Commission Directive amending Annex III of the Nitrates Directive

Since its introduction in December 1991 the Nitrates Directive (91/676/EEC) has been a key instrument for protecting waters from nitrate pollution from agriculture. Despite significant progress, nitrate pollution from agricultural sources remains a serious problem in many EU Member States.

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The Working Group on Farm Agriculture welcomes the objectives behind the proposed amendments: Import independence, reduction of mineral fertilisers and closed nutrient cycles. However, the proposal itself is criticised by the AbL as (1) it is presented before the final and transparent evaluation of the feedback on the Nitrates Directive; (2) it has not been subject to an impact assessment; (3) the additional use of…

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Dear ladies and gentlemen, for further requirements in the area of nutrients from livestock farming/biogas plants, I see only the need to apply this in the highlands of livestock farming or to check the existing requirements and, if necessary, penalise them.

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The draft act amending Annex III to the Nitrates Directive (Nitrates Directive) provides for the increase of permitted fertiliser inputs of 170 kg N/ha per year, with a separate additional limit of 100 kg N/ha per year. As a voluntary-led association of members, the BUND points out that the text discussed has not been translated into EU languages. The participation of interested bodies is therefore very limited.

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Brittany Chamber of Agriculture (CAB) Brittany is a livestock farming region. The whole of its territory is in a vulnerable zone and part in an enhanced action zone ex ZES.A part of the effluent from Breton farms is still being absorbed and exported outside Brittany. The organic nitrogen pressure from applied manure is 110 uN/ha or well below 170A/ha and the total pressure is 169.8 UN/ha.

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O.B. DI Orazio BRUNELLI AND FIGLI – S.N.C., as manufacturer of livestock manure and digestate treatment plants, appreciates the opening to RENURE fertilisers processed by an installation suitable for meeting the RENURE criteria. In this way, the treatment of slurry results in a concentrated nitrogen material that will make it possible to improve the use of nitrogen from animal slurry.

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No to an increase of nitrogen on agricultural fields We are in favour of substituting artificial fertiliser with manure or products made from manure. And we are so, no matter whether it is because the artificial fertiliser is based on fossile fuels, or because it is produced in Russia.

Surfrider Foundation Europe would like to thank the European Commission for the opportunity to provide feedback on the proposed updated rules on the use of certain fertilising materials from livestock manure (RENURE fertilisers). The draft act to amend Annex III of the Nitrates Directive raises serious concerns on several levels.

1. Objective of the Nitrates Directive It is important, when considering potential changes to the rules governing nitrates, that the context must be the primary objectives of the Nitrates Directive of reducing water pollution caused or induced by nitrates from agricultural sources and .. preventing further such pollution.

The dairy sector wishes to contribute to the challenges related to nutrient loss and nitrogen pollution in water courses and soil. The Dutch Dairy Association (NZO) therefor welcomes the proposal on updated rules on the use of certain fertilising materials from livestock manure (RENURE).

We are a small and medium-sized enterprise specialising in the processing of vegetables. https://www.gemuese-meyer.de/de/ueber-uns.html For many years, we have been trying to save resources so that we can continue to operate sustainably. We obtain energy from photovoltaics, biogas and a wind turbine, among other things. Vegetable waste is recovered in our biogas plant and used for energy purposes.

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The ELO welcomes the revision of the Nitrated Directive to allow for the widespread use of Renure fertilisers. Revision of regulation to integrate research developments should be a basic approach to good legislation. This is also an important step to improve circularity and efficiency, reduce dependence on imported fertilisers and improve farm economics.

The Irish Bioenergy Association (IrBEA) welcomes the opportunity to provide feedback to this consultation on behalf of our members who are biogas plant operators, biogas/biomethane project developers, biogas technology providers, biogas plant feedstock providers, technical consultants, service providers and farmers.

Representing a cluster of 7 European research consortia mandated by the European Commission in frame of the execution of research in nutrient (re)cycling in agriculture, we submit the joint policy brief attached to this feedback : RENU2CYCLE, NUTRI2CYCLE, NUTRI-KNOW, LEX4BIO, NUTRIBDUDGET, NOVAFERT, FERTIMANURE.

The Environmental Forum welcomes the opportunity to respond to this consultation on updating the rules on Nitrates. Effective Consultation This proposal does not appear to be consistent with the spirit of, or the specific requirements of Article 8 of the Aarhus Convention.

