SEPA Call for Evidence: Technical requirements for larger non-waste AD plants

DATE

Oct 28, 2025

TAG

On 6th October, SEPA announced a ‘Call for Evidence: Non Waste Anaerobic Digestion over 100 tonnes per day: Permit technical requirements.’ Through this call for evidence, SEPA seeks input on the proposed technical requirements for non-waste AD plants handling over 100 tonnes per day. These technical requirements will inform the permit conditions for large non-waste AD sites after 1st April 2028.

Context:

While AD using waste feedstocks has been regulated for decades because of its potential to cause environmental harm, Scottish Government’s Business Regulatory Impact Assessment (BRIA) has found that AD processes using non-waste materials (e.g., crop-fed AD plants) carry similar risks to the environment.

Following extensive engagement and consultation, the Environmental Authorisation (Scotland) Amendment Regulations 2025 introduced regulation for non-waste AD processes as a schedule 26 Part 3 Chapter 5 ‘other emissions activities’. Through this regulation, all non-waste AD sites in Scotland will be required to hold a permit or registration under EASR from 1st April 2028

The next step is for SEPA to develop the appropriate permit conditions for large non-waste AD sites, starting with this call for evidence. (Note: The non-waste AD under 100 tonnes per day registration standard conditions were consulted upon in September 2024 and published on SEPA’s website and are aligned with the waste AD registration requirements.)

Scope of Call for Evidence:

To align regulatory requirements for all AD plants, SEPA intend to utilise the Waste Treatment Best Available Techniques (BAT) Conclusions as a starting point. Through this call for evidence, SEPA seeks to understand the extent to which non-waste AD plants already comply with the relevant Waste Treatment BAT conclusions, how sites that are not currently compliant could become compliant, and any gaps or issues with meeting the standard.

You can view the full call for evidence here. The closing date for responses is 9th January 2026. Please share any comments with [email protected] by 19th December 2025.