What Is Holding Back Europe's Circular Bioeconomy?
Lessons from PRIMED’s five Living Labs
Turning agricultural residues, forestry by-products and food processing waste into valuable resources offers significant opportunities for Europe’s primary sector. From recovered fertilisers and bio-based materials to biochar and innovative food ingredients, new circular value chains can help reduce waste, diversify income and create more sustainable production systems. Nevertheless, developing a promising technology is only the first step. For farmers, cooperatives and businesses, the real challenge often lies in making these solutions commercially viable while navigating regulatory requirements, securing investment and accessing markets.
Through its 5 Living Labs (LLABs) in Spain, Portugal, Italy, Ireland and Finland, the PRIMED project has identified some of the main barriers preventing circular bio-based solutions from reaching the market. The findings, presented in Deliverable D7.2, highlight practical lessons for stakeholders interested in developing new value chains from biomass residues.
Turning livestock manure into fertilisers: understanding the rules
Livestock manure can be transformed through anaerobic digestion into digestate, a nutrient-rich material with the potential to reduce dependence on synthetic fertilisers.
At PRIMED’s LLAB in Spain (LLAB1), coordinated by ALC, this approach is being explored as part of a circular nutrient management system. Yet, even when the technology is available, the use of recovered nutrients depends on compliance with waste, fertiliser and nitrate regulations.
One particularly relevant development is the EU framework for Recovered Nitrogen from Manure (RENURE), which allows Member States to authorise certain processed manure-derived fertilisers under specific conditions and environmental safeguards.
What does this mean for farmers?
Before integrating recovered nutrients into fertilisation practices, farmers and cooperatives should verify whether the material meets the applicable quality and traceability requirements, whether its use is authorised nationally or regionally, and which nutrient application limits apply to their land. Early clarification of these conditions can help avoid investment in solutions that cannot yet be commercially deployed.
Agricultural residues: when can waste become a resource?
Agricultural residues such as rice husks and straw can become valuable feedstocks for innovative bio-based materials. In Portugal, PRIMED’s LLAB2 led by CeNTI is exploring the valorisation of silica-rich agricultural residues to produce bio-silica for industrial applications. Nonetheless, one of the main challenges is determining whether these materials are legally considered waste or by-products. This distinction can significantly affect how they are collected, transported, processed and commercialised.
Unclear classifications, together with limited investment capacity and market awareness, can discourage companies from adopting new circular solutions.
What should producers and businesses consider?
Before establishing a new supply agreement, it is important to clarify the regulatory status of the residue, identify authorised processing partners and define the quality, quantity and consistency of the feedstock required.
PRIMED also highlights the importance of collaboration between producers, industry and public authorities. Regional Shared Agendas can help stakeholders identify common challenges, coordinate investments and develop solutions adapted to local needs.
Fish processing residues: regulatory clarity is essential
Fish-processing activities generate residues such as heads, bones, skin and viscera, which can become valuable raw materials for new bio-based products, including agricultural biostimulants.
In PRIMED’s Italian LLAB3, coordinated by FILSE, the valorisation of these side streams faces regulatory challenges related to their classification as animal by-products and the requirements governing their processing and use.
Under EU legislation, animal by-products are classified into different categories depending on their associated risks. This classification determines which processing methods and applications are permitted. Unclear authorisation procedures and differences in regulatory implementation can therefore limit opportunities to develop new circular value chains.
What should fishers and fish processors know?
Before supplying fish-processing residues for valorisation, it is important to understand how the material is classified, whether it can be used for the intended application and which processing requirements apply.
Separating and identifying different residue streams, together with early engagement with processors and competent authorities, can help ensure that the materials are suitable for their intended use and avoid regulatory obstacles during the development of new bio-based products.
Forestry residues and biochar: assess the market before investing
Forestry residues offer another opportunity for circular valorisation. Through pyrolysis, biomass can be converted into biochar, a carbon-rich material with potential applications in agriculture and other sectors.
In Ireland, PRIMED’s LLAB4, coordinated by IBF, is exploring opportunities for biochar production from forestry residues. However, technological feasibility alone does not guarantee a viable business model.
One important challenge concerns the regulatory classification and environmental permitting of pyrolysis facilities. As these installations can generate atmospheric emissions, their development may involve specific environmental requirements and concerns from local communities, potentially complicating the authorisation and deployment process. Additionally, uncertainty around end-of-waste criteria, biochar product standards, permitted applications and access to financing can limit commercial development. Although carbon credits may provide additional revenue opportunities, their contribution depends on certification, verification requirements and market conditions.
What should forest owners and entrepreneurs consider?
Before investing in biochar production, stakeholders should assess not only biomass availability, production costs and market demand, but also the environmental permits required for pyrolysis facilities, applicable emission standards and potential local acceptance challenges.
Early engagement with environmental authorities and local communities, alongside a realistic assessment of potential revenues, can help identify barriers before committing significant investment.
Novel food ingredients: plan for market approval from the beginning
Innovative ingredients produced through cellular agriculture and plant cell cultivation offer opportunities to develop new products while making more efficient use of biological resources. At PRIMED’s Finnish LLAB5, coordinated by VTT, regulatory uncertainty surrounding Novel Food authorisation has been identified as a significant challenge. The approval process may require extensive safety data and additional scientific studies, introducing uncertainty around the resources and time needed to reach the market.
For companies developing novel food ingredients, regulatory planning should therefore form part of the innovation strategy from the outset.
Identifying applicable requirements, preparing the necessary scientific evidence and seeking early regulatory guidance can help companies make better-informed development and investment decisions.
What can we learn from PRIMED’s Living Labs?
Although the five Living Labs work with different biomass resources and technologies, their experiences point to a common conclusion: successful circular bioeconomy initiatives require more than technical innovation.
Regulatory clarity, market demand, financial viability and cooperation across the value chain are equally important.
Practical considerations for circular bio-based value chains
For farmers, primary producers, cooperatives and businesses considering new biomass valorisation opportunities, PRIMED highlights four practical priorities:
- Check the regulatory framework early: understand how the biomass is classified, which processing activities are permitted and what requirements apply to the final product.
- Validate the business case: assess feedstock costs, investment requirements, potential customers and realistic revenues before scaling up.
- Engage the right stakeholders: involve producers, processors, technology developers and public authorities to identify potential barriers before significant investments are made.
- Explore collaborative solutions: shared Agendas, pilot validation activities and regulatory sandboxes can help connect regional stakeholders and support the development of innovative value chains.
The findings are presented in PRIMED’s Deliverable D7.2, Framework Condition Impact on Value Chain Delivery: Business Case Examples for Focal Points, developed by EuropaBio. Building on this work, PRIMED continues to gather evidence through its Living Labs to inform the forthcoming White Paper, which will provide policy recommendations for addressing regulatory, financial and market barriers to circular bio-based value chains.