The Swedish Implementation Council 

We are happy that in its opinion on the Circular Economy Act, the Council highlights barriers for three of our solutions. 

• Example of phosphorus: Wording in the Animal Feed Regulation (Regulation 767/2009, Annex III, point 5) that does not allow the use in the EU of phosphorus that originates from wastewater in animal feed. This means that the recycling companies that today want to test new technologies to recycle phosphorus need to look outside the EU (Canada, the USA or Brazil) and that the EU at the same time needs to continue importing phosphorus from Russia and Morocco. 

• Example on aquaculture: Fish sludge is currently only classified as waste. It prevents the reuse and production of fertilizers or feed, as well as prevents the establishment of phosphorus recovery factories. If fish sludge is instead recognized as a by-product or animal byproduct, according to the Animal By-Product Regulation, it will be possible to use it for biogas through anaerobic digestion. 

• Example of carbon storage: Ragn-Sells emphasizes the need for regulations that enable the storage of carbon dioxide in products, which would facilitate the extraction of potassium carbonate and the production of limestone from recycled carbon dioxide. 

The Implementation Council proposes that the Swedish Government should “review the design of today’s regulations that prevent the transition to circular working methods and innovation, where legislation currently focuses on the origin of materials instead of on their quality and potential as a raw material”, and “develop technology-neutral frameworks that promote bio-based, recycled CO₂-based raw materials”. 

 As regards the phosphorus examples and the raised needs, these further strengthen the last year's call from the Swedish government to the Commission, requesting that the Commission ask EFSA to carry out a risk assessment, and then take the necessary steps to amend the legislation, to enable the use of recovered critical nutrients from wastewater in animal feed. The Implementation Council's opinion has now been sent to the Swedish Ministry of Climate and Enterprise. 

Read the full report here.