Background document for phase by EuropeanUnion

VIEWS: 88 PAGES: 39

									European Eco-label for Soil Improvers and
Growing Media
Revision 2005 - background document (phase 1)

ENV.G.2/SER/2004/0024r




by:

SV&A sustainability consultants
P.O. box 11133
NL 2301 EC Leiden
The Netherlands
tel.   +31 71 519 10 05
fax    +31 71 517 58 35
e-mail svena@svena.nl

Rein J.M. Aarts, MSc

for:

Stichting Milieukeur / European Eco-labelling Board




Contractnumber: ENV.G.2/SER/2004/0024r




Leiden, February 2005
ESG/02.6/report
Some general information on the European Eco-label - the Flower

                  The flower is the symbol of the European Eco-label - your guide to greener products and
                  services. It is a VOLUNTARY scheme. Criteria are established for individual product
                  groups, such as paper products, textiles, detergents, paints and appliances such as
                  refrigerators or dishwashers. When you, as a consumer, see products with the eco-label, you
                  will know that these products have been carefully assessed and have been found to make less
                  of an environmental impact than other similar competing products, or those products with
                  sometimes misleading environmental claims on them.
Key aims
•   to achieve significant environmental improvements - by developing, publishing and promoting criteria
    that push the market forward, in order to minimise the environmental impacts of a wide range of products
    and services over their whole life-cycle;
•   to ensure the credibility of the award – by efficient administration and through criteria which:
    - are environmentally strong;
    - are based on good science, including the precautionary principle;
    - take account of consumer health;
    - require good product performance;
    - are developed transparently and cost-effectively, with the participation of stakeholders;
    - are reasonably attainable;
    - are up to date.
•   to encourage manufacturers, retailers and service providers to apply for the award, to publicise their
    own participation in the scheme, and to promote the availability of eco-labelled products and information
    about them;
•   to encourage purchasers to buy products and services with the award;
•   to improve consumer awareness and behaviour regarding the environmentally optimal use of products
    and services.

How the eco-labelling Scheme works

It takes hard work and commitment to set up criteria. Every product group is designed and crafted to meet
high environmental and performance standards. Ecological criteria for each product are defined on the basis
of life cycle considerations (LCC) taken from a "cradle-to-grave" view of the environmental impacts of a
product group.

How Eco-label Criteria are developed and adopted

Proposals for the definition of product groups and ecological criteria are made either on the request of the
Eco-labelling Board (EUEB) or by the Commission. The Commission gives a mandate to the EUEB (lead
Competent Body) to develop or review the eco-label criteria. Priority product groups will be listed in the
joint working plan. On the basis of these mandates the appropriate EUEB member, supported by a working
group and the Commission will draft appropriate eco-label criteria and the assessment and verification
requirements related to these criteria. The Competent Body will take into account the results of feasibility
and market studies, life cycle considerations and an improvement analysis. A regular feed-back process to
the whole EUEB is ensured. Finalised criteria are submitted to the Regulatory Committee of national
authorities and voted upon. If the Committee takes a favourable view of the proposal, the Commission
proceeds with its adoption and publication. Otherwise, the Committee submits the proposal to the Council of
Ministers for decision.
More information: http://europa.eu.int/comm/environment/eco-label/index_en.htm
Contents




Contents

           Summary

1          Introduction ....................................................................................................................1
           1.1 General .................................................................................................................1
           1.2 Objective and main focus of the study .................................................................1
           1.3 History and background .......................................................................................1
           1.4 Reading instructions.............................................................................................4

2          Soil improvers, composts ...............................................................................................5
           2.1 Introduction ..........................................................................................................5
           2.2 Collection, production ..........................................................................................6
           2.3 Quality control and certification...........................................................................8
           2.4 Markets and applications....................................................................................11

3          Growing media .............................................................................................................13
           3.1 Introduction ........................................................................................................13
           3.2 Production ..........................................................................................................14
           3.3 Quality control and certification.........................................................................15
           3.4 Markets and applications....................................................................................16

4          Focal points ..................................................................................................................19
           4.1 Introduction ........................................................................................................19
           4.2 Sewage sludge ....................................................................................................19
           4.3 National legislation ............................................................................................21
           4.4 Other growing media..........................................................................................21
           4.5 Reassessment of the use of peat .........................................................................22
           4.6 Broadening the product group............................................................................23
           4.7 Packaging ...........................................................................................................24
           4.8 Nutrient loadings ................................................................................................24
           4.9 Life cycle assessments .......................................................................................26
           4.10 Experiences with the current criteria..................................................................28

5          References ....................................................................................................................29

           Annex I: Cross-reference




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SV&A sustainability consultants
Summery                                                                                                     i




                 Summary
Introduction     The European Eco-label intends to promote the production, marketing and use of
                 products which have a reduced environmental impact during their entire life cycle. In
                 April 1998, criteria were published for the award of the European Eco-label for Soil
                 Improvers.

                 Originally the criteria focussed entirely on the use of soil improvers for home garde-
                 ning. A first revision of the criteria was finalised in June 2001. During this revision, an
                 important point of attention was to broaden the scope to professional applications of soil
                 improvers and to extend the criteria to cover growing media as well.

                 The current criteria aim in particular at promoting:
                 •   the use and/or re-use of organic matter derived from waste material;
                 •   the reduction of environmental damage or risks from heavy metals and other
                     hazardous compounds.

                 Since the last revision, the number of licence holders has grown considerably (from 5 to
                 17) and the total sales of Eco-labelled soil improvers has been multiplied (to approxi-
                 mately 140.000 Mg in 2003). The broadening of scope to professional applications of
                 soil improvers has contributed considerably to this volume growth. So far, no producers
                 of growing media have applied for the European Eco-label.

                 The existing criteria for soil improvers and growing media expire in August 2006.
                 Stichting Milieukeur (SMK), the Dutch Competent Body for the European Eco-label,
                 was awarded a service contract to draft revised criteria. On behalf of SMK, research has
                 been performed by SV&A sustainability consultants.

Objective        The objective of this background document is to provide the Ad Hoc Working Group
                 (AHWG) an overview of various developments and experiences with the current criteria
                 in order to give a recommendation whether the existing Eco-label criteria should be
                 prolonged, withdrawn or revised. The first meeting of the AHWG will be held in
                 Brussels on March 15, 2005.

Soil improvers   Soil Improvers are defined as “materials to be added to the soil in situ primarily to
                 maintain or improve its physical properties, and which may improve its chemical
                 and/or biological properties or activity”.

                 The physical properties of the soil can be influenced in many ways. The current criteria
                 however are tuned primarily to products that improve the physical structure by adding
                 stable organic matter to the soil.

                 The two main waste streams containing high levels of organic matter are bio-/green
                 waste and sewage sludge. Sewage sludge is currently not admitted in Eco-labelled soil
                 improvers. The total annual amount of bio- and green waste in the EU is estimated to be
                 nearly 60 million Mg. Presently, some 30% of this waste is separately collected. This
                 results in an annual compost production of around 9 million Mg. Most composts are
                 applied in low price segments such as agriculture. Relatively low volumes find



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                       upmarket applications in for example the production of high quality top soils or as
                       constituent in growing media.

                       Quality control and certification are being widely regarded as most important to the
                       market acceptance of composts. Also from an environmental point of view, quality
                       control is of eminent importance. At present, all countries with a high level of organic
                       waste recovery have established extensive quality management systems for composting.
                       These standards usually exceed the requirements contained by the current European
                       Eco-label for SI & GM. However, when looking in detail to these quality systems,
                       distinct differences between the various systems occur. This leads to the question
                       whether the current quality requirements in the European Eco-label are still complete
                       and effective and/or whether it could be possible to refer to existing quality labels in
                       order to secure product quality in the future.

                       An overview of voluntary and legal national criteria for heavy metals and/or other
                       contaminants in soil improvers shows that these are not always in line with the limit
                       values of the European Eco-label.

Growing media Growing media are defined as materials, other that soils in-situ, in which plants are
                       grown.

                       Growing media have two main application areas; the professional and hobby market. In
                       the professional market, growing media are applied on a large scale in soil-less
                       greenhouse and/or container cultures. In the hobby market, growing media are better
                       known as potting soil.

                       The total volume of growing media consumed in the EU (hobby and professional) is
                       estimated to be some 20 - 30 million m3 annually. Hobby applications account for
                       approximately 60% of this volume. There is a broad spectrum of growing media
                       available. Worldwide, peat based growing media cover some 90% of the market. Other
                       materials applied are composts, synthetics and a wide range of natural organic products
                       and minerals. Many growing media are blends (formulations), where the mix of
                       materials is determined by the required end-product characteristics, availability and
                       price of raw materials. For many materials, the required end-product characteristics set
                       maximum application levels.

                       All major materials and production processes have been recently submitted to Life
                       Cycle Analysis.

                       Similar to soil improvers, quality certification of growing media is essential to market
                       acceptance. Lack of quality may not only lead to financial damage, but also to
                       environmental damage that by far exceeds the environmental input of the growing
                       medium itself. Currently, the European Eco-label criteria regarding product
                       performance are to a large extent similar for Soil Improvers and Growing Media. Given
                       their differences in function and application, it could be questioned whether such a
                       single set of criteria is realistic. Possibly, references could be made to existing quality
                       labels.




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Summery                                                                                                 iii




Focal points   As was decided during the previous revision in 2001, particular attention is paid to the
               following issues:
               •   the possible use of sewage sludge in this product group;
               •   evaluation of other growing media;
               •   a reassessment of the use of peat;
               •   completion of this product group by other sub-product groups such as humifying eco-
                   systems and organic fertilisers;
               •   a reassessment of nutrient loadings.

