FAQ

Manufacturer: If you make chemicals, either to use yourself or to supply to other people (even if it is for export), then you will probably have some important responsibilities under REACH. Importer: If you buy anything from outside the EU/EEA, you are likely to have some responsibilities under REACH. It may be individual chemicals, mixtures for onwards sale or finished products, like clothes, furniture or plastic goods. Downstream users: Most companies use chemicals, sometimes even without realising it, therefore you need to check your obligations if you handle any chemicals in your industrial or professional activity. You might have some responsibilities under REACH. Companies established outside the EU: If you are a company established outside the EU, you are not bound by the obligations of REACH, even if you export their products into the customs territory of the European Union. The responsibility for fulfilling the requirements of REACH, such as registration lies with the importers established in the European Union, or with the only representative of a non-EU manufacturer established in the European Union.

REACH establishes procedures for collecting and assessing information on the properties and hazards of substances. Companies need to register their substances and to do this they need to work together with other companies who are registering the same substance. ECHA receives and evaluates individual registrations for their compliance, and the EU Member States evaluate selected substances to clarify initial concerns for human health or for the environment. Authorities and ECHA's (European Chemical Agency) scientific committees assess whether the risks of substances can be managed. Authorities can ban hazardous substances if their risks are unmanageable. They can also decide to restrict a use or make it subject to a prior authorisation.

All thermal processed materials are chemically modified substances which mandatory must have REACH certification above 1 t/y capacity manufacturing, import and/or placing on the market (Registration, Evaluation, Authorisation and Restriction of Chemicals). Biochar is a chemically modified substance, therefore REACH regulation is mandatory to be applied. REACH is a regulation of the European Union, adopted to improve the protection of human health and the environment from the risks that can be posed by chemicals, while enhancing the competitiveness of the EU chemicals industry. It also promotes alternative methods for the hazard assessment of substances in order to reduce the number of tests on animals. In principle, REACH applies to all chemical substances. If the risks cannot be managed, authorities can restrict the use of substances in different ways.

The 3R pyrolysis process is a recovery of economically concentrated Phosphorus from food grade animal bones that could potentially provide an abundant alternative source of the nutrient and that shows similar agronomic efficiencies as the mined P-rock and chemosynthetically processed P-fertilisers. There are no emissions during processing and all material streams are fully recovered. The 3R technology is a zero emission/pollution solution for primary designed where all and any material streams are recycled and reused (converted into safe and valuable products). The 3Rprocess does not produce harmful emissions (including greenhouse gases) and the product is safe to use.

BioPhosphate is a fully safe product and providing a toxic free environment. No cadmium +no uranium = no contamination content: BioPhosphate has a similar P2O 5content as P-rock and traditional P-fertilisers, but the Cadmium content of BioPhosphate vs P-rock is not even detectable vs 30-120 Cd mg/kg of sedimentary P-rock

Indeed, the number of products presented that today are at least expected to be registered, authorized in some way with an organic certification is lower than the complexity of products seen in conventional agriculture, and this is related to several factors, mainly legislative in the sense that it depends a lot not only on the type of production process but also the type of starting material used for their process. We are talking about a framework regulation that will come into full force in July 2022. Certainly, from now until next year there will perhaps be some developments and the way may be opened up for specific applications of these products in organic farming. The element that distinguishes is the characteristics of the product, both the starting material used and the characteristics of the final product, which in some cases makes it authorizable in organic farming, while in others it does not comply with any parameters and requirements that could lead to organic farming applications. The bio-fertilizing concept because it derives from a circular economy necessarily means that it can be authorized in organic farming, but this is not the case. We see this nowadays by taking an example of a classic product such as compost. Compost is produced with certain starting matrices, it remains a conventional agricultural compost, while compost derived from green waste and therefore with a different starting material can be registered in organic farming.

Currently there are some certifications, in the hands of individual member states, for example, as you probably know compost and composted binders can also be compost certified by the Italian Consortium of Composters, these are voluntary certifications. From the point of view of the European regulation, the regulation defines quality standards, and also considers the fact that they can come from recovered materials, waste, etc. They must then be subject to certain restrictions and comply with the requirements of the European regulation. The European regulation does not provide for a certification from this point of view, it is obviously the individual member states that must take charge of the controls and then check whether these products comply with the requirements of the European regulation. It is not excluded that in the future specific certification bodies will be set up to carry out, let's say, additional voluntary certifications on the basis of these standards defined by the framework regulation of 2019.

