Legal rulings confirm that struvite is not a waste material
The Water Authorities recover phosphorus from wastewater in the form of struvite. AquaMinerals markets this struvite for the Water Authorities as a raw material for (artificial) fertilisers. Up until now, this has been quite difficult because of the absence of any government statement to the effect that this struvite was not a waste material. It has taken years to get this confirmation. Now that it has been received, it represents an important milestone, including for other recovered materials. The Water Authorities already recover 18 materials from wastewater, and many of them require an end-of-waste status in order to be placed on the market.
A material that is recovered from wastewater will be stamped as ‘waste’ until it has been demonstrated that it meets the end-of-waste criteria from the Waste Framework Directive. This can be done either through a self-assessment, a legal ruling, or an end-of-waste regulation. As early as 2015, the Water Authorities asked the Ministry of Infrastructure and Water Management for an end-of-waste regulation for materials recovered from wastewater. That was one bridge too far. A procedure for a ‘legal ruling’ was therefor initiated for a specific example, namely: the delivery of struvite to the artificial fertiliser producer ICL from the Amsterdam West wastewater treatment plant (WWTP) of the Amstel, Gooi and Vecht Water Authority.
The assessment of Rijkswaterstaat (Dutch Directorate for Public Works and Water Management) indicated that follow-up research was needed into pathogens and pharmaceutical residues. There was as yet no standard framework and approach for an assessment of this kind. RIVM (National Institute for Public Health and the Environment) needed first to develop them in interaction with the sector to enable the conduct of the safety research. This required lots of time. The entire process took almost six years. The safety research was carried out by AquaMinerals and Waternet [see ‘End-of-Waste Research: Struvite’ under downloads (in Dutch)].
On this basis, legal rulings were issued for the Amsterdam West WWTP and the WWTPs of the Vallei and Veluwe, and the Aa and Maas Water Authorities, which were also included in the safety research. There are no rulings for other WWTPs and other buyers, but we can naturally refer to the legal rulings already issued. The Ministry of Infrastructure and Water Management is currently working on an end-of-waste regulation for struvite, which will provide broader assurance.
More materials still left
End-of-waste status is also needed for the other materials that the Water Authorities recover from wastewater, such as cellulose, PHA (bioplastics), Kaumera (polymer), vivianite and CO2. A long road still lies ahead. With the current tempo and case-by-case assessments, we will not achieve the objectives of the ‘Circular Netherlands in 2050’. The Water Authorities are therefore calling for a faster tempo, and AquaMinerals supports this call.
See also the press release (in Dutch) of the Association of Water Authorities.
For more information: Aalke Lida de Jong firstname.lastname@example.org