Waste, end-of-waste or by-product
A considerable proportion of drinking water production residuals is of reliable quality and can be directly used as an alternative to all kinds of primary raw materials. These residuals – specifically, lime pellets, aquafer and part of the (iron) lime sludge – are not waste materials but are sold as by-products. The remaining residuals – as well as the lime pellets and aquafer that don’t meet requirements – are for their part disposed of as waste materials. AquaMinerals has a good grasp of the quality of the different residuals, as a function of their production location and origin.
AquaMinerals also trades in struvite (magnesium ammonium phosphate) that is recovered in wastewater treatment processes. Struvite has an ‘end-of-waste’ status under the European Waste Framework Directive. For more information see struvite.
(By-) product status
In order to deal in residuals as by-products, they must first satisfy the criteria of article 5 of the European Waste Framework Directive (2008/98/EC). These criteria have been incorporated into Dutch legislation in the Environmental Management Act.
The criteria include the requirement that there be an assured market for the product, that the application fulfil all regulatory requirements for products, and environmental and human health protection, and that there be no adverse environmental or human health impacts. AquaMinerals makes sure that the products’ applications meet the relevant requirements.
Waste products can be freed of their waste status if they fulfil the criteria of article 6 of the European Waste Framework Directive (2008/98/EC). The criteria establish similar requirements as those applied to by-products.
See also Rijkswaterstaat’s RWS Leefomgeving website (in Dutch) on the ‘afval of niet’ question.
REACH, the European chemicals regulation, is an important regulatory scheme which establishes criteria with which by-products and end-of-waste products must comply. Moreover, depending on the application, other specific regulations apply, such as those under the Fertiliser Law, to by-products that are traded as fertilisers.