auma advises an industrial company seeking to add paper mill pulper reject as a recoverable waste in its co-incineration, through a substantial modification of its integrated environmental permit. The question is not only whether it can be done: it is how to frame it so it succeeds.
Project overview
| Client | Industrial company (confidential) |
| Market | Industry |
| Practice area | Waste and circular economy · Air quality |
| Location | Catalonia (Spain) |
| Services | Strategic advisory for permit modification |
| Year | 2026 |
The challenge
Pulper reject is an abundant paper industry waste with usable calorific value. Adding it to an existing co-incineration process, however, is no minor formality:
- Change in accepted wastes: extending the authorised codes requires reviewing the conditions of the whole permit.
- Effects on emissions: it must be shown that the new stream does not worsen the installation's environmental performance.
- Order of decisions: framing the modification badly can cost months before work even starts.
The auma solution
The assignment comes before drafting: defining the permitting strategy before producing documentation.
- Analysis of how adding the new waste fits within the existing authorisation regime.
- Identification of the technical and documentary requirements the authority will impose, and the order to address them.
- Definition of the modification strategy and of the dialogue with the competent authority.
The result
- The client knows the viable permitting route and the requirements to meet before investing in documentation.
- Regulatory risks identified at the outset, while they can still be managed.
- A clear roadmap for the substantial modification of the permit.
In a permit modification, the decisive work happens before the first page is written: getting the permitting route right saves more time than any fast drafting.
Frequently asked questions
What is waste co-incineration?
Energy recovery from waste in installations whose main purpose is producing energy or materials — such as cement kilns or industrial boilers — partially replacing conventional fuel with waste that has calorific value.
What is pulper reject?
The material separated during the pulping of recovered paper: plastics, metals, wires and unusable fibres. It is an abundant paper industry waste with recoverable energy content.
Does adding a new waste require modifying the permit?
Yes. Extending the accepted wastes changes the authorised operating conditions and, depending on scope and effects, is processed as a substantial modification, with conditions reviewed against the best available techniques.
Want to recover a waste you are not currently authorised to accept?
We define the permitting strategy first and the documentation second, in that order.
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