The studies we have carried out have used magnesium chloride so that it is not from a mining source but obviously to give a circular economy character to the process and to avoid external dependence on any mining or fertilizer element. What we want to develop is to be able to use other wastes which at the same time can be a rich source of magnesium and which normally are not used or are considered as waste material. One of the interesting alternatives that we are looking at is the waste obtained from the brine of waste water plants which is very difficult to use (it is a difficult element to use and recover from animal plants but we are using it applying the concept of circular economy so that it is an impute and can be used as a renewable or alternative source of magnesium.

The concentration of phosphorus obtained from the starting fluid used as raw material is one of the most important parameters to start with. Specifically, from the studies carried out with a digestate from anaerobic digestion of pig manure, we have seen that the necessary concentration of phosphorus for the process to be technically and economically profitable and acceptable should be 8,5 mg of phosphorus.

There are currently efforts to include certain P-recyclates (struvite, ash, biochar) in the legal framework of the new EU fertilizer regulation 2019/1009. Subsequently, these products could then also be included in the regulation EC 889/2008 for ecological/biological farming. Discussions are also ongoing at the national level from the associations for organic farming regarding the intake of certain P-recycling products.

In the Benas process, most of the P is in the liquid phase. The solid phase is used for fiber production.

There are considerations in the direction of incineration of the solid phase and subsequent processing of the ash to make the P fraction more available to plants.

A subsequent pelleting would be possible. There are considerations for processing the solid phase in the direction of pyrolysis (biochar).

That depends heavily on the starting substrates.

The process water is not treated any further in the basic system.

It is recommended to apply this fertilizer before or during planting of the crop. Because it contains a high percentage of nitrogen it is necessary to apply this in small dosage max 0.5 – 1 ton / ha. It can be used in spring, especially on grasslands, because 50% of the nitrogen consist of ammonium. Early in the season a grass plant prefers ammonium over nitrate to grow from. Later in the season when temperatures rise, the grass will use nitrate to grow from. The still available ammonium will be converted to nitrate quicker when temperatures rise. The 50% nitrate of this fertilizer is a risk early in the season, because when rains come this will disappear. This is why you should always make sure this fertilizer is applied when rainfall is limited.

The product contains: N 18%. It can be used on corn, grass and vegetables. Recommended is to inject the fertilizer in the soil because spraying can cause damage on the plants.

This depends on the crop application rates. Each crops needs a different amount of nutrients for cultivation. While you need to be aware that mineral concentrate is currently still registered as livestock manure in Europe, in the Netherlands farmers can enter a pilot using mineral concentrate as a alternative fertilizer. This means it does not take up space from the livestock manure you can apply. Currently max 170 kg N/ha (230-250 kg N/ha for derogation dairy farms).

The product contains: N 6.5; P₂O₅ 0,1; K₂O 7.5 kg/ton. It can be used on potatoes. The product can be applies before planting and also during cultivation using precision fertilizing equipment. For potatoes it might be the perfect way to decrease use of potassium fertilizer significantly.

Both products are liquid, therefore it can be easily used combined with manure. A solution offered in the Netherlands is drag hose injection, to lower soil pressure. And many of them have the option to separately add another fertilizer. The dosage seems to be quite accurate, some of the machines even have NIRS sensors to exactly measure the content of the added fertilizer.

The product contains: N 6.5; P₂O₅ 0,1; K₂O 7.5 kg/ton. It is recommended to use for fresh vegetables, root crops and plants, grain maize and corn cob, grasslands, dry pulses and protein crops.

It on average contains following nutrients: N: 3.5 g/kg; P₂O₅: 0,015 g/kg; K₂O: 8.5 g/kg. It can be used on all crops, biological and conventional on fields and in glass houses.

If you use certified compost, this shouldn’t be an issue since there composts are high quality and checked for this parameter amongst others.

It is cheaper than peat and adds useful microorganisms in your pots, which is beneficial for your plants. Compost is also a fertiliser, so by adding it, you are able to reduce the amount of artificial fertilisers that you are using.

