Call for Evidence for the Bioeconomy Strategy: Towards a Circular, Regenerative and Competitive Bioeconomy

FEAD, the European Waste Management Association, welcomes the European Commission’s initiative to update and strengthen the EU Bioeconomy Strategy. Representing the private waste and resource management sector across 20 European countries, FEAD fully supports a bioeconomy that is circular and industrially competitive. However, the development of such a circular bioeconomy must be designed in synergy with existing waste management systems, must be supported by a coherent and harmonised legislative framework and must be aligned with EU objectives on waste hierarchy and circularity.

First and foremost, legislation must enshrine the principle that waste biomass and residual materials should be prioritised over primary biomass, and strict implementation of the waste hierarchy is essential. Business models must maximise waste exploitation along the value chain, in line with the cascading principle. For instance, waste from fermentation should be used for energy recovery through anaerobic digestion before the residues are used as compost.

Circularity of Biomaterials Without Disrupting Waste Systems

FEAD supports the deployment of bio-based materials where they bring real environmental benefits and fit seamlessly into existing treatment systems. However, certain developments in biomaterials, and especially bioplastics, present significant risks. Compostable bioplastics, for instance, can disrupt both plastics recycling and organic treatment processes when introduced into the respective process, as they are neither recyclable nor degrade in industrial conditions – through anaerobic digestion for example. The presence of these bioplastics in either the biowaste or the separately collected plastic waste stream is treated as contamination that negatively affects the quality of the outputs of these waste treatments, for both recycled plastic and digestate from anaerobic digestion contaminated with microplastics – rendering it unusable. Therefore, these bioplastics threaten the economic balance and operability of well-functioning waste management systems.

Additionally, our sector is particularly concerned with the confusion created by ambiguous terminology. Although FEAD welcomed the Commission’s Communication1 that clarified the terms ‘biobased’, ‘biodegradable’, and ‘compostable’, these terms are still often used interchangeably, despite denoting very different material properties and end-of-life pathways. This ambiguity impedes both consumer sorting behaviour and operational efficiency. The introduction of precise definitions in a future legislative act would help provide clarity and legal certainty on this issue.

FEAD believes that the use of bioplastics should be limited to applications that do not undermine existing recycling systems. Preference should be given to so-called “drop-in” bioplastics, such as bio-based polyethylene, which are chemically identical to conventional polymers and can be treated in existing recycling infrastructure. Compostable plastics should be restricted to narrowly defined use cases and should only be introduced if industrial composting conditions can be guaranteed.

1 Communication – EU policy framework on biobased, biodegradable and compostable plastics

Separate Targets for Biobased and Recycled Content

FEAD firmly rejects the possibility of counting biobased content toward recycled content quotas, as to be discussed under the Packaging and Packaging Waste Regulation. Such an approach conflates two distinct environmental objectives: reducing fossil resource dependency on one hand and promoting circularity through material recovery on the other.

We advocate for the establishment of separate and complementary targets for biobased and recycled content. This will avoid direct competition between the two streams, clarify market signals, and encourage investment in both circular and bio-based innovations. Combining the two into a single target would dilute the impact of recycled content obligations and risk undermining the EU’s broader recycling goals.

Implementation of Separate Collection and Free Market for Biowaste

Separate collection of biowaste has been mandatory across the EU since January 2024. However, its implementation has been inconsistent and inadequate, with large quantities of valuable organic material still being sent to landfill or incinerated without energy recovery. FEAD strongly supports the robust enforcement of this obligation and is calling for investment in infrastructure to ensure the high-quality treatment of collected biowaste.

Beyond collection, the governance of biowaste markets must be addressed. FEAD supports a model where the assignment of municipal organic waste is subject to free-market mechanisms through transparent public tenders. This system has already proven successful in some Member States, where it has reduced waste tariffs and generated cost savings for citizens. Preserving competition in the treatment market will incentivise quality service provision and innovation.

Development of a European Biomethane Market

Biomethane offers a renewable alternative to fossil gas while also contributing to the circular use of organic waste and residues. However, despite the ambitious 35 billion cubic metre target set under the RePowerEU plan, biomethane production remains far below potential.

To unlock biomethane deployment, the EU must address several critical barriers such as the lengthy and inconsistent permitting procedures, the lack of harmonised certification systems, limited access to investment finance, and the absence of a true internal market for cross- border biomethane trade. FEAD calls for 35 billion cubic metre target to be made binding and supported by measures such as fast-track permitting, integration of biomethane into the EU gas market, and cross-border mutual recognition of guarantees of origin. In addition, FEAD calls for a harmonisation and clarification over the patchwork of legislation applying to the biogas production.

FEAD also emphasises the importance of ensuring that digestate produced during biogas generation is fully valorised. This should include legal simplifications regarding the use of digestate as such as a fertiliser component under EU law, provided that the necessary quality standards are met.

Promoting Circular Fertilisers and Nutrient Recycling

Recycling nutrients from organic waste and sludge is essential for reducing Europe’s reliance on imported mineral fertilisers, closing the nutrient loop and reducing greenhouse gas emissions from waste disposal and fertiliser production. FEAD recommends evaluating the introduction of end-of-waste criteria for digestate, allowing these materials to be marketed freely once they meet clear quality standards. In parallel, the EU should establish market-pull mechanisms to boost demand for circular fertilisers. These could include Green Public Procurement rules, based on minimum recycled nutrient contents, as well as mandatory recycled nutrient quotas and recognition of biochar and other innovative products under the Fertilising Products Regulation.

Harmonisation and Revision of Key EU Legislation

A number of EU directives and regulations currently hinder the deployment of circular bioeconomy solutions due to outdated provisions, inconsistency, or excessive administrative complexity. FEAD highlights the urgent need for legislative reform in the following areas:

• The Sewage Sludge Directive, dating from 1986, needs to be revised to reflect current knowledge on nutrient recovery and ensure alignment with the Water Resilience Strategy. Additionally, the list of contaminants to be prevented should be updated to include emerging contaminants.
• The Animal By-Products Regulation must be harmonised across Member States and simplified to allow the safe and efficient treatment and recovery of animal by-products across Europe.
• The Nitrates Directive should be adapted to facilitate the use of circular and innovative organic fertilisers such as biochar and struvites, while maintaining high standards of environmental protection.
• The Fertilizers Regulation (EU 2019/1009) should be updated to expand the range of accepted fertilizer component materials and to reduce regulatory bottlenecks.
• The definition of biowaste in the EU Water Framework Directive and the Waste Framework Directive must be clarified, as it currently leaves many uncertainties regarding the treatment of organic industrial waste within their scope.

In all these areas, harmonisation must go hand in hand with flexibility to reflect national and regional specificities, especially in waste collection and agricultural practices.

In conclusion, FEAD supports a bioeconomy strategy that respects environmental boundaries while unlocking the full potential of circularity and resource efficiency. This requires alignment with the existing waste hierarchy, clarity and coherence across all applicable legislations, and strong safeguards to ensure that bio-based developments do not undermine established recycling systems or delay progress toward a truly circular economy. We remain fully committed to supporting the European Commission and Member States in developing a practical, resilient, and competitive bioeconomy strategy.

FEAD is the European Waste Management Association, representing the private waste and resource management industry across Europe, including 20 national waste management federations and 3,000 waste management companies. Private waste management companies operate in 60% of municipal waste markets in Europe and in 75% of industrial and commercial waste. This means more than 500,000 local jobs, fuelling €5 billion of investments into the economy every year.