Written Evidence submitted by Renewable Energy Assurance Limited (REAL)(SH0040)
Renewable Energy Assurance Limited (REAL) carries out a range of certification and consumer protection activities in the fields of renewable energy, organics recycling, and compostable materials. REAL operate the Compost Certification Scheme (CCS) and Biofertiliser Certification Scheme (BCS) (The Schemes). The Schemes are the only independent schemes in the UK providing an ‘end of waste’ framework for waste-derived compost and waste-digestate. CCS is aligned with BSI PAS 100, the Compost Quality Protocol (or SEPA’s Regulatory Position Statement in Scotland) and the CCS Scheme Rules, and BCS is aligned with BSI PAS 110, the Anaerobic Digestate Quality Protocol (or SEPA’s Regulatory Position Statement in Scotland), and the BCS Scheme Rules.
Through the work of the Schemes, REAL seeks to promote a circular economy and provide assurance to consumers, farmers, food producers, and retailers that quality composts and biofertilisers (end of waste certified compost and digestate) are safe for human, animal, and plant health.
REAL operate the Research Hub; funded by the composting and AD industries, the Hub aims to develop the technical and regulatory aspects of certified compost and digestate production, testing and usage, and to maintain market acceptability of these products.
Compostable Materials Certification Scheme (CMCS) is a scheme designed to provide clear labelling, recognised by the organics recycling sector, and assurance that the certified materials have been independently checked against EN13432.
REAL are submitting a response to this call for evidence as compost and anaerobic digestate can play a vital role in sustainably improving soil health, contributing organic matter as well as NPK and other beneficial elements in the soil.
REAL view that one metric by which the government could track progress towards sustainable management of soils would be measuring the use of certified organic fertilisers and soil amendments compared to manufactured fertilisers over time, thereby recognising and promoting organic fertilisers as a key indicator of sustainable soil management. Compost and digestate are sustainably sourced (from organic waste), improve soil structure and soil health, with ‘green compost’ and ‘food-based digestate’ being found to contribute 62 t/ha and 7 t/ha of organic matter respectively, in a long term AHDB trial (Bhogal and Williams, 2019). The contribution of compost to soil structure will additionally play a role in combating impacts of climate change such as increased flooding.
One of the challenges in gathering data to measure soil health is the lack of accessible data on the properties of materials applied to land. In that respect, compost and digestate certified under CCS and BCS is tested at regular intervals against PAS 100 or PAS 110 minimum quality criteria (or additional quality criteria specified by the Scottish environment agency or customers), and this data is collated in REAL’s database. This allows REAL to provide datasets for research useful for measuring soil health, such as the data pack on properties, characteristics and content of digestate, and REAL’s research paper on plastic contamination in compost and digestate.
In the agriculture sector, the government can support and encourage sustainable soil management, through promoting the use of compost and digestate as a sustainable alternative to manufactured fertilisers. This can in part be done, by aiding compost and digestate producers with the barriers the industry currently faces, and so ensuring availability of quality compost and digestate.
Food waste collection - feedstock availability
In particular, the availability of quality feedstocks is vital to producers; government involvement in introducing separated food waste collections will be invaluable in this. Additionally, feedback from producers indicates that government should seek to raise householder awareness regarding appropriate waste to be discarded in food waste bins, and in garden waste bins through public information campaigns, as this is a significant challenge.
Carbon accounting
In addition to improved soil quality, the use of organic fertilisers in the food and agriculture sector may be beneficial in terms of their capacity for carbon sequestration. While soils have historically been vital carbon sinks, they are increasingly turning to sources of atmospheric carbon due to land use and land cover change (Scharlemann et al., 2014). Early research suggests that organic amendments may enhance carbon sequestration in agricultural practices (Farooqi et al., 2018), yet the research into the nature of this sequestration potential is limited. The REAL Research Hub has commissioned a project to investigate how the production and application of compost and digestate can be inventoried and reported under the Greenhouse Gas Protocol, considering WRI’s new draft Land Sector and Removals Guidance.
The Government should support the transition to greater use of organic fertilisers—key to improving overall soil health—by promoting the potential carbon accounting benefits of using compost and digestate that food and agriculture sectors may be able to claim through inventorying their use of organic fertilisers.
REAL view that soil contamination could be most effectively tackle by promoting the use of end of waste compost and digestate. This could be done through encouraging independent certification towards quality standards of all waste derived compost and waste derived digestate, and especially when it counts towards recycling targets. Similar approach has been taken in Scotland.
Plastic contamination in quality compost and digestate
REAL’s recent research into plastic contamination in quality compost and digestate, showed that most compost samples (regardless of feedstock type) fall in the 0 (zero) to 0.02% m/m range of plastic contamination. In terms of digestate, most samples across all digestate types contained 0 (zero) to 0.039 kg/t of physical contaminants. This indicates that the PAS 100 and PAS 110 required quality management systems are effective in limiting contamination.
Moreover, a new research project commissioned by the REAL Research Hub will investigate any possible ways to further improve upon the method for detecting physical contaminants in quality compost and digestate, including an inquiry into assessing for microplastics. This research will support robust contamination testing regimes to ensure that certified compost and digestate continue to contribute positively to soil health while minimising potential stressors (e.g. plastic contamination) as much as feasible.
Improving feedstock quality
Similarly, government policy in the food sector can play a significant role in ensuring quality feedstocks for the organics recycling sector. Promoting the use of independently certified compostable packaging (CMCS), including paper and compostable plastics, for products that will be disposed of with food waste, may reduce contamination in feedstocks, as well as contribute organic material into the process.
February 2023