Please refer to: Pig Slurry Management Producing N Mineral Concentrates: A Full-Scale Case Study Axel Herrera, Giuliana DImporzano, Elisa Clagnan, Ambrogio Pigoli, Elena Bonadei, Erik Meers, and Fabrizio Adani - ACS Pubblication This scientific paper (in attachment) documents the operation of a treatment plant which produces matrices based on livestock effluents capable of reflecting the characteristics of RENURE…

AFAAIA, a French trade union, representing more than a hundred members, placing on the market for Culture Supports, mulches, organisational amendments, organic and organo-mineral fertilisers and Biostimulants, would like to thank the competent authorities for this initiative concerning the updating of the rules on the use of certain fertilisers obtained from lifting materials (RENURE).

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The Union des Industries de la Fertilisation – UNIFA [1] – French would like to inform you below of its comments on the consultation on the amendment of the Nitrates Directive 91/676/EEC of 12 December 1991 concerning the use of certain fertilising materials resulting from deflection.

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You can find ECOFI's feedback in the PDF attached here. The European Consortium of the Organic-Based Fertiliser Industry (ECOFI) represents European producers of organic fertilisers, organo-mineral fertilisers, and organic soil improvers. ECOFI membership is open to European producers in the sector whose production fully ensures the upstream traceability and the origin of raw material components.

Ireland supports the principle that RENURE products can be used as a substitute for chemical fertilisers to improve the sustainability of agricultural production. However, Ireland is concerned that all available recognised technologies for production of fertilising products meeting RENURE criteria as outlined in the European Commissions Joint Research Centre (JRC) study have not been provided for in the proposed…

LTO, POV, NAJK, and NMV are pleased with the European Commission's proposal for the approval of RENURE. This is a promising step for which LTO, POV, NAJK, NMV, and many other organizations have been advocating for years. RENURE, a product derived from animal manure, offers an important, sustainable, and environmentally friendly alternative to artificial fertilizers.

First, we consider that the proposed change should be accompanied by an appropriate assessment and the results of the ongoing evaluation of the implementation performance of the Nitrates Directive should not be available. We believe that there is no justification for the urgency of the procedure or for this to be a pretext for the proposed weakening of environmental safeguards.

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Fertilizers Europe's welcomes the opportunity to contribute to the public consultation on the proposed update to the Nitrates Directive - updated rules on the use of certain fertilising materials from livestock manure (RENURE). Please find attached the Fertilizers Europe feedback, thank you in advance for your consideration.

We thank for the opportunity that we can provide feedback on this draft act. We thank the European Commission that there is finally a legislative initiative which allows the use of RENURE as a chemical fertiliser replacement. These products are an alternative to artificial fertilisers but are not currently considered fertiliser by the European Commission.

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the Commissions latest Directive to amend the Council Directive 91/676/EEC on specific fertilizing materials from livestock manure.

Dear, POV, LTO, NAJK, and NMV are pleased with the European Commission's proposal for the approval of RENURE. This is a promising step for which POV, LTO, NAJK, NMV, and many other organizations have been advocating for years. RENURE, a product derived from animal manure, offers an important, sustainable, and environmentally friendly alternative to artificial fertilizers.

Dear, This document represents the viewpoint of LTO (also on behalf of all sub-sectors and regions), POV, NAJK, and NMV on the European Commission's consultation regarding the RENURE proposal. The Agricultural and Horticultural Organization (LTO) Netherlands represents more than 35,000 Dutch farmers and horticulturists.

LTO, POV, NAJK, and NMV are pleased with the European Commission’s proposal for the approval of RENURE. This is a proming step for which LTO, POV, NAJK, NMV, and many other establishments have been advocating for years. RENURE, a product derived from animal manure, offers an important, sustainable, and environmentally friendly alternative to artificial fertilisers.

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Ragn-Sells innovations enable treatment plants to recover nitrogen from wastewater in solid form, which can be used immediately in the production of fertilisers. Our innovation company EasyMining has developed a technology (Aqua2N) that, compared to the old biological nitrogen removal method, reduces the greenhouse gas emissions at the wastewater treatment plants, removes the N2O emissions entirely and reduces the…

Directive 91/676/EEC (the Nitrates Directive) is a valuable tool for monitoring the health status of water bodies subject to the transposition of nutrients from livestock manure. AssoFertilisers welcomes the Commission’s call for feedback on the proposal to update the Nitrates Directive to allow the use of RENURE fertilisers above the limit of 170 kg nitrogen per hectare per year.

