Circular entrepreneurship involves no waste

Phosphate is an important building block for humans, animals, and plants: it is in our bones and plays a key role in energy metabolism. Additionally, we mainly use phosphate for fertilisers, which are essential for feeding the world’s population. Everyone intake phosphate through food and then excretes it again, explains Marga Breeuwsma. She is Business Developer at SusPhos, a company that extracts phosphate from the ash of burned sewage sludge from water treatment plants, to reuse it as a raw material for, for example, fertilisers.

In addition to phosphate, SusPhos produces a second product from sewage sludge ash, which is used as a binder within the cement industry. The recovery of valuable raw materials from waste in this way is also called ‘urban mining’. 

Although there is a lot of phosphate waste in our country, we primarily obtain phosphate from polluting and finite mines. These mines are often located far away, leading to polluting transport and geopolitical dependence, as Marga explains. Representing SusPhos, she is closely involved in obtaining the end-of-waste status; this turns out to be a bumpy road.

“For the fertiliser industry, our product complies with the standards of the Fertilizer Product Regulation and we do not need end-of-waste status. For cement, this legislation does not exist, so we cannot do anything with the product. Simply put: we want to sell our cement product, but we currently cannot. If it remains a waste product, it is not profitable to produce. It is entirely justified that consumer and environmental safety take priority, and there is no debate about that. But the bureaucratic sluggishness of legislation is now hindering green entrepreneurs; and with it, the energy and raw material transition.” 

Lobbying Together

As a relatively small organisation, SusPhos seeks to connect with initiatives such as the End-of-Waste project to generate momentum. “We are too small to influence legislation and regulations alone,” Marga explains. “With this project, we join forces with other entrepreneurs, Invest-NL, and Green Chemistry, New Economy. This way, we create more lobbying power collectively. Additionally, organised attention is important for structuring and dialogue. The brainstorming at End-of-Waste led to clear guidelines on when something is considered end-of-waste.” 

Transparency 

Arnold Stokking, as chair of the Green Chemistry, New Economy platform, is linked to End-of-Waste. He explains that the project initiated by Invest-NL is based on three steps: identifying bottlenecks, defining solutions, and creating an action plan. “The End-of-Waste project helped to sharpen the goals for our lobbying agenda significantly.” 

The project also led to tangible results, Arnold continues. Navigating legal regulations for entrepreneurs can sometimes be an exhausting task because many different authorities are involved in end-of-waste issues. This leads to differences in policies and rules, making it challenging to act at national and international levels. 

As part of End-of-Waste, a study was conducted, and based on that, a report was created to make legislation and regulations transparent. “End-of-Waste significantly helped many entrepreneurs; it’s nearly impossible for each individual entrepreneur to understand all provincial, national, and European rules,” Arnold concludes. 

More certainty for entrepreneurs 

During the sessions of the End-of-Waste project, where entrepreneurs, environmental agencies, government bodies, and other parties participated, various solutions were brought forward. For example, we could move from an ‘end-of-waste legal ruling’ (as is currently the case) to a European model of resource declarations. Arnold explains that this should become a system of national resource declarations, whereby a Dutch resource declaration is also valid for other EU countries and vice versa. “It’s not about waste from the past, but about resources for the future. The Netherlands should fight as a member state of Europe to ensure that we approve each other's resource declarations in Europe.” 

Invest-NL started the project, took the lead, and flagged with politicians that it is truly time for a solution. The insights gained from the End-of-Waste project have been incorporated into policy advice that was presented to the Ministry of Infrastructure and Water Management, explains Xandra Weinbeck, who was the initiator of the project on behalf of Invest-NL.

The document includes, among other things, advice to establish binding agreements with neighboring countries and a recommendation for the introduction of a voluntary certification system. It also contains criteria that clarify when something is considered end-of-waste. “In 2024, several parties, including NVO-NCW and the Association of Water Boards, will work on our key points,” says Xandra. 

Despite the efforts of the End-of-Waste project, many green entrepreneurs still struggle to obtain end-of-waste status because legislation has not been modernised. “This lack of legal certainty has been a problem for ten years, and it’s still not well organised,” says Xandra. “This is how the circular economy cannot get started, and we’re not helping innovative entrepreneurs.” 

Conducting international trade 

Xandra explains that the lack of legal certainty for entrepreneurs leads to ‘delayed investments and customers demanding more certainty before committing to the purchase of recycled products’. Xandra: “This limits the growth of existing companies and the emergence of new companies that want to reuse waste. Therefore, it is important that the process around end-of-waste status becomes transparent and effective, and obstacles are removed, so that entrepreneurs and investors gain confidence.” 

Marga from SusPhos stresses that ‘only economic opportunities keep the green train running’. “The End-of-Waste project helps, but more people need to get involved to promote circularity in the Netherlands.” Arnold from Groene Chemie, Nieuwe Economie adds: “We are not looking for local or national solutions, but want entrepreneurs to be able to trade internationally with certainty. For the End-of-Waste project, we formed a coalition of parties that continues to do its best to make entrepreneurs’ voices heard.”