Posted: 20 October, 2025. Written by REAL
The BCS is pleased to announce the publication of the Anaerobic Digestate Resource Framework (ADRF) alongside two Regulatory Position Statements (RPS 317 and RPS 358), which have come into force today in England. These documents are now publicly available and can be accessed on the .gov website here:
The ADRF and RPS’s will apply in England only.
The ADRF will replace the Anaerobic Digestion Quality Protocol (ADQP) effective immediately upon its publication and will serve the same function; outlining the quality criteria, standards and specifications for digestate derived from the anaerobic digestion of source-segregated biodegradable waste. It details the conditions under which digestate ceases to be classified as waste and thus, can be supplied/used without waste management controls or exemptions.
Please note that the ADQP remains effective in Wales and Northern Ireland until further notice, and SEPA’s Regulatory Position Statement for Digestate remains effective in Scotland (though please note that this was updated in June 2025). The BCS has produced a guidance document for producers about the different certification requirements in each nation, linked here: Guidance For EoW Compliance in Each UK nation.
Specific Plastic Limit Introduction
There will be a new plastic contamination threshold for digestate which will be 8% of the current PAS110 physical contaminant limits. A two-year exemption period is in place, allowing digestate producers time to work towards meeting these new limits. This is covered by the Environment Agency’s RPS 317, which can be found here above. Operators will need to notify the EA of their intention to utilise the RPS.
However, please be aware that after the ADRF has been fully implemented into the BCS on 20th October, all lab test reports for samples registered from this date will show the new limits and will report to these limits. Therefore, operators should be aware that some test results may indicate a failure that will not yet be considered a non-compliance in the following circumstances:
Instead, the test reports would signal that such samples would fail after the exemption period expires. This decision was taken by BCS after considering the potential risks and issues with updating the reporting templates and through consultation with the BCS Technical Advisory Committee. We will provide a fact sheet for operators and end users explaining this change to plastic reporting.
Changes to Permissible Wastes
The ADRF introduces waste code updates that refine compliance and safety standards for digestate production. Specific waste codes have been added to, changed, or removed from this framework to reflect the EA’s current regulatory and environmental requirements. Please refer to Section 2 of the CRF for the list of permissible wastes to check the codes you currently accept.
Codes added to the ADRF:
02 07 05 (alcoholic and non-alcoholic beverage sludge)
04 02 21 (wastes from unprocessed textile fibres)
Codes removed from the ADRF:
02 02 99 (wastes not otherwise specified from prep of meat, fish etc)
02 03 99 (wastes not otherwise specified from fruit, veg, cereals etc)
02 04 99 (other biodegradable wastes from sugar processing)
02 07 99 (wastes not otherwise specified from production of beverages)
03 01 01 (untreated waste bark and cork)
03 01 05 (untreated sawdust, shavings, cuttings etc)
04 01 01 (wastes from leather industry)
19 05 99 (wastes not otherwise specified from aerobic treatment of wastes)
20 01 38 (wood other than that mentioned in 20 01 37 (treated wood))
If you have any questions or concerns regarding the changes in waste codes, it is the advice of the EA that you contact your local Environment Agency officer.
Updates to the criteria for achieving End-of-Waste
In accordance with the ADRF, End-of-Waste is now achieved at the point of dispatch. With this, there are allowances for storing materials as a non-waste prior to dispatch, though this is only permissible through the provision of contracts of supply and/or the previous 12 months’ supply records. Should either of these be provided, AD operators may store their digestate batches for no more than 10 months.
Should these documents not be presented, operators will need to store their digestate as waste until they dispatch it to the customer. RPS 358 gives producers 12 months to obtain environmental permits for their storage areas. Operators will need to notify the Environment Agency of their intent to use this RPS, in accordance with this RPS.
Digestate Now Permitted for Horticulture
The ADRF outlines specific requirements for the new market of amateur horticulture which is that all digestate destined for this market must be supplied to a member of the Responsible Sourcing Scheme (https://www.responsiblesourcing.org.uk).
Even though there is no limitation on which types of digestate can be supplied to horticulture, it is expected that the large majority of digestate supplied will be the Separated Fibre fraction.
The ADRF, along with the accompanying RPSs, are essential for regulatory compliance, human health protection, and environmental safety. We strongly encourage all certified AD operators in England, and potentially Wales and Northern Ireland, to review the ADRF, RPS 317, RPS 358, and Scheme documents thoroughly to understand how they might be affected by these changes.
Instructions for Using the RPSs
RPS 317
Operators intending to use RPS 317 must follow these steps:
Email resourcesframeworks@environment-agency.gov.uk by Wednesday the 20th of April 2026 with the subject line including ‘RPS 317’. The email must include:
Within 6 months of sending this email registering to use this RPS, send a second email to resources.framework@environment-agency.gov.uk, copying rps@realschemes.org.uk, with the subject line also including ‘RPS 317’ and the email including:
Please refer to the RPS linked above for all the other conditions of RPS usage.
RPS 358
Operators intending to use RPS 358 for temporary storage must follow these steps:
Email resourcesframeworks@environment-agency.gov.uk by 31st December 2025 with Subject line including ‘RPS 358’. The email must include:
Please refer to the RPS linked above for all the other conditions of RPS usage.
Updated BCS Scheme Rules and BCS Position on Technical Requirements
The BCS has issued updated versions of the Scheme Rules and Position on Technical Requirements. These documents are available on the BCS website here and come into effect immediately.
Key changes in the scheme rules include:
Events for Scheme Participants
Two events will help Scheme Participants understand the ADRF and regulatory changes:
To register for the ADRF webinar, email duncan@realschemes.org.uk.
To attend the forum, email oliver@realschemes.org.uk.