Everything changes the regulation 2003/2003 proposes a fact a list of products already on the market; already known as such we find the description of element that allows to identify nitrate, ammonium sulphate etc. Therefore, the products are sold under the name of the product category you will find with the implementation of this product regulation that are called example 1.A seed 2 that are of liquid organic fertilizer. We do not have in fact obligatorily any more a place with a nature or materials of origin. We lose the (old) natural definition by no longer necessarily having a description with the nature of the product. But there are obvious elements such as organic A-fertilizer that must be contained in the nutritious organic fertilizer of exclusively biological origin, knowing that it and extended in little the hunt for fossil materials, exceptions of certain numbers that are still considered indispensable. Minerals are defined in a little bit by exclusion of organic, whereas only now there was a distinction between organic and inorganic and organic carbon and mineral.

No voluntarily biochar certificates does not have any legal or technical right for commercial use of biochar.

1. Mandatory Authority permit for establishment/building construction of industrial facility and operate it under valid EU regulations applied by the MS. Usually several Authorities involved.
2. Mandatory Authority permit to market, label and apply biochar products in agricultural soil under valid EU regulations applied by the MS. Beyond July 16, 2022 EU 2019/1009 FRP might be applied (if included in the ANNEX IN 2021).
3. Mandatory REACH certificate above 1 t/y capacity import, manufacturing, placing on the market and application.
4. Extended producer responsibility and liability schedule.

The market for plant based biochar is generally as soil improver or growing media. Plant based biochar does not containing nutrients with economical importance, so this is not a fertilizer, but having combined effects in soil. Dose 5 t/ha to 20 t/ha, average 10 t/ha and no need to yearly application. Case by case application strategy to be build up and different formulation to be considered. EXW whole market prices are from €500/t or rather from €750/t, on end-user level >€1000/t.

The biochar product quality, environmental/human safety is most importantly and critically depending on the pyrolysis industrial technology performance quality level. The advanced reductive heat treatment systems are the basis for safe biochar products, whereas the key process and product quality indicator is the presence of the PAHs that is a fingerprint of the technology and product quality.

The occurrence of PAHs in  primarily derive from obsolete, low grade and inefficient pyrolysis technology design and processing condition, but in the plant based  cases also from contaminated and/or improper selected feed stocks as well.

PAH19s can be considered as the key organic pollutants and key indicator for all types of biochar product quality. There are several type of PAHs depending on the number of connecting benzene rings. To get information about specific PAHs represented in biochar, not only 16 priority PAHs (based on US EPA) were measured but the 19 most common components, that modern PAH19 measurement system is mandatory in several EU member States since 2006, often with limit PAH19 as low as 1 mg/kg.

Notice: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4714241/ The 16 EPA PAHs have played an exceptionally large role above all in environmental and analytical sciences in the last 40 years, but now there are good reasons to question their utility in many circumstances even though their use is so established and comfortable. The list of 16 polycyclic aromatic hydrocarbons (PAHs), issued by the U.S. Environmental Protection Agency (EPA) in 1976 (1) with a view to use chemical analysis for assessing risks to human health from drinking water, has gained a tremendous role as a standardized set of compounds to be analyzed, quite especially in environmental studies. Although not mandated by law in most countries, it appears that the list has attained the authority of a legal document and that the 16 compounds (“priority PAHs”) are routinely investigated in a large number of environmental situations. In this context, environmental is seen in a broader context and thus includes topics like food, too.

PCB7 and PCDD/F are not target contaminations in biochar based products. In no any cases have Polychlorinated dibenzodioxins (PCDDs) and Polychlorinated dibenzofurans PCDFs been identified as target contamination as these compounds are predominantly formed at temperatures exceeding 1000°C while the the feed material streams having low chlorine content. Therefore, the risk of dioxins and furans contamination in biochar products is low.

No, flash pyrolysis is developed, designed and applied for powdered fine ground biomass feed material processing that is objective driven for bio-energy production where majority of the feedstock is converted into oil (high liquid gas/oil yield and low solid carbon yield, where the carbon quality differently accounts as this is an energetic carbon vs  into soil).

The surface area, particle volume, and porosity are important characteristics for all pyrolysis processed carbon materials. Solid materials interact with their environment at their surfaces. Solids with larger surface areas would therefore be subject to greater effects from outside influences, when compared with identical materials which have smaller exposed surface areas. The surface area of a solid varies as the square of its dimensions, whereas the volume of a solid varies as the cube of its dimensions.