               These subjects are addressed by putting recent developments into perspective, including
               their possible impact on the current criteria of the European Eco-label. The ‘Thematic
               Strategy on Soil Protection’ introduced by the Commission in 2002, and the develop-
               ment of ‘Wise Use Guidelines for the use of mires and peatlands’ are just two examples
               of initiatives that are elaborated in the main text. This and other information is presen-
               ted to foster discussions by the AHWG.

               In addition, some special attention is paid to:
               •   the availability of updated Life Cycle Inventories for the product group;
               •   experiences of Competent Bodies and current licence holders with the existing
                   criteria.

               Where relevant, points for discussion by the AHWG are highlighted throughout the
               main text.




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Chapter 1 - Introduction                                                                                                   1




1                    Introduction
1.1                  General

                     Regulation (EC) 1980/2000 establishes a Community Eco-label award scheme which is
                     intended to promote the design, production, marketing and use of products which have a
                     reduced environmental impact during their entire life cycle. To do so, the Commission
                     gives mandates to the European Eco-labelling Board to develop and periodically review
                     the European Eco-label criteria as well as the assessment and verification requirements.

                     The existing criteria for soil improvers and growing media expire in August 2006.
                     Following a public call for tenders, the Commission awarded a service contract to draft
                     revised criteria for this product group to Stichting Milieukeur (SMK), the Dutch
                     Competent Body for the European Eco-label.

                     In recent years, SMK observes that many producers, both active in the professional and
                     home gardening market, are expanding their scope of operations. In particular the
                     professional market for growing media is internationalising in a rapid pace. At the same
                     time, retail quality standards such as EurepGap increasingly call for independent
                     ecological criteria which are internationally accepted. This strongly underlines the need
                     for an European Eco-label for Soil Improvers and Growing Media appealing to
                     professional users, retail channels and end consumers alike.

                     This document gives an update on recent developments in the markets for soil im-
                     provers and growing media that can be of interest to the European Eco-label criteria.
                     The document will be discussed during the first meeting of the Ad Hoc Working Group
                     (AHWG) to be held in Brussels on March 15, 2005. The background document was
                     prepared for SMK by SV&A sustainability consultants.


1.2                  Objective and main focus of the study

                     On the basis of this background document, the AHWG is asked to give a recom-
                     mendation whether the existing eco-label criteria should be prolonged, withdrawn or
                     revised. In case of revision, draft revised criteria will be developed with active
                     participation and involvement of all relevant interest groups.


1.3                  History and background

                     In April 1998, criteria were published for the award of the European Eco-label for soil
                     improvers1. Originally the criteria focussed entirely on the use of soil improvers for
                     home gardening. It intended to promote the application of waste derived organic
                     materials. In the first year after introduction, only a small number of producers applied
                     for the Eco-label and no soil improvers received the award.



                     1 Commission Decision of 7 April 1998 establishing the ecological criteria for the award of the Community
                       Eco-label to soil improvers (98/488/EC).



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                       By the end of 2000, the Eco-label was awarded to five products, four of which were
                       produced in France. All products were based on composted waste. Total amount of Eco-
                       labelled soil improver traded in 2000 was 20.000 tonnes [ANPA 2000 - p6].

                       The first revision of the criteria was finalised in June 2001. During this revision, an
                       important point of attention was to broaden the scope to sectors other than (hobby)
                       gardening and to extend the criteria to cover growing media as well. This broadening of
                       scope was motivated by the observation that:
                       •   the professional market for soil improvers is by far bigger than the hobby market;
                       •   growing media (hobby and professional) supposedly could contain up to 50% of soil
                           improving material, generating a theoretical market expansion for the Eco-labelled
                           soil improvers of nearly 4 million tonnes.

                       In other words: the outset was to find new markets for the application of soil improving
                       materials meeting the standing Eco-label criteria. Stretching the size of the market
                       would add commercial appeal to the criteria and thus generate an increasing number of
                       applicants.

                       On August 28th 2001, the current version of the criteria was published2. These latest
                       criteria aim at promoting:
                       •   the use and/or re-use of organic matter derived from the collection and/or processing
                           of waste material, offering compost producers new opportunities to market their
                           product;
                       •   the reduction of environmental damage or risks from heavy metals and other
                           hazardous compounds in soil improvers and growing media.

                       A basic requirement for growing media was that the organic part should be composed
                       exclusively of soil improvers meeting the Eco-label requirements. The use of peat was
                       prohibited. Also, sewage sludge remained excluded. Other adjustments include:
                       •   a new criterion on odour;
                       •   a maximum level of seeds and propagules;
                       •   a hurdle for physical contaminants;
                       •   in nutrient loadings, the difference is introduced between inorganic and organic
                           nitrogen (see also § 4.8 on page 24). Also, the hurdles for P2O5 and K2O were changed
                           to better reflect market conditions;
                       •   the hurdle for salmonella in the health and safety criterion;
                       •   newly structured and more user-friendly product information (general information,
                           information on the use of the product, specific information for soil improvers).

                       In addition, various test methods were mentioned explicitly, not excluding other test
                       methods considered by Competent Bodies as appropriate and equivalent.



                       2 Commission Decision of 28 August 2001 establishing the ecological criteria for the award of the
                         Community Eco-label to soil improvers and growing media (2001/688/EC).



SV&A sustainability consultants
Chapter 1 - Introduction                                                                                        3




                     Table 2.3.1 gives an overview of the current European Eco-label licence holders for
                     growing media and soil improvers. 17 producers manufacture 20 products that were
                     awarded the Flower. Most license holders are French (13), with a limited number of
                     licence holders coming from Denmark (1), Italy (1), Spain (1) and Belgium (1).
                     Products are sold in bags (mainly hobby market) and in bulk (mainly professional
                     applications). Since the last revision, the number of licence holders has grown
                     considerably (from 5 to 17) and the total sales volume of Eco-labelled soil improvers
                     has been multiplied (to approximately 140.000 tonnes in 20033). The broadening of
                     scope to professional applications has contributed considerably to this volume growth.

                     So far, no producers of growing media have applied for the European Eco-label.


Table 2.3.1          Licence holders European Eco-label Growing Media and Soil Improvers
 Product                                             Category             Manufacturer             Origin
 C.BIO                                               Soil Improvers       Valsud - Onyx            France
 Compost de Vallet 100% végétal                      Soil Improvers       Charier DV               France
 Compost vegetal de Billy                            Soil Improvers       Valnormandy - Onyx       France
 Compost vegetal Humosol                             Soil Improvers       Humosol                  France
 Compost VG Sol                                      Soil Improvers       Ronaval - Onyx           France
 D-GroA                                              Soil Improvers       Solum Gruppen            Denmark
 Ecolife                                             Soil Improvers       Fertil S.p.A.            Italy
 Jardinami                                           Soil Improvers       Terre et Nature Jardin   France
 Jordfrisk                                           Soil Improvers       Solum Gruppen            Denmark
 Le Compost Végétal                                  Soil Improvers       Somergie                 France
 Lémansol’s Compost                                  Soil Improvers       AWT                      France
 NaturComplet                                        Soil Improvers       Daymsa                   Spain
 Noramcal                                            Soil Improvers       Norampac                 France
 Orgabiose                                           Soil Improvers       La chanviere de l’Aube   France
 ORVAL, le Compost Végétal de Noirmoutier            Soil Improvers       Geval - Onyx             France
 ORVAL, le Compost Végétal du Santerre               Soil Improvers       Aubine - Onyx            France
 Plantamix 40 L                                      Soil Improvers       Norland SA               Belgium
 Secret-Vert                                         Soil Improvers       Atlantique Amendement    France
 Terre et Nature                                     Soil Improvers       Terre et Nature Jardin   France
 Verre de Terre                                      Soil Improvers       Terre et Nature Jardin   France




                     3 Estimate based on data provided by AFNOR Certification.



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1.4                    Reading instructions

                       Below, we start with an overview of market developments in Soil Improvers and
                       Growing Media. Given the differences in functionality and applications, this overview
                       has been split up into two chapters (chapter 3 - soil improvers and chapter 4 - growing
                       media). Subsequently, we have a look at a number of issues that, at the end of the
                       previous revision in 2001, were identified as special points of attention. In addition, the
                       experiences with the current criteria will be presented (chapter 5).

                       Throughout chapters 3 - 5, discussion points will be highlighted in bold printing. We
                       suggest that these points of discussion are addressed during the first meeting of the
                       AHWG.

                       Annex I contains a cross-reference between the current criteria and this document.




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Chapter 2 - Soil Improvers                                                                                        5




2                   Soil improvers, composts
2.1                 Introduction

                    The definition of soil improvers in the current European Eco-label criteria is “materials
                    to be added to the soil in situ primarily to maintain or improve its physical properties,
                    and which may improve its chemical and/or biological properties or activity”.

                    This definition rightfully points at the fact that soil improvement can be achieved in a
                    number of fundamentally different ways:
                    •   by improving the level of fertilisers and trace elements;
                    •   by influencing the acidity (pH) of the soil;
                    •   by improving the physical structure of the soil (water retention, air-water ratio, bulk
                        density and handling properties);
                    •   by improving the biological properties of the soil.

                    The soil improvement that is actually achieved, not only depends on the character of the
                    soil improver itself, but also on:
                    •   the starting point; soil type (sand, clay, …) and its specific condition;
                    •   the required end situation; every soil application has its own set of favourable
                        conditions.

