House of Commons - Environment, Food and Rural Affairs - Appendices to the Minutes of Evidence

Select Committee on Environment, Food and Rural Affairs Appendices to the Minutes of Evidence

Memorandum submitted by the British Cement Association

EXECUTIVE SUMMARY

1. The cement industry forms an important part of the solution to the future of waste management in the UK. It currently has 15 plants nationwide with the potential, even in the short term, to move 1.26 million to 1.51 million tonnes of material per annum, up the waste hierarchy from disposal to recovery.

2. The use of waste-derived fuels in cement kilns is accompanied by a number of environmental benefits:

— energy recovery from waste provides a solution to existing UK waste problems that is higher up the waste hierarchy than landfill and high-temperature incineration;

— the process may be used for: a wide range of hazardous and non-hazardous waste materials; wastes for which no other option higher up the waste hierarchy exists; and for wastes that require treatment involving high temperatures/long dwell times;

— the waste materials used replace fossil fuels and other virgin raw materials; and

— their use is accompanied by a reduction in process emissions.

3. The demands of EU waste management legislation will require significant changes to the UK's waste management infrastructure. Even with increased reuse of materials and minimisation of waste, substantial additional capacity will be required to recycle and recover waste arisings.

4. Other EU countries have a lower reliance on landfill but a higher use of both high-temperature incineration and co-incineration by cement kilns using alternative fuels. Cement kilns, therefore, can have a very positive role within the UK's waste infrastructure.

5. These advantages cannot be fully realised due to substantial inertia within the regulatory regime. Innovation is stifled and the inherent flexibility of the cement making process is thereby limited.

6. Many EU Member States take advantage of the capacity within their own domestic cement industry, and complying with the same EU environmental legislation as the UK, achieve far more efficient and effective recovery of these waste-derived fuels, whilst retaining sound environmental control. The use of waste-derived fuel in the UK is merely 6% compared with the European average of 12%, France and Germany 30-40%, and 50% in Belgium.

7. To realise the industry's potential, a more efficient process for granting PPC authorisations for using alternative fuels is required urgently, replacing the extra-statutory Substitute Fuels Protocol, (SFP), with a permitting process that reflects the considerable experience gained across Europe.

8. The BCA requests that the Committee expedites the future of waste management by recommending the removal of any extra-statutory and other constraints, that inhibit progress towards moving materials up the waste hierarchy, such as the Substitute Fuels Protocol.

MOVING UP THE WASTE HIERARCHY—THE ROLE OF THE CEMENT INDUSTRY

1. The cement industry is a key player in the government's Waste Strategy, offering solutions for the treatment of large tonnages of problematic and other waste streams. These include:

— fuels derived from a wide range of hazardous and non-hazardous waste materials;

— intractable wastes [ie "residual" wastes for which no other option higher up the hierarchy exists];

— wastes specifically requiring high temperatures/long dwell times. Wastes that may be treated in cement kilns include: solvents; plastics; paper and packaging; solvents; waste oils; oily sludges; tyres; sewage sludges; meat and bone meal, tallow; and contaminated waters.

2. Treatment of these materials in cement kilns involves the recovery of energy, an operation higher up the waste hierarchy than landfill or incineration.

3. With regard to the UK waste management infrastructure, the cement industry can assist government in both the short- and the long-term, viz. through

— providing an interim solution during build-up of infrastructure within the UK to meet the demands of new EU Directives; and

— treating a proportion of the wastes arising, as part of the mature infrastructure.

4. The use of waste-derived fuels in cement kilns provides a mechanism for energy recovery, and channelling material through this route is a preferable environmental option than landfill or incineration— see Annex I, paragraph 2.5.

5. Certain waste streams that contain high percentages of iron, alumina, calcium or silica may be used as a source of raw materials, replacing the limestone and clay usually used for cement production. See Annex II.

5.1. Avoidance of such bulk materials in landfill, reducing the need for natural resources and the ability of the thermal properties of the cement process to sterilize such materials, represents a major win-win-win for industry and the environment.

6. Annexes III and IV give examples of the range of waste-derived materials that are currently treated in cement kilns in Europe and elsewhere, showing the flexibility in regulatory response available in mainland Europe.

7. UK cement companies are committed to continual improvement in their environmental performance progressing towards sustainability, using environmental management systems (ISO 14001 and EMAS), and participation in programmes such as the World Business Council for Sustainable Development's Cement Sustainability Initiative, the Environment Agency Sector Plan, and the cement and concrete sector sustainability initiative.

