Abstract
The European Directive 86/278/EEC implemented in 1986 was a means adopted by the European Union to improve use of the valuables in sewage sludge by applying treated sludge on agricultural soils. To prevent an accumulation of pollutants, the Directive provided suggestions limiting concentrations of toxic elements in sewage sludge and agricultural soil. The Directive was implemented diversely throughout EU member states, with current national legislations only partly reflecting the initial intentions of the EU Directive from 30 years ago. This study demonstrates how the European Directive was implemented in three countries currently at different stages of replacing the agricultural application of sewage sludge with incineration (Netherlands, Germany and Sweden). Additionally, recent changes in the legislation with regards to the re-use and final disposal of sewage sludge in the three chosen member states are analysed. The aim was to investigate how each member state has solved the conflict between improvement of nutrient recovery from sludge and limitation of pollutants in agricultural soil. Based on this review, limit values are not necessarily reflected in application rates of sewage sludge in agriculture. Following changes in current legislation, phosphorus recovery will become a priority task. The recovery of other valuables from sewage sludge is currently not regulated in the legislation of the three member states investigated.
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