Biochar Europe

Biochar Europe (BCE) has submitted a letter to the Nutrient Management Institute (NMI) in response to the 2nd interim report concerning the review of the EU Fertilising Products Regulation (FPR),specifically regarding the possible inclusion of sewage sludge as a feed stock for pyrolysis under CMC 14.

The current NMI assessment concludes that sewage sludge biochar should not yet be authorized due to unresolved questions concerning PFAS standards and analytical methodologies. We consider this conclusion scientifically unjustified in light of the existing evidence demonstrating the effective destruction of PFAS under the pyrolysis conditions proposed by Biochar Europe.

The following letter was sent to Laura van Scholl at the Nutrient Management Institute together with supporting scientific studies and previous submissions already provided during the consultation process.

Open Letter to the Nutrient Management Institute

Dear Laura van Scholl,

In the presentation of the 2nd interim report, the result of the NMI evaluation was the following:

"Environmental safety and health risk

● Heavy metals: controlled by criteria under the FPR and additional criteria

● Pharmaceutical compounds, personal care and microplastics: removed at pyrolysis temperature >600°C

● PCBs, PAH, and PCDD/F: removed at pyrolysis temperature >600°C, controlled by criteria setting

● PFAS: removed >80% at pyrolysis temperature >600°C

In conclusion, no criteria are set for sewage sludge as an input for pyrolysis under CMC 14. Instead, NMI recommends reassessing this method in due time when there are:

● clear standards for PFAS concentrations in soil and/or fertilizing products,

● analytical methods for measuring PFAS in sewage sludge and biochar are more standardized,

● other process parameters affecting PFAS concentrations are better understood and optimized."

As already discussed in previous communications, there is clear scientific evidence that PFAS is completely removed from sewage sludge biochar under the process conditions proposed by Biochar Europe. This is clearly demonstrated by recent studies conducted over the last few years — particularly those by the Czech Academy of Sciences / University of Chemistry and Technology Prague (Dr. Jaroslav Mosko) and SUEZ (Dr. Sid Hamed Kessas).

Consequently, your conclusion — namely that it is necessary to wait until standards for soil limit values have been established — is not tenable, as sewage sludge biochar no longer contains PFAS. In this respect, sewage sludge biochar is not different from sewage sludge incineration ashes and should therefore not be treated differently.

On the contrary, biochar not only possesses an equally low toxicological profile, but also offers numerous advantages compared to incineration:

● The phosphorus contained in sewage sludge biochar is significantly more plant-available than that found in sewage sludge ashes.

● Biochar technology is available on a decentralized basis, thereby reducing transport requirements and strengthening local nutrient management.

● Biochar currently represents the most significant negative-emission technology, as recognized by the IPCC, and is included within the EU Carbon Removal Certification Framework.

A decision to further postpone the authorization of sewage sludge biochar blocks a vital opportunity to combat climate change and advance decentralized nutrient recycling — doing so without scientific justification.

We attached the most recent studies for your convenience and review, as well as an overview of previous materials already submitted to NMI but not yet reflected in your report.

Our Position Paper on Sewage Sludge Pyrolysis

The 2025 BCE Position Paper on Sewage Sludge Biochar concludes that biochar derived from sewage sludge should be classified under the Component Material Category 14, with a thermochemical conversion process requirement that should occur under oxygen-limiting conditions at temperatures >600°C for a minimum duration >5 min. Such additional process conditions would secure the safety of biochar from sewage sludge use in agriculture as long as PAH levels are monitored and controlled. Pyrolysis technology for the production of biochar from sewage sludge is widely available on the commercial market. The carbonization of this category of feedstocks can ensure product safety by minimizing and eliminating organic contaminants by advanced treatment and clearly defined process parameters.

Cover image for the Biochar Europe position paper on sludge-based pyrolysis as integrated bio-refineries

Position Paper: Sludge-based Pyrolysis as Integrated Biorefineries

Excerpt

This Biochar Europe (BCE) position paper examines whether thermochemical conversion can provide a safe and regulated pathway for using sewage sludge-derived biochar under the EU Fertilising Products Regulation.

Download the copy

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The technology holds the potential to substantially lower wastewater management expenses and transform wastewater treatment into a resource for producing a phosphorus-rich fertilising product. Currently, a large part of the sewage sludge produced is landfilled, causing an annual 4.1 Mt CH emissions. Further, the transportation of raw sludge entails logistical challenges that can be bypassed with the local production of biochar, annexing a pyrolysis plant directly to wastewater treatment facilities. Pyrolysis can transform the carbon contained in the feedstock into a highly stable form, qualifying for permanent carbon removals.

This document brings together scientific studies and technical evidence submitted to the Nutrient Management Institute (NMI) concerning sewage sludge biochar under the EU Fertilising Products Regulation, including findings on PFAS degradation, phosphorus recovery, contaminant removal, and full-scale pyrocarbonisation data.

Open Letter to the Nutrient Management Institute (NMI) Regarding Sewage Sludge Biochar Under the EU Fertilising Products Regulation

Open Letter to the Nutrient Management Institute

Our Position Paper on Sewage Sludge Pyrolysis

Position Paper: Sludge-based Pyrolysis as Integrated Biorefineries

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