Deliverable 4.4 - Proposal for end-of-waste criteria


This Deliverable 4.4 aims at defining  a draft dossier proposal for the “End-of-waste” (EoW) definition for PHA produced from biowaste and sludge.

This dossier was based on the information that has been gathered during the life of this project, both through desk and experimental work. Namely, it is based on the desk analysis of waste regulation (Deliverable D4.1), of contaminants of possible relevance (D4.3), and of the potential market for PHA (D5.3) as well as on the experimental work carried out to define PHA production (D2.2 and 2.5), PHA extraction (D2.3 and D2.6), and PHA characteristics (D3.1), including  the presence of relevant contaminants (D3.2). Moreover, the dossier also takes into account comments and recommendations we received from stakeholders during project meetings (D5.2) and the investigation made about social perception (D4.2).

The preparation of a dossier is a fundamental step towards developping new waste-based products by using new technologies because Directive 2018/851 (art 6) states that End of Waste status for a given substance or material has to be determined case by case at National level, when a specific EU regulation is absent (like in this case).

According to article 6 of the Directive, certain specified waste shall cease to be waste within the meaning of point (1) of Article 3 when waste has undergone a recovery, including recycling, operation and complies with specific criteria to be developed in accordance with the following conditions:

(a) the substance or object is commonly used for specific purposes;
(b) a market or demand exists for such a substance or object;
(c) the substance or object fulfils the technical requirements for the specific purposes and meets the existing legislation and standards applicable to products; and
(d) the use of the substance or object will not lead to overall adverse environmental or human health impacts. The criteria shall include limit values for pollutants where necessary and shall take into account any possible adverse environmental effects of the substance or object.

In particular, the specific Decree for the definition of the End of Waste status for a given substance or material at National level, should be based on the following points:

  1. Definition of the waste type (with indication of the European Catalogue Code) and its characteristics including the acceptability definitions / standards
  2. Technical parameters in terms of characteristics and definition of limits of the resulting “new” material / substance
  3. Definition of the specific use and markets for the new waste-derived product

Based on the analysis done, in the case of PHA production from urban organic waste the above reported  4 (a-d) criteria are well respected  and the required three points (1-3) have been defined in a tentative dossier (section 3) which reports proposed specifications on:

  • Allowed waste to be used for PHA production
  • Flow sheet of PHA production process
  • PHA typical composition (monomer composition and purity
  • PHA safety (presence of relevant contaminants)
  • Need and criteria for compliance with REACH/ECHA (with possible exemption) and CLP regulations
  • Market applications

As a summary we can report here that:

  1. Proposed organic waste for PHA production are typically the organic fraction from municipal solid waste and the sludge from municipal wastewater treatment, whose quantity and characteristics are typically well defined at territorial level. Based on local conditions, food processing waste can be also included.
  2. characteritics of obtained PHA can be easily determined (monomer composition, purity, ashes), and PHA meet regulatory standards or guidelines for the allowable presence of relevant contaminants as well. Exemption/compliance for REACH/ECHA regulation has to be checked case by case.
  3. There is a clear market demand for bioplastics in several sectors and a first estimation of at least 1 million ton per year worldwide can be considered. Because all market segments are well ruled, there’s a general provision that PHA use complies with existing regulations, guidelines and technical specifications for the relevant sector.