                    In short: the suitability of a soil improver depends on the specific situation. Soil
                    improvement is a mix of various effects which can be achieved by a wide range of
                    materials; organic, mineral and others. The current definition explicitly focuses on the
                    improvement of the physical properties as the prime objective of soil improvement.

Mechanism           When we look at the way in which soil improvers succeed in improving the physical
                    structure of the soil, we find two main mechanisms:
                    •   enhancing the content of stable organic matter in the soil (by applying organic soil
                        improvers). Stable organic matter means that the organic matter retains its structure
                        after it has been added to the soil and will break down only slowly. Products on the
                        basis of peat and composts typically have high contents of stable organic matter. Field
                        tests indicate that the level of stable organic matter in soil improvers show large
                        variations and that a sufficient high level of organic matter (>20%) is essential to the
                        effectiveness of the product;
                    •   enhancing the stability, handling and draining properties of the soil (by organic soil
                        improvers and/or minerals such as sand, clay, lava and others).

                    In many soil improvers, both mechanisms are combined by composing a mix of organic
                    and mineral substances. In the vast majority of applications however, the organic
                    component (in particular its content of stable organic matter) is by far the key
                    constituent of the product.




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                       In § 4.6 - page 23, an assessment will be made of broadening the scope of the product
                       group to humifying products and organic fertilizers.


2.2                    Collection, production

                       Much of the information in this paragraph is retrieved from the internet website of the
                       European Compost Network [ECNweb 2005].

                       Most of the available information applies primarily to the EU15 countries. On the basis
                       of Eurostat data, some estimates have been made for the new member states.

                       In the EU15 countries, the collected and treated amounts of organic material show large
                       differences. Around 35 percent is presently separately collected, equalling 17 million
                       Mg out of the estimated total recoverable potential of the 49 million tons bio- and green
                       waste (see table 2.2.1). This results in a compost production of around 9 million Mg.
                       Additional data on composted municipal waste in the new member states is listed in
                       table 2.2.2. Assuming that the production of organic waste per capita is more or less
                       equal in all member states, the total amount of bio- and green waste in the EU25 is
                       estimated at nearly 60 million Mg.


Table 2.2.1            Amount of separately collected and composted bio- and green waste in the EU
Country                      Sep. collected + treated              Recovery potential of                     Theoretical
                             organic waste                         organic waste                             potential
                                             [M io M g]                              [M io M g]                   [M io M g]
                                   Biowas te             Greenwas te       Biowas te        Greenwas te
A (2000)                              0,45                    0,2             1,22                0,97                  2,19
B (2000) Flanders                     0,34                   0,39                                                        1,3
B (1994) W allonia                                0,12                                                              0,16 in 2002
D (1999)                                           7                                                                      9
DK (1999)                            0,037                   0,65             0,1                 0,66              0,76 in 2004
F (2000)                              0,05                    1,5             5,25                3,5                   8,75
Fi (1998)                             0,1                                                                                0,6
GR (1995)                               -                      -                                                         1,8
I (1999)                                          1,5                                                                     9
IRE (1998)                                                                                                              0,44
Lux (1998)                                        0,03                                                                  0,06
NL (2001)                             1,6                     1,5             1,7                 1,5                    3,2
P (1995)                                                     0,01                                                        1,3
ES (2000)                         0,03 (Catal.)          0,02 (Catal.)                                                   6,6
SW (1999)                             0,14                   0,15              1                  0,65                  1,65
UK (2000)                            0,039                    1                                                      3,2 in 2006
Total                                 11,4                   5,42                                                       48,7
Treated Bio- + Greenwas te 16,9 M io. M g                                Theoretical recovery potential 49 M io. M g




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Chapter 2 - Soil Improvers                                                                                                    7




Table 2.2.2         Municipal waste composted in the new member states4
                                     yea r            2000                          2001                     a vera g e*
C o untry                                         [1 0 0 0 M g ]                [1 0 0 0 M g ]              [1 0 0 0 M g ]
Czech Rep u b lic                                                                                               2               e
Es to n ia                                           1,51                        11,08            e           11,08             e
Cy p ru s                                              -                            -                           -
Latv ia                                                                           16,3                        16,3
Lith u an ia                                           -                            -                           -
Hu n g ary                                                                       17,03                         47
M alta                                               30,47                        31,2                        31,2
Po lan d                                              248                          309                         215
Slo v en ia                                                                      65,17                        11,3
Slo v ak Rep u b lic                                                                                          39,31
 to tal                                                                                                      373,19
source: Eurostat
* average = running average over period for which statistical data are available (differs per country)
** e = estimate



                    When looking at organic waste reprocessing, Europe can be divided into 5 clusters:
                    •   in Austria, Belgium (Flanders), Germany, Switzerland, Luxembourg, Italy, Spain
                        (Catalonia), Sweden and the Netherlands, separate collection and composting of
                        organic waste is countrywide implemented. These countries cover around 80 percent
                        of all organic waste currently reprocessed in the EU;
                    •   a second group of countries, including Denmark, UK and Norway, have developed a
                        framework for separate collection and composting which they are now gradually
                        implementing;
                    •   in Finland and France, separate collection, especially in municipal organic waste, is
                        still at a starting point;
                    •   in a fourth group of countries including parts of Spain, Greece, Ireland and Portugal,
                        examples of separate collection and composting are still very rare;
                    •   for the fifth group, the new member states, sufficient statistical data needed to
                        compose a sound overview have not been found.

                    In the Draft Biowaste Directive5, the Commission tended to favour mandatory separate
                    collection of biowaste throughout the EU by 2010. Mid 2004, it was decided not to
                    produce a (final) Biowaste Directive, but to include the subject of separate collection of
                    biodegradable waste and composting in the Soils Strategy which is still being developed
                    [EU 2002/2].

                    The members of the AHWG are invited to provide additional or more accurate
                    data on separate collection and composting.


                    4 It should be considered that the definitions of municipal waste and household waste varies over countries,
                      harmonised data collection will be achieved with the implementation of the Waste Statistics Regulation.
                    5 aimed to set rules on the safe use, recovery, recycling and disposal of biodegradable municipal waste, to
                      control potential land contamination and to encourage the use of certified compost



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2.3                    Quality control and certification

General                Quality control and certification are being widely regarded as most important to the
                       market acceptance of composts. A study in the south of Germany showed that 94% of
                       the commercial compost users regarded quality certification to be a precondition. As
                       highlighted in § 3.3 (page 15), the application of inferior products may lead to environ-
                       mental damage that is by far bigger than the environmental inputs linked to the soil
                       improver itself.

                       The importance of quality control and certification is also stressed by the EU Biowaste
                       Directive and the Technical Working Groups elaborating the ‘Thematic Strategy on Soil
                       Protection6’ launched by the EU in 2002. The Commission believes that compost
                       should achieve EU-wide quality requirements which would set maximum tolerable
                       levels of certain pollutants and pathogens. The quality requirements would complement
                       the requirement for separate collection and defined process standards.

                       In order to be effective; a quality system should cover all phases influencing end-
                       product quality; collection and waste acceptance, composting and storage, packaging,
                       distribution and product application. In line with the different levels of organic waste
                       processing in the various EU countries, the status of quality assurance and certification
                       shows large differences throughout the EU (table 2.3.1).

                       At present, all countries with a high level of organic waste recovery have established
                       extensive quality management systems for composting. Some 500 composting plants
                       have implemented certified quality management systems. Together, they treat around
                       70 % of the source separated organic waste in Europe. Several others like Sweden,
                       Norway, UK and France are at the stage of the conceptual design (status December
                       2001).

                       Members of the AHWG are welcome to add more recent or missing information
                       on this subject.




                       6 EC Communication “Towards a Thematic Strategy on Soil Protection” (COM(2002) 179, of 16.4.2002)

SV&A sustainability consultants
Chapter 2 - Soil Improvers




Table 2.3.1         Survey on compost quality efforts in various countries (December 2001)
                                                                                    Plants                                              Scope
Country            Status of quality assurance/certification of compost          QA     certified production                               product
Austria            Fully establish quality assurance system                      10         2     Compost Ordinance                        Compost Ordinance and KGVÖ
Belgium            Fully establish quality assurance system in the               22        10     VLACO during the first year of           VLACO, starting the year 2
                   Flanders region, the Wallonia and the Brussels                                 operation
                   region will probably follow the Flanders example.
Denmark            Just started with quality assurance system for                                  Plant Directorate
                   compost (Criteria, standardised product definition,
                   analysing methods)
France             Proposal for quality criteria, Research program for a                           According to ISO 9000 in the Qualorg According to ISO 9000 in the Qualorg
                   quality management system                                                       research project                     research project
Germany            Fully established quality assurance system for               429          400   BGK (only hygiene issues)            BGK
                   compost and digestion residuals
Italy              Successful source separation system
Luxembourg         Some plants according to German Quality Assurance              3           3
                   System
Netherlands        Fully established quality assurance and certification         22           4    KIWA                                    KIWA
                   system
Spain              ‘Bill on the Quality of Compost’ in Catalonia
                   (Proposal)
Sweden             Just started with quality assurance system for                 2                RVF certification                       RVF certification
                   compost and for digestion residuals
UK                 Quality standard by the Composting Association                                  TCA - procedures and records            TCA - sampling, results, product
                   TCA (Proposal)                                                                  checked for each assessment period      storage and labelling checked for each
                                                                                                                                           assessment period
Other EU25         No known official efforts until now
Source              ECNweb 2005, status December 2001




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10                         ESG 02-6; Revision European Eco-label Criteria Growing Media and Soil Improvers - background document phase 1




Differences            When looking in detail at the various quality systems, fundamental differences can be
                       observed in a number of areas:
                       •   focus; end product certification only or also requirements regarding plant management
                           and processing;
                       •   types of classification; referring to the origins of the organic matter, the type of
                           application or chemical content (heavy metals and sometimes organic pollutants7);
                       •   hygiene; process requirements (i.e. composting temperature profiles) and/or product
                           test for germs such as E.coli, Camylobacter, Salmonella but also fungi, weeds
                           etcetera.