SOLUTIONS PROVIDED BY THE CEMENT INDUSTRY

Provision of a range of solutions

8. The cement industry's requirements for fuels from waste are quite specific, and many of the materials arising within the UK are not suitable for use as fuel in a cement kiln, since they are either unavailable in sufficient quantities or do not satisfy the compositional requirements.

9. The cement industry is active in the development of new routes for the treatment of a range of waste streams. In addition to working with waste management companies, it has been active in:

— the establishment of joint ventures with others within the waste management industry, [ie the producers, collectors or processors of waste], and

— the ownership or part ownership of appropriate waste management companies,

for the production of waste-derived fuels and materials suitable for use in cement manufacture

10. In addition to using waste-derived materials, the industry is committed to a £500 million investment programme for new manufacturing plant and the upgrading of existing facilities. This will result in improvements in energy efficiency [as part of the sector's 25.6% improvement within the UK Climate Change Levy scheme] and reduction in emissions.

11. Details of the involvement of the cement industry in the preparation of waste-derived fuels are included in Annex II.

Flexibility to address range of wastes

12. The cement industry has the capability and potential to address a wide range of wastes, (see the Table below). From a performance in 2001 where 150,000 tonnes of wastes were used as a fuel, within 3-5 years the industry could increase this ten-fold.

Table 1

UK CEMENT INDUSTRY USE OF ALTERNATIVE FUELS[30]

Fuel	2001—Actual Use, tonnes	Next 3-5 years—estimates of Potential Use, tonnes
Waste derived liquid fuels	110,000	200,000
Tyres	40,000	290,000
Packaging and Packaging Waste	0	500,000
Waste Oils	0	90,000 to 345,000
Meat and Bone Meal, (MBM)	0	140,000
Processed sewage pellets, (PSP)	0	40,000
Total	150,000	1,260,000 excluding waste oils
		1,515,000 including waste oils

Environmental Benefits

13. The use of these and other waste-derived fuels is accompanied by a number of environmental benefits, which were outlined in the industry's submission to the Committee's inquiry into hazardous waste, viz. replacement of raw materials and fossil fuels, reduction of CO2 emissions, and reduction of process emissions.

14. All UK cement works are independently certified to ISO 14001, the international voluntary standard for Environmental Management Systems, and over 73% of sites have additionally chosen to obtain accreditation to EMAS, the European Union Eco-Management and Audit Scheme.

15. All sites are licensed under the EU IPPC Directive and those burning waste-derived fuels will be subject to the Waste Incineration Directive.

Nationwide location of cement plants

16. The UK cement industry has 15 production facilities spread across the UK from Dunbar in Scotland, Cookstown in Northern Ireland, Padeswood and Aberthaw in Wales and 11 plants across England.

The cement industry therefore has the potential to provide the environmentally preferable local solutions to local waste disposal problems, without the need to install new capacity or to transport wastes long distances.

Community Relations

17. Cement works are typically located in rural areas and most have been in existence for over 50 years. Cement companies have a long history of involving and consulting with the communities around the plants.

18. The industry believes it is leading the way in terms of consultation with local people about developments at the works including the introduction of new fuels. Communication with the community is via many routes including: liaison committees; newsletters, public exhibitions and open days.

WASTE MANAGEMENT IN THE UK

19. The Eighth Report of the Environment, Food and Rural Affairs Committee[31] noted "the management of hazardous waste in the United Kingdom will change significantly over the next few years" as a consequence of developments in EU waste management legislation, resulting from the Landfill Directive, the Waste Incineration Directive, the Packaging and Packaging Waste Directive and the "producer responsibility" Directive on End-of-Life Vehicles, (ELVs), and Waste Electrical and Electronic Equipment, (WEEE).

20. In its previous evidence to the Committee, the British Cement Association stated, "The cement industry has a significant role to play in developing solutions to current and future problems highlighted by the UK Waste Strategy. The cement-making process provides optimum conditions of temperature and residence time for the destruction of hazardous and other wastes, and the industry has a proven track record in the application of its process technology to the beneficial treatment of a wide range of these materials".

21. The importance of the contribution to the UK Waste Strategy provided by the cement industry was stressed in evidence from the waste management industry:

21.1. Onyx stated[32]: "The cement industry offers additional capacity, with the ability to process hazardous waste pre-treated to a very controlled specification with a high calorific value. The emission standards have been shown by the Environment Agency to give more environmental benefits as a replacement to fossil fuels. Expansion in this area must be encouraged".

