Quality Protocol Revisions

The Compost and Anaerobic Digestate Quality Protocols have been undergoing revision for some time. The revised documents are now called ‘Resource Frameworks’. You can download both documents below:

Draft Resource Framework for Compost

Draft Resource Framework for Anaerobic Digestate

While the Environment Agency (EA) did not conduct a full consultation on the revised documents, they released the drafts to the REA and other organisations to collect feedback from the industry and provide suggestions for improvement.

On the 1st of August, REA held a cross-industry online meeting to discuss the Resource Frameworks, highlight changes, and gather feedback. We submitted our response to the EA on the 16th of August. Thank you to members for providing comments and feedback, including during the industry meeting. Within our response, the REA:

    • advocates for alignment of the waste codes listed in the Resource Frameworks with Standard Rules Permits via specific waste code requests;
    • supports the removal of designated market sectors to allow the sale of digestate in horticultural and soft landscaping;
    • seeks clarity in the language surrounding further processing, mixing materials, and dated language referencing PAS 100 (2018) and PAS 110 (2014).

You can read our full response here.

Following feedback, the EA will consider any reasonable amendments and produce a decision document. They will then look to remove the old Quality Protocols and publish the new frameworks (with RPS) at the end of August.


Changes in the Resource Frameworks

Purpose of the Documents

The proposed Resource Frameworks will replace the existing Quality Protocols. They have the same purpose as the existing documents:

    1. To clarify the point at which waste management controls are no longer required.
    2. To provide users with the confidence that the quality of compost and digestate from source-segregated biodegradable waste conforms to an approved standard.
    3. To provide users with the confidence that the quality of compost and digestate from source-segregated biodegradable waste is suitable for use in designated market sectors.
    4. To protect human health and prevent pollution of the environment, including soil.

End-of-Waste Requirements

The Resource Framework documents are laid out differently from the existing Quality Protocols with less detail and background information.

Under the draft Resource Frameworks, a final product is no longer considered a waste when:

    1. It is produced using only approved source-segregated waste materials listed in section 4 (previously Appendix B with some amendments).
    2. You have stored and processed the waste correctly, meeting all the conditions of PAS100:2018 for compost or PAS110:2014 for digestate.
    3. It needs no further treatment before its intended use.
    4. It meets any extra specification request by your customer (for digestate only).

The Resource Frameworks require compost and digestate producers to record incoming waste, store waste correctly, process waste following the specifications defined in PAS 100 (compost) or PAS110 (digestate), and record outgoing products. They also require certification from an approved third-party certification body. As previously, there are scenarios where unused compost or digestate may lose its non-waste status.

Plastics Limits

The draft Resource Frameworks include tighter limits for plastics in the final products.

0.06% m/m limit for >2mm plastics in air-dry compost (half the current limit)

8% of the PAS 110 physical contaminants limit for plastics in digestate

There will be regulatory position statements drafted to cover a two-year transition to the new plastics limits.

If you are supplying digestate for horticultural end uses, you must agree on specifications with customers and comply with WRAP guidance on horticultural and end markets.

List of Approved Input Materials

There are some changes from the Appendix B lists in the Quality Protocols. Some changes remove ’99’ waste codes, and others harmonise the Resource Frameworks and standard rule permits. Please check the list of approved input materials, and associated descriptions, in the attached draft Resource Frameworks and let us know if there are any problems.

Designated Market Sectors

Unlike the existing Quality Protocols, the draft Resource Frameworks do not propose designated market sectors.