Bureaucratic Barriers Remain: Food Scrap Composting on Farms
The 20th Annual Vermont Organics Recycling Summit, held in Montpelier at the end of March, featured a policy update session, co-facilitated by Rural Vermont and the Compost Association of Vermont, focused on recent and pending changes to Vermont’s solid waste and materials management framework. Presenters from the Vermont Agency of Agriculture, Food and Markets and the Vermont Department of Environmental Conservation highlighted developments related to on-farm composting under Act 41 and proposed updates to the Solid Waste Management Rules, including new regulatory pathways for depackaging facilities.
The session emphasized that, since the passage of Act 41 in 2021—successfully advanced by Rural Vermont, the Compost Association of Vermont and partners—farms may import up to 2,000 cubic yards of food scraps annually for composting, an activity defined in statute as farming. Despite this, participants highlighted persistent bureaucratic and regulatory barriers that complicate farm-based composting as a viable diversification strategy within the profitable waste management sector.
A key challenge is the absence of clear, farm-specific rules from VAAFM governing the incorporation of food scrap management into agricultural systems. The legislature held multiple hearings to review progress on this mandate in April. The VAAFM has yet to launch rulemaking specific for agriculture, and has indicated plans to initiate rulemaking and potentially integrate these provisions into the Required Agricultural Practices (RAP) rules later this year.
Practitioners also raised concerns about the applicability of national compost labeling standards being applied to on-farm operations. These standards were described as poorly scaled to smaller producers, limiting their ability to make agronomic claims about compost benefits and requiring precise ingredient disclosure despite the variable nature of feedstocks. Many see the upcoming RAP rulemaking as a critical opportunity to address these constraints and develop more practical, scale-appropriate labeling requirements.
Current Use Tax policy emerged as another significant barrier. The Vermont Department of Taxes has indicated that farms composting food residuals may risk losing eligibility for the Use Value Appraisal (UVA) Program, which provides property tax reductions for agricultural land. Because Act 41 did not update the statutory definitions of farming used within UVA, some farmers have reportedly been discouraged from adopting composting practices out of concern for jeopardizing their tax status.
More broadly, participants pointed to ongoing challenges including interagency coordination, uncertainty around permitting thresholds, and the practical implications of new and evolving regulatory requirements on existing infrastructure and operators. The session underscored a broader tension between Vermont’s ambitious diversion goals and the need for workable, clearly aligned policies that support on-the-ground implementation.
In response, Rural Vermont and the Compost Association of Vermont are reviving a coalition to advance policy solutions that make food scrap composting a viable pathway for farm diversification. Stakeholders interested in engaging with this effort are encouraged to connect with us directly.
The session fostered a more shared understanding of the evolving policy landscape while identifying priority areas for refinement as Vermont continues advancing its solid waste management rules.
A recording of the VORS session is available here.
Watch legislative hearings here:
Take Action
Now is a good time to let the Department of Taxes know that: “It needs to be clear - farms that diversify into composting food scraps can stay enrolled in the UVA program!” The Current Use Advisory Board is in a rulemaking process, and has drafted updated Rules for Implementing Use Value Appraisal of Agricultural and Forest Land in Vermont. Even though the Department of Taxes stated to us in email that they believe the issue of composting food scraps might need to be resolved in statute and not in rule - let them know that this issue matters to you now! Submit your feedback through the public comment form at tax.vermont.gov/public-comments.