21.2. SITA stated[33]: "this option [co-incineration in cement kilns] has thus far not been incorporated explicitly into a hazardous waste strategy for the UK, despite the potential that it offers as a safe alternative under appropriately controlled conditions".

22. The BCA concur with the Environmental Services Association, ESA, statement[34], "we are dismayed by the fact that—even now—existing infrastructure to treat hazardous waste is being undermined by an inadequate regulatory framework".

23. Both the BCA and ESA stressed that the regulatory climate within mainland Europe provided far greater certainty and shorter times for granting authorizations for the use of waste-derived fuels than within the UK. In the UK, some £1 million to £2 million of risk capital must be committed for 15 to 30 months in respect of each fuel application, without the certainty of gaining permission for permanent use.

24. These views are reflected by the producers of waste. The Chemical Industry Association reported[35] "the uncertainties in the area of waste policy make it difficult for waste producers to develop coherent medium to long-term strategies. Whilst this situation persists, it is difficult to envisage that, in the short-term at least, producers will truly be able to take responsibility for planning the final destination of their waste".

25. The Report of the Strategy Unit—"Waste Not, Want Not"[36]—suggests that the waste hierarchy[37] provides a sensible framework within which to achieve a better balance between the various options available for the management of waste.

The Report indicates that for its success, a package of short- to medium-term measures is required to put England on the path to more sustainable waste management, and envisages a package that would inter alia stimulate innovation and improve resource productivity.

One of the suggested means of improving the UK's performance is by learning from the best (and worst) practices of other countries.

The Report recommends[38] that an independent body should bring together the literature and evidence on the relative health and environmental effects of all different waste management options.

The cement industry supports the conclusions of the Report, which are equally true for municipal and industrial waste.

THE DEVELOPMENT OF A WASTE TREATMENT INFRASTRUCTURE WITHIN THE UK

26. Implementation of the EU Landfill Directive will result in the diversion of waste from landfill sites. The packaging waste and the "producer responsibility" Directives on End-of-Life Vehicles and Waste Electrical and Electronic Equipment will inter alia impose mandatory targets on recovery and recycling.

27. The report of the Strategy Unit highlights the inadequacies of the current waste treatment hierarchy. In moving from the present position to a mature infrastructure comprising a range of processes across the waste hierarchy, there will be an interim period during which advanced techniques are being developed and additional capacity is being installed.

28. Ideally the majority of the processes in the mature infrastructure will be towards the upper end of the waste hierarchy, but this will not be possible for all wastes.

29. BCA welcomes the establishment of the Hazardous Waste Forum, and is committed to its role within this multi-agency initiative.

CONSTRAINTS WITHIN EU AND UK LEGISLATION

Definitional Constraints

30. The minutiae of UK and EU waste management law do not necessarily provide guidance on the sustainable management of waste. They do, however, place legally binding constraints on both government and industry on how waste must be treated.

31. In the context of this enquiry, two issues are of relevance:

— When a material ceases to be regarded as "waste"; and

— The distinction between "recovery", "recycling", and "disposal".

32. With a regard to the former, no matter how much processing has been given to the waste, or the extent to which the processed material has the properties analogous to a material of non-waste origin, it will continue to be regarded as waste until it has satisfied the legal requirements for "complete recovery".

33. For example, scrap steel that has been treated so that it is a suitable feedstock for a steelmaking furnace, is considered as waste until it has been used in the steelmaking furnace for the manufacture of ingots, sheets or coils of steel. Likewise, the use of waste processed to meet the requirements of the cement industry will remain as "waste" until their "complete recovery" in a cement kiln.

34. In the context of packaging waste, this restricts the issue of Packaging Recovery Notes, PRNs, and Packaging Export Recovery Notes, PERNs to the final user of the recovered material, eg the steelmaker or the cement manufacturer.

35. With regard to the distinction between "recovery" and "disposal", guidance on this issue is now available from an increasing number of cases reviewed by the European Court of Justice, and it is clear that the use of waste-derived fuels in cement kilns regarded in law as "recovery" whereas burning wastes in high temperature incinerators is "disposal". The consequences of this in law are:

35.1. The use of waste-derived fuels in cement kilns is higher up the waste hierarchy than the burning of wastes in incinerators.

35.2. Under EU Council Regulation EEC/259/93 on the supervision and control of shipments of waste, waste cannot be imported or exported for burning in incinerators, as this is a "disposal" process.