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While there may be reasonable grounds for subjecting RENURE fertilisers to different regulations than untreated manure, it is perplexing why this change is being rushed through without a proper impact assessment and before the ongoing fitness check evaluation of the Nitrates Directive is completed. Moreover, it is unclear how this change facilitates achieving the overall objectives of the Nitrates Directive.

De Bilt, may 16, 2025 Response by LandschappenNL to the draft Commission Directive amending Council Directive 91/676/EEC as regards the use of certain fertilising materials from livestock manure, April 2024 L.S. Hereby we want to response to the draft Commission Directive amending the Council Directive 91/676/EEC regarding the use of fertilising materials (RENURE) form livestock manure.

In the technical assessment the phenomenon of gaseous nitrogen loss is mainly discussed on the basis of the model results. During meta-analysis data on N leaching and N air losses make up less than 30% of the total pairwise comparisons. It would be important to clearly distinguish between leaching and gaseous loss as one can deteriorate water quality and the other can affect greenhouse gas emissions.

An Taisce is the National Trust for Ireland. We have a number of serious concerns regarding this proposed amendment to the Nitrates Directive. While we have pasted some of our points below, given the character limit we could not cover all of our points, and would direct the Commission to the attached document for our full submission. 1.

Legambiente agrees with the aim of reducing the use of synthetic mineral fertilisers, replacing them with equivalent products obtained from waste biological matrices (RENURE), with a view to the circular economy and reduction of output.

Feedback to the Commissions proposal for a Directive revising the rules for application of manure-based fertilisers above the 170 kg limit from The Swedish Society for Nature Conservation 17 May 2024 Summary The Swedish Society for Nature Conservation opposes the proposed increase of the limits of the overall nitrogen load allowed in environmentally vulnerable zones as currently regulated by the Nitrates directive…

In principle, the German Farmers’ Association (DBV) welcomes the procedure as such and the specific draft of Annex III to the Nitrates Directive. The use of nitrogen from treated manure allows farmers to feed crops even more effectively and can not only help to reduce Europe’s dependence on imported fertilisers or the energy sources needed to produce these fertilisers, thereby ensuring food security.

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We at GEA Farm Technologies are pleased to have the opportunity to comment on this. In view of climate change, it is all the more necessary to promote sustainable ways of fertilizing. The RENURE guideline is therefore important for the farmer. As GEA, we offer farmers a technology that produces high-quality fertilizer on the farm using only electricity (solar, biogas, wind), air and manure.

Overall, the document is quite limited in what constitutes ReNure. ICOS recognises the need for a pragmatic and scientific approach to the categorization of ReNure. However, it is essential to review in line with evolving and ongoing research. Adoption rates will only increase if the barriers (especially economic) are reduced.

Grupa Azoty welcomes the Commission invitation to provide feedback on the proposed update of the Nitrates directive, aimed at allowing the use of RENURE fertilizers above the limit of 170kg N per hectare per year. Below you can find some comments: 1.

The recent global market crises triggered by the SARS-CoV-2 pandemic and the Russian Federation’s invasion of Ukraine have demonstrated the fragility of the European continent in particular as regards the supply of raw materials.

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We welcome the Commission's proposed amendment under consultation, amending Council Directive 91/676/EEC as regards the use of certain fertiliser materials from livestock manure. It represents a first step towards enhancing the circular approach to manure management, with production of organic fertilisers and consequent reduction in the use of chemical fertilisers and dependence on imports of the latter.

The Spanish Association of Water Supply and Sanitation (AEAS) expresses its concern regarding the draft act to amend the Nitrates Directive due to its potential impact on water resources, in particular those used for abstraction of water intended for human consumption.

Lithuania may find it more difficult to implement this EU directive on the use of RENURE fertilisers than some other EU countries for several reasons: 1. Technological infrastructure Problem: Lithuania has less developed technological infrastructure in the agricultural sector, especially compared to technologically advanced countries such as the Netherlands or Germany.

