CFA has submitted a response to the Government’s consultation on sewage sludge regulations, ahead of the March 2026 deadline.

Dr Rachel Hackett led CFA’s engagement on the consultation, which proposed three options: consolidating regulations under Environmental Permitting Regulations; retaining the current structure but reviewing its content; or continuing with guidance and good practice only.

CFA’s position is clear. The industry has followed the ADAS Safe Sludge Matrix – developed in the late 1990s with CFA and retailers – for over 25 years, preventing human sewage sludge from being applied to RTE crops. The Matrix has been included in every edition of CFA’s Microbiological Guidance for Growers and is universally supported by UK retailers. It has, however, always relied on commercial commitment rather than legal force.

The case for legislative underpinning is well established. Sludge treatment historically achieves only a 2-log reduction in pathogens and does not address heavy metals or, increasingly, PFAS and microplastics – making it unsuitable for food production.

Growers outside formal assurance schemes can introduce risk for the wider supply chain, and past incidents have demonstrated that poor
overseas practice can result in UK products being rated high risk by authorities, despite no domestic usage – although no legal prohibition exists. CFA’s view is that strengthening UK law by incorporating the Safe Sludge Matrix would protect responsible growers, reduce reputational risk across the supply chain and provide the legal certainty that 25 years of good practice deserves.