36. A fuller description of the relevant case law is given in Annex I.

Constraints specific to cement and lime industries

37. The ability to utilize the industry's capability, and to consider other innovative solutions to the UK's waste management problem is being hampered by excessive and overly burdensome regulation that is not applied to cement makers in other EU countries nor to other industries in the UK: the Substitute Fuels Protocol is the prime example.

38. The impact of this is to:

38.1. delay the development of a long-term solution to the treatment of the UK's waste problem.

38.2. delay the delivery of significant environmental benefits;

38.3. threaten future investment in UK cement industry by European parent companies.

39. In order to realise the cement industry's potential to contribute to the solution to the UK's waste problem it is necessary to achieve a paradigm shift from rigid regulatory controls that work against environmental best practice to regulation and a system that works in support of more sustainable development.

40. A smarter regulatory framework would also enable better resource utility through improved industrial ecology—the use of the by-products of one industry as a raw material in another.

41. Details of these regulatory constraints were submitted as evidence to the Committee's inquiry on hazardous wastes[39].

Constraints Imposed by the Taxation Regime

42. The submission by Solvent Resources Management Ltd, SRM, to this Committee[40] notes that the taxation of waste-derived fuels [referred to as "Substitute Liquid Fuels", SLF] has the effect of pushing certain wastes down the waste hierarchy.

WASTE MANAGEMENT EXPERIENCE IN EUROPE

43. The Report of the Strategy Unit acknowledges[41] that [in relation to municipal waste] "the way England manages its waste harms the environment and squanders resources . . . England can learn from the best performers ["other countries"] by focussing on waste minimisation; reusing and recycling more waste; and making the most of a wide range of alternative technologies for dealing with residual waste".

44. European best practice holds many of the keys to achieving sustainable development in the cement sector and in turn the cement sector can contribute to broader sustainable development in the UK.

45. Other EU countries have a lower reliance on landfill but a higher use of both high temperature incineration and co-incineration by cement kilns using alternative fuels. It therefore seems that both processes can have their respective roles within the UK's waste infrastructure.

46. In a number of European countries, the cement industry is the preferred treatment route for wastes, where it is the first to be approached when problematic wastes arise, such as MBM.

47. Annex IV lists examples of a number of European Member States where the cement industry is providing a solution to their waste management problems. This Annex demonstrates the number and variety of waste-derived materials treated at many of the European cement plants. In France, three or four wastes is the norm whereas at the Obourg plant in Belgium, nine wastes are treated.

Only two plants in the UK treat are currently authorized to treat more than one waste.

48. The UK cement industry is currently undertaking a more detailed analysis of these examples, with a view to generating case studies of cement industry best practice, and the flexibility afforded to these Member States by the substantially shorter times required for authorizations to burn these materials.

CONCLUSIONS—THE WAY FORWARD

49. The management of waste within the United Kingdom will change significantly over the next few years, primarily as a consequence of developments in waste management legislation arising from the EU.

50. The cement industry forms an important part of the solution to current problems, having 15 existing plants nationwide with the potential, even in the short term, to treat 1.26 million to 1.51 milliom tonnes of waste annually.

51. The use of waste-derived fuels in cement kilns is accompanied by a number of environmental benefits, but these advantages and the extensive experience within UK cement companies and their European partners cannot be fully realized due to the substantial inertia within the regulatory regime.

52. Many EU Member States take advantage of the capacity within their own domestic cement industry, and complying with the same EU environmental legislation as the UK, achieve far more efficient and effective recovery of these waste-derived fuels, whilst retaining sound environmental control.

53. To realise the industry's potential, a more efficient process for granting PPC authorizations for using alternative fuels is required urgently, replacing the extra-statutory Substitute Fuels Protocol, SFP, with a permitting process that reflects the considerable experience gained across Europe.

54. The BCA requests that the Committee expedites the future of waste management by recommending the removal of any extra-statutory and other constraints, that inhibit progress towards moving materials up the waste hierarchy, such as the Substitute Fuels Protocol.

British Cement Association

January 2003

Annex I

LEGISLATIVE ISSUES[42]

In the context of this enquiry, two issues are of relevance:

1. When a material ceases to be regarded as "waste". Until the point at which a material ceases to be regarded on law as "waste", it will be subject inter alia to the provisions of waste management legislation, such as the Duty of Care provisions and those relating to the storage, treatment, and carriage of waste.

1.1. As the law stands, a material continues to be regarded as "waste" until it has undergone "complete recovery". Thus, no matter how much processing has been given to the waste, or the extent to which the processed material has the properties analogous to a material of non-waste origin, it will continue to be regarded as waste until it has satisfied the legal requirements for "complete recovery".