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The EEB would like to express its deep concern regarding the Commissions draft act for a Directive to amend Annex III of the Nitrates Directive. The proposal would allow the application of fertiliser products recovered from manure (up to 100 kg N per hectare and year) above the current legal threshold of 170 kg N per hectare and year set for livestock manure.

The France gaz renouvelables (FGR) welcomes the opportunity to provide feedback on the updated rules on the use of certain fertilising materials from livestock manure (RENURE). The Commission proposal to amend the Nitrates Directive (Council Directive 91/676/EEC) recognises the advancements in manure processing techniques, which have enabled the production of manure-derived fertilisers which are as environmentally…

The agricultural machinery sector welcomes the European Commissions draft act on the use of certain fertilising materials from livestock manure, known as RENURE. As the draft act notes, allowing farmers to create and use RENURE contributes to food security and the European Unions open strategic autonomy by increasing circularity in nutrient cycles thus to the benefit of farmer, environment and climate.

As you know, the Nitrates Directive needs to be updated, especially in relation to the technical and scientific novelty that has been in recent years in relation to the production of new fertilising materials and their distribution techniques.

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Eurogroup for Animals response to the Commissions public consultation: Nitrates updated rules on the use of certain fertilising materials from livestock manure (RENURE) Relaxed rules on nitrates is a step in the wrong direction - reducing animal numbers and incentivising a dietary shift should be the key priorities The excess of nitrates is linked to high density of farm animals in intensive systems, in combination…

The Union of Water Boards represents 21 water boards working in the Netherlands on strong dykes and clean and sufficient water. This includes strengthening dykes and providing space for rivers, purifying sewage and steering water levels RENURE is a new type of manure in addition to livestock manure and chemical fertilisers.

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I welcome the European Commission’s RENURE proposal as a huge step in the right direction. The proposal is strongly supported by the approach taken by the SAFEMANURE report. However, the proposal includes 3 cases which are contradictory to this report, create unnecessary and undesirable restrictions, and will specifically hamper the objectives of introducing RENURE.

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Greenpeace opposes the proposed increase of the limits of the overall nitrogen load allowed in environmentally vulnerable zones as currently regulated by the Nitrates directive (91/676/EEC). The EU already experiences a significant and harmful overload of nitrogen in its waters and ecosystems across rural areas, which causes worrying levels of pollution.

We celebrate this long-awaited Directive amendment as it will favour circularity of agro-industrial systems. However, we identified some requirements exclusive for RENURE products that could hamper their competitivity, although their safety and agronomic performance have been demonstrated.

FrieslandCampina welcomes the opportunity to give feedback to the EU consultation regarding RENURE. FrieslandCampina wishes to contribute to the challenges related to nutrient losses and nitrogen pollution in soil, air and water courses. The aim of the Nitrates Directive is to protect water quality by reducing and preventing nutrient pollution from agricultural activities.

Spanish Ministry of Agriculture, Fisheries and Food welcome the initiative of this delegated act. However, we propose the following changes that could help to promote circular economy by safely using manure derived products, without endangering the environmental targets set by the EU, specially, those referring to the Nitrates Directive. 1.

The Spanish National Fertilizer Manufacturers Association (ANFFE), which includes the main fertilizer manufacturers established in Spain, appreciates the invitation to comment on the proposed revision of the Nitrates Directive with the objective that RENURE fertilizers can be applied above the annual limit of 170 kg of N/ha.

The European Dairy Association (EDA), representing the European milk processing industry, welcomes the opportunity to contribute to the EU consultation on updated rules on the use of certain fertilising materials from livestock manure (RENURE).

We support the use of valuable raw materials like manure (animal or human) rather than chemical fertilizers in favor of a circular economy. We have, however, major concerns about the proposal of the European Commission to allow the application of RENURE above the threshold of 170 N/ha/year for animal manure. You can find our view in the supporting PDF document.

Aqua Publica Europea, the European association of public water operators, welcomes the opportunity to provide feedback to the consultation on proposed updated rules on the use of certain fertilising materials from livestock manure (RENURE fertilisers).

Lombardy Region – Directorate-General for Agriculture, Food Sovranity and Forestry. With reference to the proposed amendment to the use of RENURE as a chemical fertiliser, the first step is to place the dubious economic value of the processes identified for the production of RENURE. It can be estimated that the cost to be incurred is in the order of EUR 10 and EUR 20 per cubic metre of slurry.