                       All known quality systems contain additional (but different) requirements for impurities
                       (plastics, metals, glass, stones), organic matter, plant compatibility, degree of decompo-
                       sition, salt and water content. All systems contain instructions for providing the product
                       data necessary for a proper product application.

Discussion             Quality certification is of eminent importance to the sound application of soil
                       improvers, also from an environmental point of view. The current ‘quality
                       criteria’ in the European Eco-label for SI and GM contain requirements for
                       physical contaminants8, product performance9, health and safety10, seeds and
                       propagules11. Are these requirements still complete and effective (for soil
                       improvers) and/or would it be desirable/feasible to refer to existing quality labels
                       in order to secure product quality.

Contaminants           Many countries have established maximum levels for heavy metals (table 2.3.2). The
                       criteria are laid down in quality standards which are voluntary or legally binding. In
                       some cases, incidental deviations are allowed. Sometimes, correction factors are applied
                       to determine the limit values that are used in practice. With exception of the limits in
                       the Netherlands, all limit values are more of less in line12. The table shows in shading
                       where national requirements exceed the current European Eco-label values.




                       7 Currently, Denmark and Austria are the only countries addressing organic pollutants in legislation.
                       8 In the final product (with mesh size > 2 mm), the content of glass, metal and plastic shall be lower than
                         0,5 % as measured in terms of dry weight.
                       9 (a) Products shall be supplied in a solid form and contain not less than 25 % dry matter by weight and not
                         less than 20 % organic matter by dry weight (measured by loss of ignition).
                         (b) Products shall not adversely affect plant emergence or subsequent growth.
                         (c) Products shall not give rise to offensive odours after being applied to the soil.
                       10 Products shall not exceed the maximum levels of primary pathogens as follows:
                         - Salmonella: absent in 50 g
                         - E.coli: < 1 000 MPN/g (MPN: most probable number).
                       11 In the final product, the content of weed seeds and the vegetative reproductive parts of aggressive weeds
                         shall not exceed two units per litre.
                       12 Dutch legislation is currently under review. At the moment it is not decided whether this revision shall
                         include the requirements regarding heavy metals.



SV&A sustainability consultants
Chapter 2 - Soil Improvers                                                                                                 11




Table 2.3.2         Heavy metal limits in the EU(mg/kg dry matter)
Country              Quality Standard of                 Cd       Cr         Cu        Hg       Ni        Pb           Zn
Austria              Biowaste Ordinance Class A           1       70         150       0,7      60        120         500
Belgium/Fl           Agricultural Ministry               1,5      70         90         1       20        120         300
Denmark              Agricultural Ministry               0,4       -        1000       0,8      30        120         4000
Germany              Biowaste Ordinance Type II          1,5      100        100        1       50        150          400
Ireland              Draft                               1,5      100        100        1       50        150         350
Luxembourg           Environmental Ministry              1,5      100        100        1       50        150         400
Netherlands          Agricultural Ministry - BOOM         1       50         60        0,3      20        100         200
Spain (Cata.)        Class A (draft)                      2       100        100        1       60        150          400
Sweden               Quality assurance organisation       1       100        100        1       50        100         300
UK                   TCA Quality Label                   1,5      100        200        1       50        150          400
EU-Eco-label*                                             1       100        100        1       50        100         300
* and Mo 2, Se 1,5, As 10 and F 200 mg /kg dm only for products containing material from industrial production



                    Austria and Denmark are the only countries that have established limit values for
                    organic contaminants. Most quality standards prohibit the acceptance of organic waste
                    in case a more than average contamination can be suspected or observed.

Discussion          Voluntary or legal national criteria for heavy metals and/or other contaminants in
                    soil improvers are not always in line with the limit values of the European Eco-
                    label. Is this a reason for adjusting the existing criteria?


2.4                 Markets and applications


Table 2.4.1         Compost sales and market shares in the EU (status 1999 to 2001)
                             AT           BE       D     DK           NL     IT       LUX     FR              Total
                 x 1000 M g 2000         2000     1999  2000         2001   2001      2000   2000      abs            %
Lands caping                 102          101             47          82     119        6     156       612            8
Landfill + Res toration        -           8        925   50           -                                983           14
A griculture                 102                   1591   43          615    261       9      426      3082           43
                                           35
Horticulture                  34                   185    29           -                       41       289            4
Earth works                   17           137     370     -           -                      123      1026           14
                                                                             379
Privat gardens                68            74      518  155          82               4                901           12
Export                                      20       -     -          41                                61             1
M is cellaneous              17             16     111    36           -      32       2      74        287            4
Total volume (M io. M g/y)        0,34    0,39     3,7     0,36      0,82    0,79     0,02   0,82      7,24           100


                    The table indicates that most compost is still used in applications with relatively low
                    market value - in agriculture, in earth works and landscaping. Relatively low volumes
                    (in particular green compost) are applied in upmarket applications such as the
                    production of high quality top soils or as constituent in growing media. See also:
                    [Klasmann 2003].

                    In the Netherlands, a research project was carried out investigating the options to
                    upgrade biomass for large scale application in growing media. The main hurdle was the


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12                       ESG 02-6; Revision European Eco-label Criteria Growing Media and Soil Improvers - background document phase 1




                       necessary reduction in electro conductivity (i.e. the need to reduce salt levels). An
                       extensive survey of existing and expected techniques did not identify feasible solutions
                       offering a promising perspective in terms of costs and reliability [RHP 2004].




SV&A sustainability consultants
Chapter 3 -Growing media                                                                                    13




3                  Growing media
3.1                Introduction

                   Definition: growing media are materials, other that soils in-situ, in which plants are
                   grown.

                   Growing media perform two functions; they provide a physical structure in which
                   plants can root. In addition they facilitate the water-gas system in the root environment
                   (including the uptake of nutrients and trace elements). Nutrients and trace elements can
                   be an intrinsic part of the growing medium, but in most cases they are applied separate-
                   ly.

                   Growing media have two main areas of application; the professional and the hobby
                   market.

Professional       In the professional market, growing media are applied on a large scale in soil-less food
                   cropping (mainly greenhouse fruit vegetables such as tomato, cucumber, sweet pepper
                   and strawberry) and in the production of cut flowers and plants. In comparison to in-soil
                   cropping, the use of growing media can have a number of substantial economic and
                   environmental benefits - no need for soil decontamination, better utilization of nutrients,
                   lower energy consumption, higher yields. These benefits contribute to an ongoing
                   increase in soil-less horticulture throughout Europe (see also § 3.4 - page 16).

Hobby              In the hobby market, growing media are better known as potting soil, used in- and
                   outdoors to grow pot plants.

                   The total volume of growing media consumed annually in the EU (hobby and
                   professional) is estimated to be some 20 - 30 million m3. The hobby market accounts
                   for some 11 - 16 million m3 (average 25 - 35 l/capita/yr) [estimate based on Bohlin].
                   Professional applications consume volumes in the same order of magnitude. A more
                   detailed overview is given in § 3.4 - page 16.

                   There is a broad spectrum of growing media available. Worldwide, peat based growing
                   media cover some 85 - 90% of the market [Bohlin, WU 2002 - p53]. Other materials
                   applied are composts, synthetics and a wide range of natural organic products and
                   minerals (see table 3.1.1 for an overview).




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14                         ESG 02-6; Revision European Eco-label Criteria Growing Media and Soil Improvers - background document phase 1




Table 3.1.1            Overview growing media
product group                                          description                                product
           peat based growing media                    at least half the organic matter inpeat (> 90 vol% peat )
 Organic




                                                       the product is peat                peaty GM (> 50 vol% peat))
           compost                                     product of meso- or thermofile     bio waste compost
                                                       treatment of organic material      green waste compost
                                                                                          composted bark
           synthetic organic products                  product of resinating or           phenol resin
                                                       polymerisation of organic          ureumformaldehyde foam
                                                       molecules                          poly-urethane foam
           other organic products                                                         wood fibre
                                                                                          wood dust
                                                                                          wood chips
                                                                                          bark
                                                                                          coir
                                                                                          jute fibre
                                                                                          flax fibre
                                                                                          rice hulls
           mineral wool                                product of spinning and processing stone wool
 Mineral




                                                       of mineral wool                    glass wool
           granular minerals (unprocessed)             granulated natural minerals        pumice
                                                                                          lava
                                                                                          sand
           granular minerals (processed)               minerals that have been processed perlite
                                                       in such a way that their chemical  vermiculite
                                                       or physical structure has been     expanded clay granules
                                                       changed.
Source                 [CEN 1999]



3.2                    Production

                       Growing media production processes are as diverse as the materials used. Various types
                       of peat are harvested on numerous locations and mixed in various grains with additives
                       such as clay, sand, wood fibre and coir. Organic waste is composted in open air or in
                       closed composting facilities. Perlite is produced by heating perlite ore mined in Greece
                       at a temperature of nearly 1000 °C. Stonewool is the product of spinning a melt of
                       diabase (dolerite), basalt and various additives, and coir is imported from countries such
                       as India and Sri Lanka and washed and buffered in the countries of origin or inside the
                       EU.