1.2. For example, scrap steel that has been treated so that it is a suitable feedstock for a steelmaking furnace, is considered as waste until it has been used in the steelmaking furnace for the manufacture of ingots, sheets or coils of steel. Likewise, the use of waste-derived fuels in cement kilns will be regarded as "complete recovery".

1.3. In the context of packaging waste, this restricts the issue of Packaging Recovery Notes, PRNs, and Packaging Export Recovery Notes, PERNs to the final user of the recovered material, eg the steelmaker or the cement manufacturer.

2. The distinction between "recovery" and "recycling" Until the introduction of the Directive on Packaging and Packaging Waste, 94/62/EC, there was no legislative distinction between "recovery" and "recycling".

2.1. However, the Packaging and Packaging Waste Directive and the producer responsibility measures on End-of-Life Vehicles[43], (ELVs), and on Waste Electrical and Electronic Waste[44], (WEEE), all contain targets for both "recycling" and "recovery".

2.2. These targets are legally binding, and it is therefore important to both government and industry that waste management processes are classified correctly.

2.3. "Recycling" is defined in Directive 94/62/EC as:

"the reprocessing in a production process of the waste materials for the original purpose or for other purposes including organic recycling but excluding energy recovery",

"any of the operations provided for in Annex II,B".

2.4. Until recently, there was a degree of uncertainty on the extent to which the category of recovery process "used principally as a fuel" could be applied. Guidance on this issue is now available from an increasing number of cases before the European Court of Justice[46], for example the Opinion of the Advocate General of the European Court of Justice in cases Commission v Germany, case C-228/00, Commission v Luxembourg, case C-458/00, and Verol Recycling Limburg BV v Minister van Volshulsveting, Ruimtelijke Ordening en Milieubeheer, case C-116/01.

2.5. The Opinions broadly state that whereas waste-derived materials used as a fuel in cement kilns should be classified as a recovery process under R1 of Annex IIB to the Waste Framework Directive, burning wastes in an incinerator should be classified as a disposal operation under D10 of Annex IIA to the Directive. Thus,

2.5.1. The use of waste-derived fuels in cement kilns is an operation higher up the waste hierarchy than the burning of wastes in incinerators.

2.5.2. Under EU Council Regulation EEC/259/93 on the supervision and control of shipments of waste, waste cannot be imported or exported for burning in incinerators.

2.6. These are subject to ratification in the Judgement of the Court, expected early in 2003.

Annex II

CEMENT COMPANY INITIATIVES WITH WASTE INDUSTRY

1. LAFARGE CEMENT

Lafarge Cement has established two joint ventures which are providing disposal routes for waste which, within three years will collectively handle and move up the waste hierarchy as fuels and raw materials more than:

— 16 million tyres, saving 120,000 tonnes of coal.

— 500,000 tonnes of minerals based waste, saving precious virgin raw materials.

1.1 Sapphire Energy Recovery—a tyre disposal joint venture

— Sapphire Energy Recovery Ltd, a joint venture between Lafarge Cement UK and Michelin Tyres PLC is the market leader in environmentally friendly tyre disposal. Since it was launched in 2001, Sapphire has set-up a UK-wide disposal network stretching from Scotland to the west country, sourcing and preparing used tyres for use as fuel in cement kilns.

— The establishment of Sapphire, and the high capacity disposal route which sustains it, has been underpinned by investment of over £12 million, principally by Lafarge in gaining permits to use tyres as fuel and installing the necessary automated equipment for efficient tyre handling at its works. This proactive work has ensured that the country is better placed to meet the tyre disposal requirements of the landfill directive ahead of the 2006 deadline.

— Sapphire was handling a modest 400 tonnes (56000 tyres) a week just after it was launched last year. Its disposal volumes have now grown to over 1,200 tonnes (168,000 tyres) each week, equivalent to 65,500 tonnes (9,000,000 tyres annualised) a year. Sapphire's target for 2004 is 120,000 tonnes (16,800,000 tyres).

— The use of tyres in cement kilns is permitted by the Environment Agency and has been proven in exhaustive trials to deliver environmental benefits including dealing with what has traditionally been seen as a "problem" waste, reducing emissions from the cement factories and saving fossil fuels for future generations.

1.2 Glacier ARM Ltd—an alternative cement-making raw materials joint venture

— In 2002, Lafarge Cement UK launched a joint venture with Geodur International AG of Switzerland called Glacier ARM. Glacier's role is to process industrial by-products, which would normally be discarded as waste, into alternative raw materials for cement making.

