Are the residuals of drinking water production and the resources recovered from wastewater waste or raw materials? Thanks to the ‘Waste or product’ guideline, things have been made clearer for companies and regulators.
Because distinguishing between what is a product and what is waste is pretty difficult, we still occasionally have discussions with regulators in which someone might for instance say: ‘What you do, for example, using lime pellets in glass, concrete or carpets, is recycling. And recycling is the recycling of waste.’ Sounds logical, but it’s not quite right. Waste is ‘any substance or object which the holder discards or intends or is required to discard’. That is certainly not the case when it comes to our lime pellets, aquafer and struvite. On the contrary. They are used in attractive high-value applications, which require a product status. Lime pellets and aquafer satisfy the criteria of a by-product. A by-product is generated in a production process which, in the first instance, is intended to produce another item. The conditions for by-product status attribution include the certainty that the by-product will be used, and that this entails no adverse human or environmental impacts.
Thanks to the new guideline, from now on we’ll all be talking about the same thing, which makes us pretty happy.
The ‘Afvalstof of product?’ (‘Waste or product’) guideline of the Ministry of Infrastructure and Water Management clarifies the concepts of ‘waste’, ‘by-product’ and ‘end-of-waste’ status: https://lap3.nl/publish/pages/138148/ienw_leidraad_afvalstof_of_product_jul2018.pdf