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The European Biogas Association (EBA) welcomes the opportunity to provide feedback on the updated rules on the use of certain fertilising materials from livestock manure (RENURE). The Commission proposal to amend the Nitrates Directive (Council Directive 91/676/EEC) recognises the advancements in manure processing techniques, which have enabled the production of manure-derived fertilisers which are as…

The NABU is grateful for the opportunity to comment on the European Commission’s planned amendment of Annex III to the Nitrates Directive. The NABU takes the view that the associated increase in the permitted amount of nitrogen fertiliser applied by an additional 100 kg N/ha to a total of 270 kgN/ha per year should be rejected as a matter of urgency.

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The proposed update of the Nitrates Directive 91/676/EEC for the use of RENURE fertilisers derived from livestock manure, aims to favour a circular economy approach based on recycling nutrients to replace chemical fertilisers.

Feedback of CEEweb for Biodiversity (Hungary + CEE region) to Nitrate Directive updated rules on the use of certain fertilizing materials from livestock manure (RENURE) The ambition behind the amendment to substitute the use of fertilizers and thus reduce import dependency is supportable, but the proposed amendment to the Nitrates Directive are not adequate to address the problems.

OVGW would like to express its deep concern regarding the Commissions draft act to amend Annex III of the Nitrates Directive and its potential impact on drinking water resources. The Nitrates Directive (Directive 91/676/EEC), which was adopted more than 30 years ago to protect water quality by preventing nitrates from agricultural sources from polluting ground- and surface waters and by promoting the use of good…

The Province of Limburg is pleased with the European Commission's proposal for the use of RENURE (fertilizer substitutes). We also see three areas for improvement: 1. We propose not to limit the interpretation to three technology-product combinations.

The Deutsche Naturschutzring e.V. (DNR) strongly rejects the proposed draft delegated act amending Annex III to the Nitrates Directive and recommends that the European Commission withdraw this proposal. Raising the limit by 100 kg per hectare per year to 270 Kg N/ha for the use of ‘renure fertiliser’ is not viable. RENURE is not a defined term and can also mean the use of conventional organic fertiliser.

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Feedback: Nitrates updated rules on the use of certain fertilising materials from livestock manure (RENURE) VCM would recommend these adaptations to the Annex draft: (1) There should be no upper limits for pathogens in the fertilising materials, subparagraph (iv) from the Annex draft, or the Commission clarifies methods of hygienization.

It is interesting to be able to use more organic nitrogen fertilisers of animal origin. This may be permitted by exceeding the ceiling of 170 U organic N of animal origin. While taking care to respect the plant’s needs in the strict sense (and thus respecting the balance of nitrogen fertilisation), it is important to maximise the use of organic matter.

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In this letter, ForFarmers evaluates and advises the Commission’s RENURE proposals through 3 focal points. 1. Target guidance! Process livestock manure into chemical fertilisers that meet quality criteria not limit to just 3 techniques. 2. Delete additional pathogen requirements in RENURE and instead make use of local and European legislation applicable to livestock manure. 3.

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The Finnish Biocycle and Biogas Association (SBB) thank for the opportunity to submit a statement on the rules on the use of certain fertilising materials from livestock manure (RENURE). The wider use of organic fertilisers and nutrients from recycled waste streams will strengthen EU self-sufficiency and food security.

The Agency for agriculture & fisheries (Flemish government) welcomes the directive amending the Council Directive (91/676/EEC) as regards the use of certain fertilising materials from livestock manure. The Agency for agriculture and fisheries supports the Belgian position in preparation of the nitrate committee, but we would like to draw the attention to a few points.

Opinion of the Wasserleitungsverband Nördliches Burgenland on the amendment of Annex III to the Nitrates Directive (Directive 91/676/EEC): The Nitrates Directive was adopted in 1991 to protect ground and surface water against pollution caused by nitrates from agricultural sources. It is one of the key instruments for achieving the objectives of the EU Water Framework Directive.

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In view of climate change and increased scarcity of water resources, a revision of Directive 91/676/EEC needs to work towards good surface and groundwater protection. Leaching of nutrients into water bodies and groundwater must be avoided. We therefore oppose higher fertiliser inputs than 170 kg N/ha, for both mineral and organic fertilisers.

