Food Waste and Catering Waste; Focus on Valorisation of Used Cooking Oil and Recovered Triglycerides - The Economic Utilisation of Food Co-Products - page 95

This procedure requires compliance with an ''approved standard'', which in
the case of the conversion of UCOs and some recovered fats into chemicals and
other potentially valuable products (materials and other fuels) does not exist,
due to a number of reasons mainly related to the potential variability and lack
of traceability of the raw materials. The reprocessing of UCOs and animal
by-products into different products regardless of their purpose, with or without
the production of energy may constitute ''recycling'' or ''other'' recovery or
possibly even pre-treatment steps. At that stage, every case would have to be
analysed individually, in order to evaluate whether the process in question has a
positive environmental effect or having undergone recycling. These procedures
may be perceived by potential producers and organisations both as an
opportunity to acquire end-of-waste status or an administrative constraint.
The quality protocol/''end-of-waste'' approach is intended to incentivise
processors generating waste, to address their issues with food waste and prove
the viability of an end-of-waste status by producing as much information as
possible for the waste in question. This approach is expected to have very
significant commercial implications with the extension of the Quality Protocols
approach, being a positive step towards strengthening the economic potential
of wastes where there is uncertainty over end-of-waste status.

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6.4.2 REACH Legislation
A potential policy and regulatory disincentive to the reprocessing of food wastes
into chemical substances is the consequence of end-of-waste status and chemical
substances legislation, most notably through Regulation (EC) No. 2006/1907 on
the Registration Evaluation Authorisation and Restriction of Chemicals
(REACH). 42 This requires all those who manufacture in the EU in quantities of
one tonne or more per annum per manufacturer (or who meet the threshold
criteria in an importer capacity) to obtain a registration for the chemical
concerned, without which the substance cannot be placed on the market within
the EU. Despite provisions that enable producers/ importers to share the cost of
obtaining all the necessary hazard and risk data required to register the same
substance, the testing and administrative costs of achieving a registration are
nonetheless considerable. Thus, small-scale producers in the EU, particularly of
novel substances/ mixtures resulting from food waste reprocessing, may
ultimately find the compliance costs of REACH legislation a major barrier to the
commercial viability of the process. With other major economies outside the EU
also showing interest in adopting similar legislation to REACH (including the
US and China), 43 even manufacturing and distribution outside of the EU may at
some point become unviable and therefore the usability of this type of as
feedstock within the manufacturing industry.

6.5 Valorisation Routes
The situation in the EU with regard to FW/ Bio waste/ FSCW regulation
exemplifies the potential impact that research in the area can have into driving