Anaerobic digestion of animal by-products (ABPs): regulatory changes and compliance (Decree of April 9, 2018, effective as of January 1, 2023)

The anaerobic digestion of animal by-products (ABPs) is regulated by European Regulation (EC) No. 1069/2009, which classifies these materials into three categories based on their sanitary risk level :

Category 1 : High sanitary risk (excluded from any recovery)
Category 2 : Moderate risk (e.g., manure)
Category 3 : Low risk (e.g., food waste)

Certain animal by-products from Categories 2 and 3 can be recovered through anaerobic digestion, provided that strict hygienization requirements are met. This process involves heating the material to 70°C for 1 hour with a maximum particle size of 12 mm, in order to reduce biological and sanitary risks.

Decree of April 9, 2018: End of Exemptions and New Obligations

Historically, some anaerobic digestion facilities were granted an exemption allowing them to treat non-hygienized livestock effluents alongside hygienized food waste on-site. However, the Decree of April 9, 2018 ended this practice, mandating mandatory compliance since January 1, 2023.

Key points of compliance :

Raw meat or aquatic animal by-products (ABPs) not listed on the exclusive list of materials compatible with the exemption will downgrade the entire food waste stream.
Only ICPE 2781-2 facilities are authorized to treat food waste through anaerobic digestion.
Off-site hygienization requires maintaining biological safety criteria, including a temperature above 50°C until the material reaches the anaerobic digestion sites. This regulatory requirement is often not met due to logistical constraints, increasing biological and sanitary risks.

What solutions are available to comply with the regulations?

Several solutions exist for operators wishing to continue recovering their food waste while complying with the regulations :

Addition of a dedicated digester for food waste recovery:
- Total separation of streams to maintain the exemption for hygienization of livestock effluents (mixing only allowed in post-storage).
- Significant land area required with traditional infinitely mixed technology, which is unstable in mono-feeding of food waste.
Selective collection of food waste without raw ABPs:
- Implementation of two separate collections.
- In practice, collectors often perform a combined collection of all food waste.
Off-site hygienization before anaerobic digestion:
- Solution requiring the maintenance of biological safety criteria for hygienized food waste until it reaches the anaerobic digestion sites.
- Frequent non-compliance due to failure to maintain biological safety criteria during transport, leading to sanitary risks.
Hygienization of 100% of ABPs prior to anaerobic digestion:
- Regulatory compliance.
- High energy consumption for hygienizing livestock effluents, with limited technical feasibility for solid effluents.

The BioRenGaz solution: performance and compliance

In the face of these challenges, BioRenGaz offers a compact and high-performance anaerobic digestion solution that reduces land footprint by up to 90%, lowers operational costs by 75%, while increasing biogas production by 10%.

Our patented technology is based on:

✅ A dedicated digester, integrated alongside the existing installation.

✅ A more compact unit, providing a significant space-saving advantage.

✅ BioRenGaz innovation: a 100% renewable, biosourced and recycled culture carrier, offering a high-performance and sustainable solution for optimized anaerobic digestion.

In conclusion

Regulatory compliance is now essential for operators wishing to recover animal by-products through anaerobic digestion. With the Decree of April 9, 2018 and the deadline of January 1, 2023, it is crucial to choose suitable technical solutions.

BioRenGaz supports industry players in this transition by offering innovative, high-performance technology that is fully compliant with the regulations.

Discover and download the guide here :