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As Norway is a member of the European Economic Area (EEA), it has an obligation to implement EU environmental directives, one of these being the Nitrates Directive. In this document we wish to provide feedback on this draft amending legislation from a Norwegian market perspective.

WWF Germany expressed concerns about the draft delegated act amending Annex III to the Nitrates Directive (91/676/EEC). In particular, the increase in nitrogen uptake by a further 100 kg N to 270 kg N ha/a with so-called RENURE fertilisers is neither clearly defined nor sufficiently justified and therefore raises concerns. An actual increase in the permitted amount of nitrogen to 270 kg N ha/a is to be rejected.

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We welcome the initiative by the Commission to draft a proposal for a broader application of organic fertilisers and nutrients from recycled waste streams, enabling the production of manure-derived fertilisers which are as environmentally safe as synthetic fertilisers. Whilst the wording in the proposed draft is a welcome step, its proposed provisions do not allow farmers to unlock the full potential of RENURE.

The HUN-REN Centre for Agricultural Research, Institute for Soil Sciences is a 75-year-old research organisation that conducts research in the fields of nutrient management, soil science and soil mapping. We are currently conducting research on the implementation of the Nitrates Directive in Hungary on behalf of the Ministry of Agriculture.

16 May 2024 Amending Council Directive 91/676/EEC as regards the use of certain fertilising materials from livestock manure The Opportunities of Plasma Treatment of Manures and Digestates We highly advice to include the option in the directive of introducing innovative processing solutions - such as plasma treatment of manure - in a defined procedure, or include plasma treatment now in Annex III On April 19th 2024…

Too rigid rules for 170N upper limit. The soil characteristics of intensity are not taken into account. In addition, the measurement site density in the measurement procedures are not uniformly regulated in the EU, resulting in very different results between the Länder, which are difficult to compare

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RENURE defines the properties of organic fertilisers below which the applicability of more than 170 kg N per hectare is to be made possible without the associated increased groundwater risk due to nitrate leaching. It is clear that a N-efficiency (NUE) of organic fertilisers comparable to mineral fertilisers can only be achieved once they are processed in terms of their chemical properties.

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The Federal Chamber of Labour (BAK) is the statutory representation of approximately 3.7 million workers and consumers in Austria. It represents its members in all social, educational, economic and consumer policy matters at national and EU level. In addition, the BAK is part of the Austrian social partnership and is registered in the EU Transparency Register under number 23869471911-54.

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We celebrate this long-awaited Directive amendment as it will favour circularity. However, we identify some requirements exclusive for RENURE products that could hamper their competitivity. - Need for clarification on ammonium salts It seems that technologies obtaining equivalent consistency, such as membrane assisted stripping systems (membrane contactors), vacuum evaporation systems, scrubbing systems treating…

If the EU continues to do so with these bans, regulations and this endless red tape, we no longer need to think about the legacy of animals (slurry, solid manure) or biogas slurry or pressed biogas slurry, as this will no longer be the case in Germany in the very near future.

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JUST as various other Dutch commissions and the Dutch Center for Manure Vervation (NCM) we are pleaded with the European Commission’s proposal for the use of RENURE (fertile substitutes). We also see three areas for improvement: 1. We do not propose to limit the interpretation to three technology product combinations.

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NCM's viewpoint on the European Commission's RENURE proposal The Dutch Center for Manure Valorization (NCM) sees the EC's RENURE proposal as a step in the right direction. However, we also see a number of requirements in the proposal that we believe are both unnecessary and undesirable. These are such that they will significantly hinder the RENURE's potential contribution to a more sustainable agriculture.

The Province of Fryslân welcomes the European Commission's proposal for the use of RENURE (fertilizer substitutes). In Fryslân, we strive to further reduce nutrient-losses from agriculture and close nutrient cycles as much as possible. We strive for the most optimal utilization of animal manure therefore. Application of RENURE-fertilizers will assist us in that goal.

Fertilisers Efficiency Enhancers, a sector group of Cefic, represents the value chain of nitrogen stabilisers and other efficiency enhancers in Europe and promotes the agronomic and environmental benefits of nutrient enhancers in fertiliser applications.

The province of Groningen is pleased with the European Commission's proposal for the use of RENURE (fertilizer substitutes) in agriculture. We would like to raise three points of attention and improvement: 1. We propose not to limit the interpretation to three technology-product combinations, so that other/future technologies that meet the same product requirements can also be used. 2.

