”Resources should compete on quality – not origin”

How can Europe strengthen resilience, competitiveness and food security using resources that already exist within its own borders? That was one of the questions discussed when EU Commissioner Jessika Roswall invited selected stakeholders to Brussels for a roundtable on water resilience and circular resource use on 18 June. The following is an edited version of the remarks delivered by Pär Larshans, Chief Sustainability Officer at Ragn-Sells Group.

Commissioner Roswall, thank you for the invitation! In your letter, you describe water as a resource, as a carrier of resources and as an enabler of industrial systems.

We fully agree. At Ragn-Sells, we would even go one step further: wastewater is one of Europe's most significant untapped sources of strategic resources.

At a time when Europe is seeking to strengthen competitiveness, resilience and strategic autonomy, that is more important than ever.

The future of food security will depend not only on how we produce food, but also on how we recover and reuse the resources already flowing through our cities. As urbanisation continues, wastewater systems will become increasingly important not only for protecting the environment, but also for securing the nutrients needed for future food production.

In a circular economy, wastewater treatment plants can no longer be viewed solely as facilities for pollution control. They must increasingly become Resource Plants – facilities that not only clean water, but also recover nutrients, produce recycled water, generate energy and supply strategic resources.

The technologies needed for this transformation already exist. The challenge is increasingly regulatory, rather than technical.

Let me start with nitrogen.

The recently published EU Fertiliser Action Plan highlights the need to strengthen access to fertilisers while addressing affordability and reducing dependency on imported chemicals. The Fertiliser Action Plan also emphasises the importance of improving nutrient management, while ensuring that the decarbonisation of the fertiliser industry goes hand in hand with maintaining competitiveness. Technologies now exist that can recover nitrogen from wastewater and convert it into fertiliser products for agriculture and other valuable chemical products for industrial use, while supporting increased biogas production and eliminating climate-intensive laughing gas emissions.

This is a clear example of what a Resource Plant can be. However, wastewater treatment plants have not yet been given this task by society. Today, they are highly effective at protecting water quality – but they will not add the production of raw materials unless required.

The same principle applies to phosphorus.

Phosphorus is essential for food production and cannot be substituted. Europe remains heavily dependent on imported phosphorus, despite the fact that significant quantities are already available in European wastewater streams. Recent data show that imports of phosphate rock from Russia continue to grow, even as Europe seeks to reduce strategic dependencies in other sectors. At the same time, Europe is restricting the use of equivalent recycled phosphorus already produced within its own borders.

The EU Fertiliser Action Plan recognises nutrient recycling and phosphorus recovery as part of the solution. Technologies capable of recovering high-quality phosphorus from incinerated sewage sludge already exist and are now being deployed at industrial scale in Europe. The resulting product contains no detectable cadmium. It is approved for use in organic farming and has the quality characteristics required for potential use in animal feed.

Yet current EU feed legislation still prevents recycled phosphorus recovered from sewage sludge ash from entering the feed market. A new report, which I will hand over shortly, shows that removing these barriers could create thousands of new jobs and unlock more than EUR 9 billion in investments across Europe.

In other words, Europe does not lack resources. It lacks a regulatory framework that allows high-quality recovered nutrients to compete on equal terms with virgin materials.

But not everything should circulate.

If Europe wants to reuse more water in industry and agriculture, while increasing resource recovery, contaminants such as PFAS must be managed safely.

The cleaner the incoming streams, the greater the opportunities for safe resource recovery. This is why source control, pollution prevention and resource recovery must go hand in hand.

Technologies to capture and concentrate PFAS are being deployed across Europe, but we fight an uphill battle as long as it remains legal to add PFAS in products beyond the most critical applications.

This is also one of the reasons why wastewater treatment plants are becoming increasingly important strategic assets for Europe.

Taken together, these examples point in the same direction. Europe can recover more resources, reduce emissions, strengthen food security and reduce strategic dependencies if regulation evolves alongside technology.

The same principle applies beyond wastewater treatment itself. It is also about how we use the water we already depend on for food production.

Aquaculture is a good example.

Future growth in food production from water must largely come from aquaculture, as wild fisheries have limited potential to expand sustainably. Yet today, aquaculture remains largely linear. Nutrients are fed to fish, but a significant share is lost to surrounding waters, contributing to eutrophication instead of being recovered and reused.

Through the EU project AquaPhoenix we are exploring how circular nutrient flows can increase food production from aquaculture while reducing environmental impacts.

Circular nutrient management in fish farming has the potential to increase European food production while supporting more than 100,000 jobs and generating substantial economic value. This could help Europe produce double or triple food from its own aqua resources while reducing nutrient losses to the environment.

In the AquaPhoenix project, this is done by collecting the sludge sinking from the net pens and extracting its resources. But one key barrier is that nutrients recovered from fish sludge cannot be returned to productive use as fertiliser or feed. As a result, nutrients that could support food production remain outside the circular economy. Without a clear regulatory pathway for these nutrients to circulate, investment in circular aquaculture systems remains limited.

The sludge can also be used to produce sustainable biogas through anaerobic digestion – a well-established process for biological waste. Collection of fish sludge from Norway alone has the potential to generate up to 300 million cubic metres of methane per year, equivalent to around 3 TWh of energy, comparable to the annual electricity consumption of about 600,000 households.

This, however, comes with regulatory challenges. While fish sludge consists of excreta and feed residues and thus is functionally similar to livestock manure, it is explicitly excluded from the definition of “manure” under the EU Animal By-Products Regulation (Regulation (EC) No 1069/2009). As this definition is carried over into Renewable Energy Directive, and certification systems such as ISCC, fish sludge, currently, cannot benefit from the favourable treatment given to manure in terms of greenhouse gas accounting and policy incentives, creating economic and regulatory barriers for its use in biogas production.

This is why the upcoming Circular Economy Act is so important. Across nitrogen, phosphorus and aquaculture, the pattern is remarkably similar. The technologies and the resource streams already exist within Europe. The remaining barriers are often regulatory.

• For phosphorus, this means revising Annex III of the Feed Regulation, which currently prevents recycled phosphorus from use in animal feed, so that high-quality recycled phosphorus can compete on equal terms with virgin materials. Sweden has proposed a renewed EFSA assessment, which could provide a science-based foundation for reviewing the current restrictions.
• For aquaculture, it means creating a clear regulatory pathway for nutrients recovered from fish sludge to be returned to productive use as fertiliser or feed. Ultimately, it means ensuring that legislation governing waste, animal by-products, fertilisers and feed supports circular resource flows rather than unintentionally blocking them. As regards biogas production, we see two potential pathways can be pursued to address this: first, revising the ABP Regulation to include fish excreta in the definition of manure; and second, recognising fish sludge as an unavoidable waste or residue feedstock within the framework of the Renewable Energy Directive (for example, through Annex IX), thereby enabling similar favourable treatment without requiring a change to the manure definition.
• More broadly, Europe needs a regulatory framework that allows high-quality recovered resources to circulate safely and compete on equal terms with virgin materials. Resources should be assessed according to their quality, safety and performance – not solely according to their origin.

Europe already possesses more of the resources it needs than we often realise. The challenge is no longer finding the resources. It is creating the conditions for them to circulate safely and productively throughout the economy – whether they originate from wastewater, aquaculture or other resource streams.

That is the opportunity before us in the Circular Economy Act.

Thank you!

 

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