Statement to MOEW to enquiry for imposing criteria on RDF

Co-processing of alternative fuels (AF) in general and of refuse-derived fuel (RDF) are good examples of circular economy since they can reduce CO2 emissions and landfilling to the benefit of the society. The cement industry in Bulgaria has invested hundreds of millions of euro for the necessary environmental investments to co-process AF in a sustainable way.

In respect to MOEW enquiry, for imposing criteria on RDF (EWC codes 19 12 10 and 19 12 12), BACI requested to be taken into consideration, that every industrial facility has different requirements and limitations based on the process technology, type of conventional fuels used, type of raw material etc. In this respect it is not practical to provide you with specific common criteria, since these criteria should be different for every installation. What is important however, is that every industrial facility operates with fuel steams according to their technical capacities within the frame set in the environmental permits and has in place an appropriate quality control system to pre-select and continuously monitor the quality of wastes used as alternative fuels in order to assure compliance with the emissions limits of their permits.

The Bulgarian cement industry is assuring that the RDF/SRF quality of the material used is tested and evaluated to meet the set quality requirements and moisture content to ensure stable operational process and environmental performance, independently of local or imported origin. By this, we can make sure that we are always on the same high level of quality assurance like other EU members.

Availability of local streams with stable characteristics like calorific value and quality would be always a priority stream for us, rather than imported RDF, thus we highly appreciate MOEW’s efforts towards better efficiency in waste management and co-processing and we would like to ensure MOEW that the cement industry will be a reliable partner in all these initiatives.