                       In general, production can be divided into two clusters;
                       •   Large scale industrial production (high capital intensity), mainly stonewool and other
                           processed minerals and synthetics,
                       •   Medium/small scale production (lower capital intensity); most natural organic
                           growing media13.

                       Organic growing media usually are a blend of materials (or formulations). The chosen
                       mix determines to a high degree the suitability of a growing medium in a specific


                       13 Usually the production of raw materials (peat extraction, mining) is large scale.



SV&A sustainability consultants
Chapter 3 -Growing media                                                                                    15




                   application and offers the producer the flexibility to adapt to fluctuations in raw
                   materials supplies (price and availability).

                   Composts and rice hulls are always derived from waste. Both materials are used as co-
                   constituents in growing media. For composts, various studies indicate maximum
                   feasible levels of some 20 - 40 vol% [bgk 2001, Remake 2001 - p11, Vlaco 2001 - p24,
                   EPEA 2004 - p1] but higher percentages have been reported as well [WRAP 2004 p40,
                   41].

                   A number of other materials -wood products and coco products- can be derived from
                   waste, but are often also produced from virgin material specifically for the application
                   in growing media.

                   All major materials and production processes have been recently submitted to Life
                   Cycle Analysis (LCA - see § 4.9 - page 26).


3.3                Quality control and certification

                   The suitability of the product for specific applications (quality and safety) is always an
                   important environmental issue; the environmental inputs of products which are not fit
                   for use are by definition lost (initial environmental damage). In the case of growing
                   media and soil improvers, lacking product quality easily leads to damage inflicted on
                   plants or crops (secondary environmental damage). In most cases, this secondary
                   damage amounts a multitude of the initial damage. This is due to the fact that the
                   environmental impact linked to the production of growing media is adding only a few
                   percent to the total environmental impact of the production of plants and crops [SMK
                   1999 - p30]. Quality requirements could therefore be seen as key environmental criteria.

                   In the EU, there are currently five known Quality labels for growing media:
                   •   CAS (France);
                   •   BECAS (Belgium). Both CAS and BECAS assure that certified products meet legal
                       requirements;
                   •   RAL/GGS (Germany and German speaking countries); a product certificate based on
                       legal standards and a number of additional requirements regarding the end product;
                   •   RHP (Netherlands); a product certificate which focuses on the entire production chain
                       (including the retrieval and transport of raw material);
                   •   and recently introduced: KIWA (Netherlands); a product certificate primarily
                       focussing on mineral growing media.

                   All quality labels typically have some 40 - 60 applicants14, mainly in their home
                   markets, but also abroad. In the countries mentioned above, the market share of
                   certified professional products is high (60 - 70%). In the hobby market, the market
                   share of certified products is much lower (30%?).


                   14 the number of KIWA licence holders is 2.



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16                       ESG 02-6; Revision European Eco-label Criteria Growing Media and Soil Improvers - background document phase 1




                       In countries without a ‘national’ quality mark, the market share of certified products is
                       much lower. However, most major, internationally active suppliers deliver under one of
                       the quality labels mentioned above. In view of the ongoing internationalisation, and
                       concentration in the sector, it is expected that the market share of certified products will
                       continue to grow in the coming years.

                       Many of the current Eco-label criteria regarding the functional quality of growing
                       media originate from the original set of criteria (published in 1998) which applied to
                       Soil Improvers only. In general, it could be questioned whether it is realistic to use one
                       single set of criteria for the functional quality of both soil improvers and growing
                       media. Furthermore, it could be questioned whether a number of the criteria -in
                       particular those protecting the environmental quality of the soil- are relevant or
                       applicable to Growing Media. These include the criteria concerning hazardous
                       substances, physical contaminants and nutrient loadings.

Discussion             Quality certification is of eminent importance to the sound application of growing
                       media, also from an environmental point of view. The current ‘quality criteria’ in
                       the European Eco-label for SI and GM contain requirements for physical contami-
                       nants15, product performance16, health and safety17, seeds and propagules18, and
                       EC19. Are these requirements complete and effective (for growing media) and/or
                       could it be desirable and feasible to refer to existing quality labels in order to
                       secure product quality.


3.4                    Markets and applications

                       A rough estimate of the European market for growing media (professional and hobby)
                       including an indication of the market shares of the various products is given by table
                       3.4.1 on the next page. We expect to receive additional information on this subject on
                       short notice.




                       15 In the final product (with mesh size > 2 mm), the content of glass, metal and plastic shall be lower than
                         0,5 % as measured in terms of dry weight.
                       16 (a) Products shall be supplied in a solid form and contain not less than 25 % dry matter by weight and
                         not less than 20 % organic matter by dry weight (measured by loss of ignition).
                       (b) Products shall not adversely affect plant emergence or subsequent growth.
                       (c) Products shall not give rise to offensive odours after being applied to the soil.
                       17 Products shall not exceed the maximum levels of primary pathogens as follows:
                         - Salmonella: absent in 50 g
                         - E.coli: < 1 000 MPN/g (MPN: most probable number).
                       18 In the final product, the content of weed seeds and the vegetative reproductive parts of aggressive weeds
                         shall not exceed two units per litre.
                       19 The electrical conductivity of the products shall not exceed 1,5 dS/m.



SV&A sustainability consultants
Chapter 3 -Growing media                                                                                                                       17




Table 3.4.1        Market overview substrates
                                                                    Estimated substrate consumption                      Peat based
Substrate areas (hectares)
                                                                            (x1,000 m3/y)*                              (x1,000m3/y)




                                                    Substrate (%)




                                                                                                                  professional
                                      In soil (%)
                         Vegetables




                                                                     stonewool




                                                                                           pumice
                                                                                 perlite




                                                                                                                                       hobby
                                                                                                    foam

                                                                                                           coir
Market
Benelux                 5.500           27            73             435          35        10       8      8     3000               700
France                  2.000           50            50             94           6                                800              1000
Germany                  180            58            42              7                                           3100               900
UK                                                                                                                1100              1900
Scandinavia               470          15             85             38                                            900              1300
Austria                   400          88             13              5                                     1      300               100
Spain                   35.000         90             10             306          88                        9      600               800
Italy                   19.000         97              3             47           9                         1     2100               800
Greece                  12.500         99              1
Poland                   5.100         88             12
Hungary                  4.000         95              5
Bulgaria                  700         100
Others                 unknown
Total (known)           84.850         88             12             930         140                       30      20,000 - 30,000
Remark             The overview was compiled by adding information retrieved from various sources.



                   The market overview indicates the following:
                   •   in many crops, soil-less horticulture has become more or less standard practice in
                       Scandinavia, the Netherlands, Belgium and to a lesser extent also in France and
                       Germany. Southern Europe is a growth market showing large potential due to its vast
                       areas of greenhouse cropping. The volumes growing media applied in Southern
                       Europe have risen considerably over the last five years;
                   •   peat based growing media are by far the most widely used. Stonewool and perlite
                       come second and third with volumes that do not nearly match the volume of peat, but
                       are still considerable and growing.

                   Note: Coir (and many other products such as compost, wood products and rice hulls) is
                   primarily applied as co-constituent in growing media formulations and not so much as a
                   pure growing medium. This is illustrated by the fact that the total annual consumption
                   of the European growing media industry of coir is estimated to be some 450,000 m3 (as
                   compared to the use of 30,000 m3 as a pure substrate).

                   In § 4.4 (page 21), an assessment will be made of the possible inclusion of non organic
                   growing media in the European Eco-label for SI and GM.




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18                                ESG 02-6; Revision European Eco-label Criteria Growing Media and Soil Improvers - background document phase 1




                                 A market study carried out by the International Peat Society (IPS) [Bohlin], shows the
                                 market shares of the various types of constituents as displayed in figure 4.3.120.


Figure 4.3.1                       Market share of different constituents in growing media [Bohlin]


                                                                                                            peat
                                                                          84,9%
                                                                                                            other organic
                                                                                                            composts
                                                                                                            sand, clay, perlite, etc
                                                                                                            mineral wool, foam




                             3,5%
                                    3,2%
                                            4,2%
                                                      4,2%



                                 Figure 4.3.2 shows the large variations between countries in the consumption of
                                 growing media per capita. The differences can be explained by the size and structure of
                                 professional horticulture (with the Netherlands in the lead with large areas of soil-less
                                 cultures) and by differences in consumer behaviour (showing a relatively high
                                 consumption of potting soil in the Scandinavian countries and the UK).


Figure 4.3.2                     Annual consumption of growing media per capita [Bohlin]

                           250

                           200
          litre/capita/y




                           150
                                                                                                                               Professional
                           100                                                                                                 Hobby

                           50

                            0
                                   NL         DK           FI          SE         DE          GB          FR




                                 Over the last decade, the peat content in peat based growing media has been decreasing
                                 steadily. This subject will be looked into in more detail in § 4.5 (page 22).




                                 20 covering the annual consumption of growing media in Netherlands, Denmark, Finland, Sweden,
                                   Norway, Germany, UK and France (total 16 million m3)

SV&A sustainability consultants
Chapter 4 -Focal points                                                                                         19




4                    Focal points
4.1                  Introduction

                     In 2001 it was decided that on the occasion of the next revision, particular attention
                     should be paid to the following issues:
                     •    The possible use of sewage sludge in this product group;
                     •    Reassessment of criteria if incompatible with national legislation e.g. heavy metals;
                     •    Evaluation of other growing media;
                     •    Reassessment of the use of peat;
                     •    Completion of this product group by other appropriate sub-product groups e.g.
                          humifying eco-systems, organic fertilisers;
                     •    Packaging;
                     •    Reassessment of nutrient loadings.