Copa and Cogeca welcome the approach as such and the specific draft Annex III to the Nitrates Directive, with the aim to reduce dependence on imported commercial fertilisers or fertilisers produced in Europe at high energy costs by making widespread use of so-called RENURE fertilisers, i.e., fertilisers obtained from the processing of farm manure and comparable to synthetic fertilisers.

Copa and Cogeca welcome the approach as such and the specific draft Annex III to the Nitrates Directive, with the aim to reduce dependence on imported commercial fertilisers or fertilisers produced in Europe at high energy costs by making widespread use of so-called RENURE fertilisers, i.e., fertilisers obtained from the processing of farm manure and comparable to synthetic fertilisers.

EurEau would like to share its feedback to the draft act for a Directive to amend Annex III of the Nitrates Directive. In the attached document you can find our concerns regarding the Commissions draft act to amend Annex III of the Nitrates Directive and its potential impact on water resources, in particular those used for abstraction of water intended for human consumption.

Water pollution by excess nitrates is already a real problem, with direct impacts on our health and that of ecosystems. In Spain alone, at least 171 municipalities exceed the permitted nitrate values (above 50 mg/l). Some 214.851 people do not have access to drinking water in their municipalities.

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We welcome the most necessary revision of the Nitrates Directive and the planned inclusion of RENURE fertilisers. The basic regulatory point of the Nitrates Directive is to avoid potential water pollution caused by nitrates from agricultural sources. It therefore does not regulate possible other areas, such as further limit values, the placing on the market, etc. of fertilisers.

Filed in German · English published by the European Commission

In general, we welcome the inclusion of RENURE fertilisers in the current draft Nitrates Directive. However, the Commission proposal deviates from the technology neutral approach outlined in the original Joint Research Center (JRC) study.

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The Dutch Green Gas Platform believes that the Renure legislation can make a significant contribution to a circular Dutch livestock farming sector. It enables livestock farmers to produce fertilizer from their own manure, reducing dependency on the energy-intensive synthetic fertilizer industry that's also emitting huge amounts of CO2 and nitrogen.

The protection of water is an important concern for the Austrian population, as shown, for example, by the Right2Water citizens’ initiative. Across the EU, 1.884.790 people, with the support of European citizens, have called for all EU residents to have the right to water and sanitation. This is particularly important to protect the water against the discharge of pollutants.

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The Provincie of Gelderland is pleased with the European Commission's proposal for the use of RENURE (fertilizer substitutes). This naturally nourishes the soil with fertilizers of organic origin, saves on the use of artificial fertilizers and further reduces the leaching of fertilizers into the groundwater.

Considering the management system of manure and digestate in the landscape of Lombardy Region - Italy, the writer H2ORO SRL, as a producer of organic and mineral fertilisers, appreciates the public consultation in view of the amendment to the Nitrates Directive (91/676/EEC) for a more targeted use of livestock manure.

It is long time to give preference to the closed circular economy without commercial fertilisers. Clear with maximum limits! Livestock density and kg/ha. The major advantage lies in the energy balance compared to artificially produced fertilisers. It is also the value for the soil. Humus construction much better. And there is no need to transport fertilisers over long distances.

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WWF Spain is concerned about the proposal to amend Directive 91/676/EEC which allows inorganic livestock manure fertilisers (RENURE fertilisers) to be exempted from the application limit of 170 kg N/ha. This will not reduce the nitrogen load in water bodies and does not consider key aspects such as soil typology, climate or absorption capacity of different crops.

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ESPP welcomes the proposal to exempt from the 170 kgN/ha limit THREE (only) specified recycled nutrient products recovered from manure, subject to their being of consistent quality. This will enable a level playing field for consistent, quality recycled products from manure, limited to those which are essentially similar to synthetic inorganic fertilisers.

CIA Agricoltori Italiani, one of the large agricultural organisations in Europe representing Italian farmers and agricultural business owners, welds the unity to provide feedback on the draft Directive Nitrates updated rules on the use of certain fertilising materials from livestock manure (RENURE). Please find attached Cia Agricoltori Italiani feedback.