Smaller particles having larger surface area than larger particles, but larger surface area above 300 m2/g means also high chemical activity, which might be advantageous at adsorbent use in water, but highly disadvantageous with negative effects for  applications in living soil environment. The critically important character is the pore size and volume, as these area/volume relationships apply equally to pore size as they do to particle size. Only when particle sizes, surface areas, and pore/void measurements are available can truly meaningful comparisons between different samples of the same material be made. Depending of the pyrolysis technology performance and the feed material characteristics together, two samples with similar dimensions, but with differing porosities, may have dramatically different pore volumes and surface areas. Soil microbes prefer macrospores structures to have enough space, as their biological dimensions are larger than 2 nm. Porosity structures.

This is a possible feed, but not optimal. Poultry manure may contain high Zn/Cu, that may be over high concentrated in the char, while the thermal processing is destroying valuable organics in the manure, that are otherwise providing higher economical value in the composted manure as it is with no treatment than the char products after processing. Poultry manure itself is very low nutrient dense material (<5% P2O5) with low economical interest for the users, as the extra cost for processing is not reflected in the nutrient density value. Poultry manure is fine grain sized and that powder like material is challenging to further formulate and apply in practice under full industrial conditions. Application dose rates are high, such as 10 t/ha. However, it is to be remarked, that  processing also means total sterilization of this material that is a plus environmental safety value for poultry manure case.

No, hydrochar when char is made by hydrothermal carbonisation is not a biochar. HTC is an LABILE CARBON (or leachable C) solution, that is a pre-treatment process of wet biomass, for energetic applications aiming to improve the quality of solid fuel compared to raw biomass. Torrefaction and HTC hydrothermal carbonisation<280°C (depolymerisation): the material core temperature is in the range of 180°C to 280°C and there is a partial pyrolysis decomposition reaction in the material during this stage, most importantly removal of chemically bounded water. „Hydrothermal char decomposes rapidly (50% in 100 days regardless of soil type) and can stimulate emissions of GHG”. In this context chars produced by slow pyrolysis and hydrothermal carbonization vary in carbon sequestration potential and greenhouse gases emissions (Soil Biology & Biochemistry 62 (2013) 137e146). HTC is not applicable for industrial pyrolysis processing that is resulting safe carbonized SOLID CARBON biochar products for stabile carbon soil agri applications. HTC is not biochar and as labile carbon the C degradation is usually rapidly decomposing in soil with approx. 1.5 years to 7.4 years C loss half life and converted into GHG CO2 gases, while improving the N2O emissions as well.

Primarily the biochar processing technology engineering design and performance quality is the prime definition factor to determine the output biochar product quality, safety and application value. Obsolete biochar processing technologies resulting low end carbon products, that are qualified for energetic carbons, but not for safe biochar for agri use. Secondarily the selected feed material characteristics are also important factors that are reflected in the output biochar product character.

No biochar is not a new product. In modern age since 1870, the time of the technology revolution, many carbon processing technologies and many different types of carbon products developed, produced and applied in large industrial scale, especially related to the WWI, WWII and past decades of activated carbon operations. The carbon processing technologies and carbon products are the most extensively scientific/technical researched and technological developed past 150 years. Majority of the carbon processing technologies and carbon products developed for energetic and activated carbon adsorbent applications. Some of them have been successful, others are not. However, the new environmental and climate challenges of the 21st century require to develop new generation innovative biochar processing technologies towards zero emission performance, and new products with new applications. Due to the new environmental improvements and strict regulations, new technologies and methods need to be developed.

• having no  specific and mandatory EU and MS Authority permits for import, manufacturing, placing on the market and application above 1 t/year capacity, and/or
• having no  specific and mandatory REACH ecotox certification above 1 t/year capacity import, manufacturing, placing on the market and application, and/or
• having no labelled Extended Producer Responsibility certificate, and/or
• the output  product economical value and free market valorisation is not based on common market demands and commercialization process, e.g.  product valorization may not be based on grants and subsidies, and/or
• does not meet the quality to be irrevocably put into open ecological soil environment, and/or made from input feed material, that is not sustainable, and/or
• made for renewable biofuel with energy functionalities (torrefraction, hydrothermal carbonization chars).

