Position paper on REACH and digestate
Digestate, the second product of anaerobic digestion is being discussed under the End of Waste criteria (for certain products which cease to be waste according the Waste Framework Directive 2008/98/EC). If fulfilled, that would enable its trade as a commercial product, i.e. organic fertilizer.
As a new product placed on the market, digestate would also potentially face unintended consequences from the REACH Regulation 1907/2006/EC (Registration, Evaluation, Authorisation and Restriction of Chemicals).
The European Biogas Association and German Biogas Association representing the biogas industry, have discussed with representatives of DG Environment and DG Enterprise from the European Commission about the anaerobic digestion process, the differences between anaerobic digestion and composting and the scope of the REACH Regulation.
The biogas industry representatives have built up a comprehensive description of the biogas technology and the composition of digestate, arguing for an exclusion from the REACH perimeter.