                     These points are elaborated below. In addition, some special attention is paid to the
                     availability of updated Life Cycle Inventories for the product group, and to experiences
                     Competent Bodies and current licence holders with the existing criteria.


4.2                  Sewage sludge

                     Note: after composting (sewage sludge or sewage sludge in combination with other
                     waste streams), sewage sludge or products derived from sewage sludge can already
                     apply for the current European Eco-label for SI and GM. Composting is an effective
                     way to improve the properties of sewage sludge, both in terms of sanitation and in
                     transforming nitrogen to slowly releasing forms.

                     Sewage sludge is a by-product from sewage plants treating domestic or urban waste
                     waters, septic tanks and so on. The progressive implementation of the Urban Waste
                     Water Treatment Directive 91/271/EEC in all Member States is increasing the
                     quantities of sewage sludge requiring disposal. From an annual production of some 5.5
                     million tonnes of dry matter in 1992, the Community is heading towards nearly 9
                     million tonnes by the end of 2005. In Europe around 45% is currently recycled to
                     agricultural land, 18% is landfilled and 17% is incinerated [EU 2003].

                     There are different forms of sludge, from low dry matter slurries to semi-solid cake and
                     granules. Treated sewage can be spread on land, where it can supply nitrogen,
                     phosphorous and some potassium and sulphur. It can potentially be dried and
                     combusted, anaerobically digested or co-composted with biomass crops, straw, wood-
                     chips etcetera. However, sewage sludge may also contain toxic elements such as heavy
                     metals and pathogens like E.coli and Salmonella.

                     The Sewage Sludge Directive 86/278/EEC seeks to encourage the use of sewage sludge
                     in agriculture and to regulate its use in such a way as to prevent harmful effects on soil,
                     vegetation, animals and man. To this end, it prohibits the use of untreated sludge on


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20                       ESG 02-6; Revision European Eco-label Criteria Growing Media and Soil Improvers - background document phase 1




                       agricultural land unless it is injected or incorporated into the soil. Treated sludge is
                       defined as having undergone "biological, chemical or heat treatment, long-term storage
                       or any other appropriate process so as significantly to reduce its fermentability and the
                       health hazards resulting from its use". Restrictions are included for the application of
                       (untreated) sewage sludge on grassland to be grazed and soil in which crops are grown.

                       The Sewage Sludge Directive is currently under revision. The revision was announced
                       in the Communication “Toward a Thematic Strategy on soil protection” (COM(2002)
                       179). It is a first step in the development of an encompassing EU policy to protect soils
                       against erosion and pollution. On sewage sludge it states: ‘Provided that contamination
                       is prevented and monitored at source, the careful and monitored use of sewage sludge
                       on soil should not cause a problem, and, indeed, on the contrary could be beneficial and
                       contribute to an increase of soil organic matter content. [EU 2002/2, p14]’.

                       In general there is ongoing discussion and concern on a number of topics.
                       1) The application of sewage sludge should not inflict nutrification of the soil. Whether
                          this will be the case also depends on possible changes in the criteria for nutrient
                          loadings21.
                       2) The functional quality of the product should be guaranteed (i.e. free of pathogens
                          etcetera). It is not clear whether quality labels accommodate the certification of
                          sewage sludge or products derived from sewage sludge in a sufficient way or when
                          such systems will become available. This will be subject to further investigation.
                       3) Any environmental hazards should be excluded, meaning that the product should
                          comply with the requirements on heavy metals and other contaminants that apply
                          also to the other soil improving products.

                       According to the information provided by Member States on the implementation of the
                       Sewage Sludge Directive 86/278/EEC for the period 1998-2000, weighted average
                       heavy metal concentrations in sewage sludge were as follows (1999):


Table 4.2.1            Heavy metals in sewage sludge (mg /kg dry matter; EU - 1999)
 Heavy metal                            Sewage sludge                            European Eco-label limit values
 Cd (cadmium)                               2.0                                                1
 Cr (chromium)                               73                                              100
 Cu (copper)                                330                                              100
 Hg (mercury)                               1.5                                                1
 Ni (nickel)                                 36                                               50
 Pb (lead)                                  104                                              100
 Zn (zinc)                                  811                                              300
[EU 2003 - p12]




                       21 Furthermore, the inclusion of sewage sludge, being in character more related to organic fertilisers than
                         to composts, would probably be more straightforward in case the focus of the product group would be
                         broadened to fertilisers (see § 4.6 - page 23)



SV&A sustainability consultants
Chapter 4 -Focal points                                                                                       21




                     On Cd, Cu and Zn, these values are clearly above the current limit values in the
                     European Eco-label criteria for SI and GM. The current limit values for heavy metals in
                     the Sewage Sludge Directive 86/278/EEC are identified as one of its weaknesses [EU
                     2003 - p14-15]: ‘Although reaching the upper threshold limits for heavy metal concen-
                     trations in agricultural soil … does not pose any immediate risk to human and animal
                     health, these upper limits do not seem to be protective enough for soil quality in the
                     long term.’

                     4) And evidently, the admittance of sewage sludge should not conflict with EU legis-
                        lation or any national legislation or policies in the member states.

                     A concise overview on this latest issue is given in ‘Disposal and Recycling Routes for
                     Sewage Sludge’ [EU 2002]. Based on an analysis per country, it is concluded that
                     National regulatory requirements vary greatly from one country to another. In this area,
                     national regulations, based on the same scientific grounds, should be considerably
                     improved by the next Directive on sludge use, in order to provide long-term perspec-
                     tives for the use of sludge. With regard to increasing confidence in the use of sludge,
                     standardisation initiatives (continuation and completion of CEN TC 308 work on the
                     production and disposal of sewage sludge) have a major role to play.

                     It is also concluded that the current state of the debate on sludge recycling and disposal
                     routes clearly shows that the current uncertainties over possible risks for human health
                     and for the environment play a major part in the resistance against expanding various
                     sludge recycling routes. The areas where scientific results are the most expected are
                     possible effects of organic pollutants and pathogens in sludge.

                     In all areas mentioned above, much research has been performed over the last few years
                     and much research is still in progress.

Discussion           In view of the above, in particular (i) the EU Thematic Strategy for Soil Protection
                     and (ii) ongoing research on various issues regarding the beneficial application of
                     sewage sludge: should the possible inclusion of sewage sludge be elaborated in
                     phase 2?


4.3                  National legislation

                     See ‘contaminants’ on page 10.


4.4                  Other growing media

                     The history of the European Eco-label for Soil Improvers (with Growing Media added
                     later) explains why the initial focus was on the inclusion of organic growing media,
                     leaving the other types of growing media more or less out of consideration. This is also
                     expressed by the aim of the European Eco-label for SI & GM: to promote ‘the use
                     and/or re-use of organic matter derived from the collection and/or processing of waste
                     material’.




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22                       ESG 02-6; Revision European Eco-label Criteria Growing Media and Soil Improvers - background document phase 1




                       As was illustrated earlier, next to organic growing media there are a number of other
                       types of growing media available; synthetic and processed and non-processed minerals
                       (see the table on page 14). Their functional characteristics have provided them consi-
                       derable market shares in various markets and applications. At the same time, updated
                       Life Cycle Inventories are available to assess the environmental properties of these
                       growing media (see also § 4.9 - page 26).

                       Retail quality standards such as EurepGap increasingly call for independent ecological
                       criteria which are internationally accepted. Keeping the European Eco-label restricted to
                       organic growing media, could create the impression that the environmental quality of
                       organic growing media is (by definition) superior to other types of growing media, and
                       could therefore lead to market distortion.

Discussion             Should the possibility of admitting hybrids22 and non-organic growing media be
                       elaborated in phase 2?


4.5                    Reassessment of the use of peat

                       In a number of European countries and over a longer period of time, there has been a
                       vivid public discussion about the use of peat in soil improvers and growing media (and
                       other applications). The current European Eco-label for SI & GM states that growing
                       media shall not contain peat or any products derived from peat.

                       At the end of the 1990’s, industry, environmental organisations and government in the
                       UK jointly agreed to reduce the use of peat in growing media and soil improvers with
                       40% in 2005 and 90% in 201023. From the outset it was clear that a large part of this
                       substitution objective would be achieved in less critical applications such as soil impro-
                       vers and mulch.

                       In response, the horticultural sector indicates that short term large scale substitution of
                       peat in professional applications will lead to high costs (due to more expensive raw
                       materials) and loss of efficiency in cropping (loss of quality, less yield) [PPA 2000].

                       This however has not refrained large retailers such as B&Q and Homebase to launch far
                       reaching objectives in peat reduction in their potting soil assortment (B&Q for example
                       85% in 2006) [B&Q 2003]. At the same time, substitution of peat being part of their pot
                       plants proves much more difficult. Substitution rates show large variations depending
                       on grower and cultivar [Marks and Spencer 2004].

                       This suggests clear differences in substitution rates and levels between the professional
                       and the hobby market. In their report ‘Peatering Out - towards a sustainable UK
                       growing media industry’ environmentalists conclude as follows: ‘Peat replacement in
                       horticulture will best be achieved by a period of progressive dilution of peat products
                       rather than by an abrupt changeover.’ and ‘Specifications are required to manufacture
                       professional products to the highest standards and consistency. Growers need to have

                       22 Hybrids meaning mixtures of different types of growing media.
                       23 In hobby gardening, landscaping and professional horticulture.