1. mandatory EU and MS Government Authority permits for import, manufacturing, placing on the market and application above 1 t/year capacity,
2. REACH certified above 1 t/year capacity import, manufacturing, placing on the market and application,
3. labelled and full value chain safe product,
4. having Extended Producer Responsibly product guarantees,
5. the input material made from is sustainable sourced, e.g. not competing with human food, animal feed and plant nutrition supply, not from primarily and secondarily land use and having environmentally sustainable logistics, while meets the EU Circular Economy incentive relevant sections.

Biochar is plant and/or animal bone biomass origin stabile carbon carboniferous pyrolysis material, that is reductive thermal treatment processed under at least 10 minutes between at least 400ºC and 850ºC material core final temperature. Biochar is Authority permitted/legally labelled product with soil functionality application driven character, such as solid organic fertilizer and/or organic soil improver and/or other product functional substances. There are three different feed material characters with specific treatment scenarios for safe biochar production:

1. Input materials (Point 1 of CMC14 Annex I.):
   1. pyrolysis processed above 400ºC material core final temperature for at least 10 minutes residence time or
   2. gasified above 750ºC material core temperature for at least 2 seconds residence time.
2. Input materials (Point 4 of CMC14 Annex I, manure):
   1. pyrolysis processed above 500ºC material core final temperature for at least 10 minutes residence time or
   2. gasified above 750ºC material core temperature for at least 2 seconds.
3. Input materials (Point 4 of CMC14 Annex I, except manure):
   1.  pyrolysis processed above 750ºC material core final temperature for at least 10 minutes or
   2. gasified above 750ºC material core temperature for at least 2 seconds.

It is important to nuance this difference since we worked with 60% compost in the pots here, which is very much. In a normal culture this content will be maximum 30% so the shifts in pH and EC will be lower. The effect on growth is also variable, some plants such as Acer may show a reduced growth due to this, while Chrysanthemum seems to tolerate it perfectly. An assessment per crop is necessary here.

Since most standard fertilisers contain multiple nutrients (generally N, P, K and Mg), it is impossible to give all plants in a trial the same amount of all nutrients as present in compost. Therefore, you must focus on the most important one and for growth of Acer campestre, that is nitrogen. In addition, nutrient leaching and nutrient levels in the pot at the end of the growing season show, in addition to our growth and plant quality measurements show that we are already over-fertilizing. More nutrients are therefore not a good idea. The advantage of using compost is exactly that you will need fewer other fertilizers.

In Flanders, Bokashi is not a standardised processing (no legal framework). The input streams, for example, do not undergo a temperature increase which results in the hygienisation of (farm) composting. Compost is also more stable in the soil, while there is a higher conversion and release of nutrients and other substances when using Bokashi.

Straw does indeed have other interesting uses. However, on several farms it is also added to the composting process.

Clay is sometimes added to create clay-humus complexes. You must be careful with this because the temperature then increases less and the hygienisation is more difficult.

A compost cloth is laid on the ridges to avoid too much water in the heaps. This minimises leaching and the loss of nutrients. These cloths do allow air to pass through.

Hygienisation is a key issue in the certification process of compost: producers must be able to demonstrate during the audit that they use the required process temperatures. This guarantees pure end products that are free of pathogens, weed seeds and micro-/macrobial life. The latter organisms subsequently colonise the compost again (after maturation). Compost therefore also has an effect on, a.o., the presence of worm populations.

During compost quality control, a lot of attention is going to the reomoval of impurities. There are strict standards.

In order to facilitate soil improvement from certified compost, a.o., there are partial exemptions from P content in the fertilizer action plan (Flanders).

We have not yet experienced that the processability was worse due to the use of mineral concentrate.

For manure separation at source, the economic advantage of the investment made (barn system) is in the lower disposal costs. Moreover, the solid manure is better suitable for anaerobic digestion (higher biogas yield). Furhtermore, due to the separation process, there are less NH₃-emissions.

Nutrients have a negative unit price in areas where there is an excess of manure (e.g. Flanders and the Netherlands), whereas mineral N as fertiliser has a positive value. This dispersion in unit valuation can be a strong economic driver for recovery. Of course, an extra driver is also the environmental point of view. Depending on origin (chemical or non-chemical scrubber water, nutrient content, high purity, higher pH, etc.) the price can vary between 0 and 10 EUR/m³. This product is automatically available if there is a chemical air scrubber. So if the end product of the scrubber can be used as a fertiliser, this is an extra advantage.