Sewage sludge treatment and applications

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe, considers sewage sludge management as an important topic to discuss at European level.

The evaluation of the Sewage Sludge Directive (SSD) conducted by the European Commission in 2023, showed that 40% of the 2 to 3 million tons of sludge yearly produced in the EU (17 kg/ha) are applied on farmland. The other share is incinerated (27%), composted (about 10%), or landfilled (currently estimated at 11%, and phasing out)[1].

Practices across Member States vary significantly. In Italy and in France 80% of sewage sludge is directly reused through spreading to the soil or composting. In contrast, countries like the Netherlands have banned the application of sludge to land since 1995 due to environmental and health concerns. In Germany, approaches differ regionally, with incineration remaining the most common treatment. 

The evaluation also confirmed that the SSD remains relevant, particularly in promoting the use of sewage sludge in agriculture as part of a circular economy. However, it identified the need to update the range of regulated pollutants. While the Directive currently sets limits for heavy metals, it does not address contaminants such as organic compounds (e.g. PFAS), pathogens, pharmaceuticals, microplastics and pesticides. Several scientific studies highlight the risk posed by such contaminants, especially PFAS[2].

FEAD does not favor any specific treatment method but aims to provide an overview of the non-homogeneous practices across Europe.

FEAD therefore encourages:

• the safe use of sewage sludge in agriculture, where sludge characteristics and soil conditions allow safe use, leading to a greater focus on nutrient and organic matter recovery (e.g., phosphorus, nitrogen) and reducing reliance on synthetic fertilizers, in line with the circular economy goals, and
• the thermal treatment of sewage sludge with subsequent phosphorus recovery – and any other method using end of waste pathway to valorize organic matter and nutrients – when the aforementioned conditions are not met. Recovering phosphorus from sewage sludge ash might offer an efficient solution, particularly as phosphorus is classified as a strategic raw material under the Critical Raw Materials Act (Regulation (EU) 2024/1252).

Our focus is on supporting safe and sustainable sludge management practices that contribute to the circular economy goals.

To ensure this, FEAD strongly emphasizes the need to revise the SSD and puts forward key considerations on several critical aspects.

Contaminants:

• encouraging the control of sources of contaminants in wastewater, to reduce their transfer into sludge. A positive example is the new EPR scheme introduced in the Urban Wastewater Treatment Directive (UWWTD)[3]
• periodically reviewing the list of contaminants and their threshold limits and promoting the development of harmonized analytical methods for detecting contaminants across Europe. Ongoing studies on sludge quality in the different Member states should be supported, particularly when it comes to emerging pollutants, such as PFAS, pathogens, pharmaceuticals, microplastics and pesticides
• requiring advanced sludge treatment to degrade organic pollutants and reduce pathogens

Sludge quality:

• strengthening quality control of sludge used in agriculture by improving traceability throughout its production, recycling, and recovery. Introducing mandatory quality assurance schemes that establish clear rules for land application
• making sure that quality criteria already existent are met. Only high-quality sludge, yet to be clearly defined, should be permitted for agricultural use, under strict application rates and criteria tailored to specific land use systems and local conditions
• establishing mandatory nutrient management plans to balance the nutrient supply of sludge with the actual needs of crops also by promoting research and development on the examination of N and P availability in sewage sludge for an efficient and sustainable use in agricultural crop systems
• rejecting Protected Designation of Origin, Protected Geographical Indication, Geographical Indication and any other labels that impose a ban on the use of sludge or sludge compost unless supported by scientific evidence demonstrating its impact and implement quality assurance schemes

Other recommendations:

• establishing clear criteria and methodologies – currently lacking – for the inclusion of sewage sludge in national End-of-Waste (EoW) legislation for fertilizing products
• encouraging the refinement of thermal treatment of sewage sludge for producing safe amendment, such as biochar or hydrochar, that can be used for improving soil retention capacity, reducing the need for fertilizers, providing at the same nutrients while ensuring safeness in regard to organic pollutants that can be thermally degraded
• promoting the exchange of information between stakeholders and good practices in place in Europe  
• aligning the Sewage Sludge Directive with the Soil Monitoring Law and other relevant pieces of legislation.

FEAD proposes these measures, consciously considering the different situations across Europe. This is why we support the revision of the Sewage Sludge Directive as the most appropriate legislative instrument to address these requests.

In the PDF document, you can also find the annex, where we included more detailed information on the situation at national level to better understand our proposals.

[1] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=SWD%3A2023%3A158%3AFIN&qid=1684830815132

[2] enviromail_10_europe_pfas_forever-chemicals-in-soil.pdf

[3] PFAS Phase Out: A Prerequisite for a Water Resilient Europe

[4] Directive – EU – 2024/3019 – EN – EUR-Lex

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. https://fead.be