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Chapter 4 -Focal points                                                                                                      23




                     thorough confidence, knowledge and familiarity with materials before they will use new
                     materials for commercial crops, on which their livelihood depends24’ [RSPB 2002].

                     Green compost, wood products (fiber, chips and bark) and coir products are seen as the
                     most promising materials to substitute peat. It is however widely accepted that in
                     particular in professional applications, peat will continue to be a key constituent for
                     high quality growing media for years to come. In fact, many peat substitutes have
                     gained market access due to their combined application with peat in potting soil
                     formulations; ‘alternative’ growing media work best when they contain an element of
                     peat [WU 2002 -p53].

                     There are also some important developments regarding peat extraction. Under the
                     RAMSAR convention25, guidelines have been developed for a sustainable or wise use
                     of peatlands, meaning ‘the use in a way and rate that meets current needs without
                     damaging the opportunities of future generations to fulfill their needs’. The wise use
                     guidelines have been developed by the IMCG26 in cooperation with the IPS27. A model
                     has been developed that balances the various interests linked to a certain use of a
                     peatland (including conservation / non use). In this, the intrinsic (nature) values of the
                     peatland are also taken into consideration [WU 2002].

Discussion           In view of these developments, should the reassessment of the use of peat be
                     continued in phase 2?


4.6                  Broadening the product group

                     A special point of attention is a possible expansion of the product group by other
                     appropriate sub-product groups, in particular humifying eco-systems and organic
                     fertilisers.

                     Humifying agents are substances that support the humifacation processes in the soil.
                     Humification can be defined as the process whereby the carbon of organic residues in
                     the soil is transformed and converted to humic substances through biochemical and
                     abiotic processes. In a way, the stable organic matter supplied by soil improvers provide
                     the feedstock for the humification process. This humification process is very complex
                     and to a large degree still unexplored.

                     The effects of humic substances on plants have been extensively studied. Humic
                     substances are renowned for their ability to:
                     •    chelate soil nutrients (organics and trace elements);

                     24 Peatering Out presents a scenario that would end the commercial use of peat in the UK in 10 years.
                     25 The Convention on Wetlands, signed in Ramsar, Iran, in 1971, is an intergovernmental treaty which
                       provides the framework for national action and international cooperation for the conservation and wise
                       use of wetlands and their resources. There are presently 144 Contracting Parties to the Convention, with
                       1420 wetland sites, totalling 123.9 million hectares, designated for inclusion in the Ramsar List of
                       Wetlands of International Importance. www.ramsar.org.
                     26 International Mire Conservation Group - focus on nature conservation.
                     27 International Peat Society - focus on peat utilisation.



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24                         ESG 02-6; Revision European Eco-label Criteria Growing Media and Soil Improvers - background document phase 1




                       •   improve nutrient uptake, especially phosphorous, sulphur and nitrogen;
                       •   reduce the need for nitrogen fertilization;
                       •   remove toxins from both soils and animals;
                       •   stimulate soil biological activity;
                       •   improve soil structure;
                       •   buffer N, P, S and Zn;
                       •   improve water-holding capacity.

                       Humifying substances are sometimes also indicated as ‘soil conditioners’. The function,
                       working mechanisms, chemical content and application of humifying materials differs
                       from the soil improvers currently included in the European Eco-label for SI & GM. The
                       same applies to (organic) fertilizers. One could say that stable organic matter, humifica-
                       tion and fertilization are three complementary chapters in the story of plant nutrition.

                       Expanding the scope of the criteria to humifying substances and fertilizers could
                       therefore seem a logical step ahead to complete the product group. However, the
                       question should be asked in what way these sub-groups contribute to the current aims of
                       the European Ecolabel for SI & GM and/or if these aims should be revised. Also, the
                       differences in function, content and application (including topics such as certification
                       and legislation) would most likely require the development of two additional sets of
                       Eco-label criteria.

Discussion             In view of the above; should the scope of the European Eco-label for Soil
                       Improvers and Growing media be expanded to humifying substances and
                       (organic) fertilizers?


4.7                    Packaging

                       Possible changes on the information accompanying the product (on packaging or fact
                       sheet) largely depend on the deliberations on the other topics mentioned in this
                       document.


4.8                    Nutrient loadings

                       Almost all soil improvers contain nutrients (N, P, K); as intrinsic part of their raw
                       materials or by added synthetic or organic nutrients. Depending on the origins of the
                       nutrients, they will be released to the environment sooner of later. This means that
                       repeated application of soil improvers may lead to overfertilisation (or eutrophication).
                       In order to prevent this, the current European Eco-label for SI and GM maximizes the
                       contents of N, P and K.

                       The actual nutrient load generated by a soil improver is primarily determined by a
                       combination of two factors:




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Chapter 4 -Focal points                                                                                                      25




                     •    nutrient content - the total amount of N, P2O5 and K2O contained by the soil improver.
                          Nutrient content is the product of nutrient concentration (g/kg d.m.) and dosage
                          (litre/m3);
                     •    nutrient release - the speed with which the nutrients are released to the environment28

                     In order to prevent overfertilisation, the current European Eco-label criteria follows
                     both routes (content and binding) by setting the following criteria:

                     (a) The concentration of nitrogen in the product shall not exceed 2 % total N (of dry
                     weight) and inorganic N must not exceed 20 % total N (or organic N ≥ 80 %).

                     (b) When used at the rates of application as recommended in the information provided
                     with the product, the product shall not exceed maximum nutrient loadings of:
                     — 17 g/m2 total nitrogen
                     — 10 g/m2 P2O5
                     — 20 g/m2 K2O

                     Note: This requirement does not apply to products where less than 10 % (w/w) of the
                     nutrient content is available for plant growth during the first season of application.
                     Such products (for example many mulches) are defined as those having a C:N ratio
                     greater than 30:1.

                     The nutrient loading that are mentioned (17/10/20 g/m2) are based on ‘good agricultural
                     practice’ that leads to balanced fertilisation in the most sensitive soil types29.

                     There is currently some discussion on this matter:
                     •    the distinction between organic and inorganic (mineral) N is not the whole story;
                          organic N is not by definition a ‘slow’ fertilizer. Decisive is the amount of stable
                          organic matter as part of the total content of organic matter. For most regular soil
                          improvers including composts and mulches these data are available;
                     •    some products with a C:N ratio greater that 30 do release considerably more nutrients
                          in the first year of application than the 10% of their contents mentioned in the criteria.
                          This applies in particular to the release of P2O5 and K2O. The absence of a ‘recom-
                          mended application rate’ in this product group may therefore foster overfertilisation;
                     •    application of the criteria would in many cases lead to a ‘recommended application
                          rate’ that is far below application rates that are common in every day practice (for
                          example 3 litre / m2 equalling a layer of 3 mm, where a dosage of 20 litre is more
                          common) [Smith 1997]. Applications in such a low dosage will add so little organic
                          matter to the soil that the application will hardly have any effect.




                     28 If nutrification actually takes place again depends -next to the nutrient load- on a complex combination
                       of factors such as soil type and soil condition, nutrient uptake by plants, water dosage and ground water
                       level.
                     29 fertilisation that leads to an equilibrium between intake and excretion of nutrients.



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26                         ESG 02-6; Revision European Eco-label Criteria Growing Media and Soil Improvers - background document phase 1




                       A possible way ahead may be to let go of the 30:1 criterion and to determine the
                       ‘recommended application rate’ on the actual release of nutrients in the first year of
                       application. Release rates can be retrieved from literature. In consultation with the
                       AHWG, a standard set of release rates (per type of soil improver) could be compiled in
                       phase 2;

Discussion             Should further research on nutrient loadings be part of phase 2?


4.9                    Life cycle assessments

                       Already in 1993, prior to the release of the original criteria for the European Eco-label
                       for GM & SI, a first screening was carried out of the environmental properties of
                       various materials. Due to the wide spread of materials and the lack of comprehensive
                       quantitative information, several parts of the survey obtained an exploratory and
                       qualitative character.

                       In 1999, the Dutch Competent body (SMK) started research on a national environ-
                       mental label for growing media [SMK 1999]. As part of this research, the environ-
                       mental information on the various products was updated and elaborated in LCA-format.

                       During the recent revision of the SMK-criteria, the LCAs were updated and extended
                       again. In addition, extensive LCAs have been performed as input for the environmental
                       classification module under development by the RHP foundation (see the text frame
                       below). As part of these activities, special attention was given to environmental inputs
                       for which an LCA is less suited, in particular the impact on biodiversity and other
                       ecological values due to the extraction of raw materials (peat, minerals and others).


‘BasiQ Green’; the environmental classification system under construction by the RHP-foundation
 ‘BasiQ Green’ is the name of the classification system that expresses the environmental quality of RHP-certified
 growing media. It is currently under construction. It intends to offer producers and (professional) users
 transparency about the environmental quality of a particular substrate.
 Depending on their environmental profile, growing media are appointed an A, B or C classification. This
 classification is based on clear and public criteria. The criteria applied are partly quantitative, partly qualitative.
 The quantitative criteria are based on LCA’s (lifecycle analyses) which have been made for all major raw
 materials and additives.
 The qualitative criteria address aspects that are hard to quantify, but are nevertheless environmentally relevant,
 such as the level of environment management in the various stages in the production chain (including end-of-
 life).



                       For the following materials LCAs are now available (in alphabetical order):
                       •   (composted) bark;
                       •   coco (dust, coir, chips, blocks);
                       •   composted organic matter (green waste, household green waste collection);
                       •   expanded clay granules;



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Chapter 4 -Focal points                                                                                                         27




                     •    various types of peat;
                     •    perlite / vermiculite;
                     •    pumice;
                     •    rice hulls;
                     •    stonewool;
                     •    wood fibre;
                     •    various additives such as sand, clay and fertilizers.

