraction of bio-waste in

the mixed waste is not known.

In Denmark separate collection of bio-waste from industrial kitchens to use

as animal feed was previously a requirement. This requirement was aban-

doned in 2002 due to the EC Regulation 1774/2002 laying down health

rules concerning animal by-products not intended for human consumption

(the by-product regulation) and subsequently the recycling rate has

dropped. Today bio-waste can be anaerobically digested in accordance with

the provisions in the by-product regulation or it can be incinerated with en-

ergy recovery along with household waste. The allocation between the two

treatment methods is not available, as the fraction that is incinerated along

with household waste is not known. Animal waste is collected separately

and treated in accordance with the rules concerning by-products.

In Denmark it has been assessed whether it is most appropriate from an

economical and environmental point of view to collect source separated bio-

waste for composting or anaerobic digestion rather than incinerate the bio-

waste as a mixed waste from the households at dedicated incineration facili-

ties. The assessment showed that compared to the current practice at Dan-

ish incineration facilities it is not appropriate from an economical and envi-

ronmental point of view, to carry out separate collection and biological

treatment of the bio-waste. (The resulting report 814/2003 is enclosed).

There may be local circumstances, however, that could alter that conclu-

sion. For that reason the decision on whether bio-waste should be collected

separately is delegated to Danish municipalities. The allocation between the

two treatment methods is not available, as the fraction that is incinerated

along with household waste is not known.

Subject 4: Improved energy recovery from bio-waste

Denmark is considering bio-waste to be an increasingly important source of

renewable energy. It can contribute significantly and cost-effectively to ful-

filling the EU targets replacing fossil fuels and reducing green house gas

emissions. Denmark calls on the Commission to put more emphasis on the

ways to incorporate bio-waste in the energy supply systems giving high pri-

ority to maximising energy efficiency.

In Denmark a significant fraction of the bio-waste from households is incin-

erated in Danish waste incineration facilities, which deliver electricity and

heat to the electricity and heat grids. If the waste is incinerated at efficient

facilities, which produce both electricity and heat, it can thus contribute to

meet the EU’s renewable energy targets.

The fraction of the organic household that is anaerobically digested also

contributes to meeting the EU's renewable energy targets as the biogas is

utilised for energy purposes. As the majority of the digestate is recycled for

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agricultural use the anaerobic digestion in-directly contributes to energy

savings, as the energy use for production of fertilizer is avoided.

Subject 5: Improved recycling of biowaste

It is deemed that in Denmark today there is a relatively high degree of recy-

cling of the total amount of bio-waste; cf. the remarks to subject 3.

Denmark agrees with the Commission’s view that, due to the differences

between the Member States, it may be difficult or inappropriate to set a

"one-size-fits-all" target for recycling while avoiding adverse environmental,

economic and administrative effects. Consequently Denmark considers it

necessary to leave room for national flexibility to identify the best waste

management option for each situation.

Subject 6: Strengthening the use of compost/digestate:

Environmental protection of soil and groundwater has a high priority in

Denmark since the majority of Danish drinking water is based on groundwa-

ter treated very simply by oxidation and filtration. The soil needs protection

in consideration of groundwater and human health. Furthermore it can be

added that the background level for heavy metals in Danish soils is lower

than in many other Member States. Consequently Denmark has imposed

strict requirements regarding the use of sludge, compost and the like for

agricultural purposes to ensure that no pollution of soil and groundwater

with undesired substances takes place.

Therefore it is of the great importance for Denmark to be able to maintain its

high level of protection of soil and groundwater and consequently Denmark

propose that only minimum requirements should be established for compost

and its use in EU.

In Denmark the application of compost is regulated by the Executive Order

on the Application of Waste for Agricultural Purposes which establishes limit

values for heavy metals and xenobiotic substances, sanitary restrictions on

applications of waste and restriction for total supply of nutrients. Further-

more, limit values for heavy metals in soil are established. The Executive

Order is enclosed.

Denmark is not in favour of setting EU standards for pollutants and concen-

trations, but prefers minimum requirements. That could be minimum re-

quirements for microbiological parameters, xenobiotic substances such as

DEHP and NPE and heavy metals such as cadmium, copper, zinc, mercury

and lead. The concentration limit value should be based on an environmen-

tal and health assessment and it should be possible for Member States to

set up more stringent requirements according to national considerations

where it is deemed necessary.

Regarding the use of compost (digestate) from mixed waste it is the overall

Danish position that only source separated bio waste should be recycled.

Denmark has previously considered it difficult to achieve a high quality of

compost, due to impurities in the waste, unless a source separation had

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been carried out. Denmark does not exclude the possibility that recent ef-

forts to remove unwanted substances and materials from the waste (due to

the producers’ responsibility for batteries and WEEE, for example) have

increased the quality of compost from mixed waste. It is the Danish opinion

that if the Danish requirement of source-separation is to be deviated from, it

should be reviewed whether compost from mixed waste can achieve the

same quality as compost from source-separated bio-waste.

Subject 7: Operational standards for small plants which do not fall un-

der the IPPC

In Denmark Environmental permit is required for composting facilities that

receive 100 tonnes per year or more. The requirement for environmental

permit for anaerobic digestion facilities in Denmark is 30 tonnes per day or

more.

The application of compost/digestate for agricultural purposes in Denmark is

regulated by the Executive Order on the Application of Waste for Agricultur-

al Purposes and in this order sanitary requirements prior to application are

established.

Subject 8: Further development of bio-waste management techniques

Denmark considers it to be important that funding for research and devel-

opment of new treatment technologies for bio-wastes are established and

Denmark finds that existing as well as future treatment technologies should

be assessed on the basis of life cycle thinking.

Denmark has carried out a cost-benefit analysis of increased recycling of

source separated organic household waste based on a life cycle assess-

ment (LCA). The resulting report 822/2003 is enclosed

Further remarks

Denmark considers that it is not evident from the definition of bio-waste

whether organic waste from industry, including animal waste, is covered,

since the meaning of the term “comparable” is unclear. (The Waste Di-

rective defines ‘bio-waste’ as: “biodegradable garden and park waste, food

and kitchen waste from households, restaurants, caterers and retail premis-

es and comparable waste from food processing plants”).

Denmark calls on the Commission to commit itself to consider whether

waste from slaughterhouses, for example, is covered by the definition.

./.