NEW REPORT:
"CIRCULAR USE OF BIO-WASTE FROM THE HORECA SECTOR IN SELECTED EUROPEAN COUNTRIES.
RECOMMENDATIONS FOR POLAND"
Kitchen waste containing animal protein doesn't have to be a problem, it can be a resource.
The new report written by INNOWO and published in partnership with REFOOD, analyses the potential for utilising Category 3 animal by-products (ABP cat. 3) from the HoReCa sector as a valuable raw material stream within the circular economy.
Kitchen waste containing animal-derived components can become biogas, energy, organic fertilisers and digestate, reducing landfill use and limiting greenhouse gas emissions.
The report analyses solutions for the management of Category 3 animal by-products (ABP) from the HoReCa sector used in Germany, Denmark and the United Kingdom, comparing them with the situation in Poland in terms of legal regulations, control systems, communication and inter-ministerial cooperation.
The findings indicate that an effective Category 3 ABP management system requires not only appropriate regulations but also their effective enforcement. Consistent communication and close cooperation between public institutions are also crucial.
Poland has the potential to implement solutions based on a clearer interpretation of existing regulations and better use of existing administrative structures. However, it is still at an early stage in developing a system for managing Category 3 ABPs from the HoReCa sector.
Effective management of Category 3 ABPs from the HoReCa sector could improve waste management efficiency, support the energy transition and reduce the environmental costs in Poland.
GERMANY
Germany has a comprehensive Category 3 ABP management system in place, covering almost the entire food service sector.
DENMARK
Ambitious regulations, but uneven enforcement, in place since 2025 and varying across municipalities.
UNITED KINGDOM
The strongest regulations and economic incentives, but a gap remains in oversight of waste producers.
POLAND
The key barrier is the lack of a clear interpretation of the regulations and coordination between institutions.
KEY FINDINGS:
RECOMMENDATIONS FOR POLAND
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A joint position from the Ministry of Climate and Environment, the Ministry of Agriculture and Rural Development and the Ministry of Health, stating clearly that kitchen waste generated during meal preparation and containing animal protein constitutes ABP cat. 3 — issued as guidelines, with no amendment to legislation.
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Strengthening oversight within existing structures: adding to the State Sanitary Inspectorate’s instructions a duty to verify whether a venue holds a waste collection contract and a contract for managing ABP cat. 3 or waste with code 16 03 80.
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A coordinated information campaign for the sector: a press conference, ministerial statements, educational materials and a clear account of the environmental and economic benefits.
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Economic instruments: a gradual increase in landfill charges for mixed commercial waste, investment support for biogas plants and temporary financial incentives for venues sending waste to proper treatment facilities.
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A long-term view: comprehensive regulations for bio-waste and ABP cat. 3, an interministerial working group on biogas and the circular economy, and integration of waste, agricultural and energy policy.
AUTHORS:
CONTACT:
Zofia Koch
Sustainable Development Specialist
INNOWO The Institute of Innovation and Responsible Development
+48 600 458 997