— Glacier's operation in the UK is breaking new ground, sourcing wastes rich in silica, iron, alumina and lime minerals for blending into raw materials for the cement-making process. The industries which provide suitable waste streams include the:

— water industry

— aluminium industry

— many other metal producing industries

— automotive industry

— petrochemical industry, and

— pharmaceutical industry

— Glacier took two years to launch as it carried out a market investigation to determine waste disposal routes, volumes available, and types of materials and locations; and set up the first production site in Sheffield.

Glacier ARM's ambitious development programme is that within three years it will annually supply over 500,000 tonnes of alternative raw materials (ARMs), primarily to Lafarge Cement UK's works. This will play an important part in moves towards sustainability as the ARMs replace virgin raw materials that would otherwise have to be extracted and used.

2. CASTLE CEMENT

2.1 SRM Ltd—a Recycling and recovery company, within the Heidelberg Cement Group, the parent company of Castle Cement[47]

SRM Ltd. specialises in the recycling of solvents and the production of waste derived fuels from materials unsuitable for recycling, it operates from six locations spread across the UK and employs some 300 people.

The principle business is the recycling of solvents: some 100,000 tonnes of solvents are recycled using a range of distillation cleaning and drying equipment, either to be returned to their original owner for re-use or sold on the open market. For example SRM is now the largest producer of paint thinners in the UK.

The residues from the recycling businesses as well as those materials unsuitable for recycling, again some 100,000 tonnes, are manufactured to the various specifications required by the cement and lime works customers, for use as fuel in their high temperature processes. It is interesting to note that without this beneficial use of residues many of the recycling operations would be uneconomic.

SRM was the proud recipient of the "Queens Award for Innovation" for its de-drumming equipment, which allows the safe, economic and environmentally sound disposal of difficult liquid waste in drums. The contents of the drums going to cement kiln fuel, while the drums become clean shredded steel, which is recycled to the steel industry. The drums would otherwise have been landfilled or incinerated.

SRM is also involved in the production of fuel from selected steams of paper, plastic and packaging wastes in a new process designed with a capacity of 70,000 tonne per year. This is a process that will be replicated across the UK once sufficient experience is obtained.

Annex III

EXAMPLES OF WASTES TREATED BY EUROPEAN CEMENT MANUFACTURERS

Meat and bone: Waste from the food processing industry.

Used oils: Sourced from industrial machinery and equipment manufacturers. This may be ether mineral or synthetic in origin and includes transmission fluids, coolants, refrigeration oils and lubricants.

Contaminated water: Industrial waste water from chemical or biochemical industries.

Waste solvents : Cleaning solvents; photo liquids, grouping solvents eg G3000; non chlorinated solvents; organic solvents; solvent wastes. Sourced from chemical, pharmaceutical, biochemical, printing, lithography and industrial processes.

Scrap tyres: Tyre manufacturing rejects; used tyres; and tyres from end-of-life vehicles, ELVs.

Waste hydrocarbons: Hydrocarbons residues from the chemical and biochemical industries, eg "kormul", a recycled petrochemical sludge.

Biomass: Animal fats; coffee husks; moinha [a residue from charcoal]; mycelium [a by-product from citric acid production]; palm kernel shells; rice husks; boiled seeds; sunflower shells; vegetable oils; wood wastes.

Process sewage: Pasteurised and pelletized domestic sewage.

Packaging waste: Plastics film and cardboard from commercial and non-commercial sources.

Impregnated sawdust: Viscous organic residues.

Meat and bone: Waste from food companies.

Contaminated water: Industrial waste water from chemical or biochemical industries.

Scrap tyres: Tyre manufacturing rejects; used tyres; and tyres from end-of-life vehicles, ELVs.

Waste hydrocarbons: Hydrocarbons residues from the chemical and biochemical industries, eg "kormul", a recycled petrochemical sludge.

Biomass: Animal fats; coffee husks; moinha [a residue from charcoal]; mycelium,[a by-product from citric acid production]; palm kernel shells; rice husks; boiled seeds; sunflower shells; vegetable oils; wood wastes.

Process sewage: Pasteurised domestic sewage treatment plant.

Packaging waste: Plastics film and cardboard from commercial and non-commercial sources.

Impregnated sawdust: Viscous organic residues.

Annex IV

EXAMPLES OF EUROPEAN EXPERIENCE IN USE OF WASTE-DERIVED FUELS