                     The data are structured in such a way that the environmental profile of single materials
                     as well as product mixtures can be assessed. The LCAs have been performed and docu-
                     mented in conformity with SETAC principles, meaning that objectives, functional unit,
                     system boundaries, sources, assumptions and sensitivity analyses have been defined and
                     administrated in a standard manner30.

                     The LCAs show distinct differences in the environmental profiles of the various
                     materials. Some general outcomes:
                     •    in almost all materials, transport throughout the production chain contributes
                          considerably to the overall environmental profile (positive for some waste derived
                          materials and minerals);
                     •    peat scores considerably above average on the emission of greenhouse gasses. A
                          survey on the state of art in science on how to calculate and allocate these greenhouse
                          emissions was part of the study;
                     •    various realistic formulations of growing media (including some ‘reduced peat’
                          mixtures31) have an environmental profile that is considerably better than market
                          average.

                     At present, all LCAs are based on production and application in Northern European
                     markets (including of course transport of raw materials to the production location and
                     distribution to the end user). In order to put things into a European perspective,
                     transport distances and modalities should be transformed to a sort of European
                     average32. Due to the structure of the database, this operation could be executed easily.




                     30 SETAC; The Society of Environmental Toxicology and Chemistry; an international scientific network
                       leading in standardising LCA-practices.
                     31 Mixtures of peat and alternative materials are receiving increasing market acceptance in professional
                       horticulture, thus creating a growing market for these alternatives - see also the remarks on this issue on
                       page 23.
                     32 For example: the average transport distance of perlite-granule from the mine in Greece to the perlite
                       factory elsewhere in Europe is ….km.



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28                         ESG 02-6; Revision European Eco-label Criteria Growing Media and Soil Improvers - background document phase 1




4.10                   Experiences with the current criteria

                       The experiences gathered by the Competent Bodies with the current criteria show the
                       following picture (we expect to receive additional information shortly).

                       In general:
                       •   in particular in France and Denmark there is satisfactory market response in the sub-
                           group of Soil Improvers;
                       •   there have been no applicants for Growing Media so far.

                       Since there have been no awards for Growing Media, no experiences with the certifi-
                       cation of this product sub-group have been collected. Some general remarks on this
                       issue were made on page 16.

                       Other specific remarks regarding the criteria:
                       •   in criterion 2, the sentence ‘products containing material from industrial processes’
                           may be clarified;
                       •   in criterion 3 (physical contaminants), additional information is welcome on the
                           required contents of the test report including test methods to be applied;
                       •   criterion 4b (nutrient loadings at recommended application rate) is being qualified as
                           ‘not suitable for use’. It is costly to prove a mineralisation rate. It would be welcomed
                           if the criteria would be more realistic / in touch with every day practice;
                       •   criterion 5b and 5c (adverse effects on plant growth and odour); references to
                           applicable test methods are welcome;
                       •   criterion 8a (organic part of growing media consists of soil improvers) is being quali-
                           fied as inappropriate / unjust. It denies the fundamental differences in functionality
                           between soil improvers and growing media. There is a call for allowing other products
                           as well (including peat) in order to be able to meet market demands.




SV&A sustainability consultants
Chapter 5 - References                                                                                   29




5                        References

ANPA 2000                Revision of Eco-label Criteria for Soil Improvers, Report Phase I, ANPA - Italian
                         Environment Protection Agency, Rome, November 2000.
BGK 2001                 Umweltpreis für Forschungsergebnisse zur Substitution von Torf durch Kompost,
                         Bundesgütegemeinschaft Kompost E.V. (BGK), 2001, www.bgkev.de.
Bohlin                   Bohlin, C., Data on the use of growing medium constituents, data collected for
                         the Horticultural Peat Working Group, International Peat Society, publication
                         date unknown (data concerning 1999, 2000 and 2001).
B&Q 2003                 B&Q Social Responsibility Factsheet Env. 03 - Peat and Growing Media, B&Q,
                         UK, 2003.
CEN 1999                 Kipp, J., personal information based on CEN TC223, August 20th 1999.
ECNweb 2005              Information retrieved from the internet site of the European Compost Network
                         (ECN); www.compostnetwork.info, 2005
                         This information was compiled by Mr Josef Barth (Informa Compost Consul-
                         tants), based on a number of sources including (1) M. de Groot: "Composting in
                         the European Union" - Report in assignment of the European Commission DG
                         XI., DHV, Amersfoort, The Netherlands, June 1997, (2) J. Barth, N. Zöller, H.
                         Stöppler-Zimmer: Quality assurance and regulations of composting and compost
                         application in five European countries. AFR report, Stockholm, Sweden, 1998,
                         (3) W. Bidlingmaier et al.: BioNet - Biological Waste Management in Europe,
                         www.bionet.net, 1998 and (4) information provided by the German Compost
                         Quality Assurance Organisation BGK.
EPEA 2004                Boden-, Ressourcen- und Klimaschutz durch Kompostierung in Deutschland,
                         EPEA Internationale Umweltforschung GmbH, Hamburg, April 2004.
EU 2001                  European Commission (2001) ‘Second Draft Working Document on the
                         Biological Treatment of Biowaste’.
EU 2002                  Aubain, F., et al., Disposal and Recycling routes for Sewage Sludge, Andersen /
                         SEDE, on behalf of the European Commission DG ENV, 22 February 2002.
EU 2002/2                Communication from the Commission, Towards a Thematic Strategy for Soil
                         Protection, COM(2002) 179, Brussels, 16.4.2002.
EU 2003                  Draft Discussion Document for the Ad Hoc Meeting on Biowastes and Sludges,
                         15-16 January 2004, DG ENV.A.2/LM, 18 December 2003.
Klasmann 2003            Presseinformationen - Weltweit erste Zertificierung für Substratcompost,
                         December 3rd, 2003, information retrieved from the internetsite of the Klasmann-
                         Deilmann-Gruppe, www.klasmann-deilmann.com,.
Marks & Sp 2004          Marks and Spenser, annual report on Corporate Social Reponsibility 2002-2003,
                         www.marksandspencer.com.
NMI 1999                 Evers, M., Concurrentiepositie van GFT-compost ten opzichte van andere
                         bodemverbeteraars, Nutriënten Management Instituut NMI b.v., Wageningen, NL,
                         December 1999 (vertrouwelijk).
RHP 2004                 Boon, H., personal communication, RHP foundation, Naaldwijk, NL, 2004.


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30                       ESG 02-6; Revision European Eco-label Criteria Growing Media and Soil Improvers - background document phase 1




PPA 2000                          Peat Producers Association (UK).
Remake 2001                       Robin, A., Use of Compost in Agriculture, A synopsis on behalf of The
                                  REMAKE Programme, Scottish Agricultural College, March 2001.
RSPB 2002                         Peatering Out - towards a sustainable UK growing media industry, English Nature &
                                  RSPB, UK, 2002.
Smith 1997                        Smith, G., et al., Revision of EC Eco-labelling Criteria for Soil Improvers: An
                                  Assessment of the Likely Impact of the Proposed Changes on Applications for
                                  the Award, Henry Doublesday Research Association, Ryton-on-Dunsmore,
                                  Coventry, UK, November 1997.
SMK 1999                          Aarts, R., Milieukeur substraat, onderzoek ten behoeve van het opstellen van
                                  Milieukeurcriteria, (Milieukeur growing media, research on behalf of the
                                  development of Milieukeur criteria) SV&A report no. msp/3-2, Leiden, NL,
                                  November 1st, 1999.
VLACO 2001                        VLACO’s activiteitenverslag 2001, Vlaamse Compostorganisatie, Mechelen,
                                  Belgium, 2001.
WRAP 2004                         Wallace, P, et al., To support the development of standards for compost by
                                  investigating the benefits and efficacy of compost use in different applications,
                                  WRAP - the Waste & Resources Action Programme, Barnbury, Oxon, UK, May
                                  2004.
WU 2002                           Joosten, H., and Clarke, D., Wise Use of Mires and Peatlands, International Mire
                                  Conservation Group and International Peat Society, 2002.




SV&A sustainability consultants
Annex I - Cross reference                                                                     I-1




Annex I: Cross-reference

Current criteria                                  This document (subject and page)
Scope and objectives                              History, p1
                                                  Product definition SI, p5
                                                  Stable organic matter, p5
                                                  Product definition GM, p13
                                                  Overview GM, p14
                                                  Sewage sludge, p19
                                                  Other growing media, p21
                                                  Reassessment of peat, p22
                                                  Broadening the product group, p23
                                                  Experiences, p28
1a     Waste derived organics                     Broadening the product group, p23
                                                  Other growing media, p21
                                                  Reassessment of Peat, p22
                                                  Experiences, p28
1b     No sewage sludge                           Sewage sludge, p19
2a     Heavy metals                               Contaminants, p10
2b     No bark treated with pesticides
3      Physical contaminants                      Quality criteria SI, p10
4      Nutrient loadings                          Quality criteria GM, p16
5      Product performance                        Sewage sludge, p19
6      Health and safety                          Broadening the product group, p23
7      Seeds/propagules                           Nutrient loadings, p24
8a     GM: Organics meet Soil Improver criteria   Experiences, p28
8b     GM: No peat                                Reassessment of peat, p22
                                                  Experiences, p28
8c     GM: EC                                     Quality criteria GM, p16
9      Information provided with the product
                                                  Packaging, p24
10     Information appearing on the Eco-label




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