Filed in Italian · English published by the European Commission

The Leibniz Institute of Freshwater Ecology and Inland Fisheries (IGB) is Germanys largest research centre for freshwaters. Our research findings help to tackle environmental changes and to develop strategies for sustainable water management true to our guiding principle Research for the future of our freshwaters.

Deutsche Umwelthilfe e.V. (DUH), EU Transparency Register No 03506017714-81 The Deutsche Umwelthilfe e.V. (DUH) is grateful for the opportunity to comment. In substance, Deutsche Umwelthilfe e.V. strongly opposes the amendment of Annex III to the Nitrates Directive and calls on the European Commission to withdraw or revise the proposal.

Filed in German · English published by the European Commission

BEATLES (https://beatles-project.eu/) is a Horizon Europe which stands for Behavioural Change Towards Climate-Smart Agriculture. The project considers that the update of RENURE directive present potential to enable livestock farmers to produce fertiliser from their own manure which favours a more sustainable management.

Atria welcomes the long-awaited changes to the nitrates directive. This interim solution must be rapidly adopted and implemented by the member States. Enhancing the use of manure nutrient is crucial for fertilizer self-sufficiency and food production security.

Feedback by Bond Beter Leefmilieu (Flemish Umbrella organisation of Environmental Organisations) on the ECs initiative to revise the rules regarding the application of fertiliser products recovered from manure in the Nitrates Dir. We do not agree with the lack of proper assessment during the preparation phase and pre-empting the results of the ongoing fitness check evaluation of the Nitrates Dir.

ver.di is a co-initiator of the European Citizens’ Initiative entitled ‘Water is a human right/right2water’. We pay particular attention to protecting the water resource from pollution. This is because what is not registered does not have to be removed expensively. Ver.di therefore opposes the proposed amendment. The European Union is already experiencing significant nitrate pollution in soils and waters.

Filed in German · English published by the European Commission

The Nitrates Directive cannot be replaced. This is cutting red tape. Because fertiliser prices are very much higher, in any event, no longer excessive. And if the rules are reduced, organic fertilisers can also be used/exchanged more effectively. Throughout the system, other nitrate sources are completely neglected.

Filed in German · English published by the European Commission

In the view of the Bavarian Farmers’ Association, a revision of the nitrates directive is overdue. The goal of clean groundwater and surface waters must be kept in mind, but much more flexible and practicable regulations must be found regionally.

Filed in German · English published by the European Commission

Delft, May 10th, 2024 MEZT welcomes the draft COMMISSION DIRECTIVE (EU) amending Council Directive 91/676/EEC as it regards the use of certain fertilising products from livestock manure as a major step towards circularity of minerals in the agri-sector. 1.

The proposal is generally welcomed, as the risk of nutrient discharges into the environment for fully processed products from farm manure is not different from that of conventional mineral fertilisers. The exclusion of these products from the 170 kg limit is a prerequisite for the establishment and viability of full processing processes.

Filed in German · English published by the European Commission

WWF is concerned that the proposed amendment of the nitrates directive allowing inorganic fertilisers from livestock manure (known as "RENURE" fertilisers) to be exempted from the 170 kgN/ha spreading limit, may not result in a reduction in the nitrogen load in the water bodies. We are concerned that the proposed amendment might have a rebound effect and stimulate higher livestock numbers.

Natuurpunt (Flemish umbrella organisation of Birdlife): Natuurpunt hereby provides feedback on the ECs initiative to revise the rules regarding the application of fertiliser products recovered from manure in the Nitrates Dir. We do not agree with the lack of proper assessment during the preparation phase and pre-empting the results of the ongoing fitness check evaluation of the Nitrates Dir.

The Greek Bioecenomy Council is the Industry Association for circular bioeconomy in Greece. Our mission is to unite companies who utilize renewable biological resources, thereby fostering the development of a sustainable economic sector. We are grateful for the opportunity to provide input on the proposed amendments to Directive 91/676/EEC.

Approving this clause means a regression in the protection of soils and aquifers, as it does not lead to any progress in authorising more than 170 kg/ha regardless of the source of nitrogen used. The use of this technology is expensive and unrealistic for a scale of family farming.

Filed in Spanish · English published by the European Commission

1 The Foundation "Dutch Center for the Development of Circular Precision Fertilization " (NCOK) welcomes the proposed COMMISSION DIRECTIVE (EU)amending Council Directive 91/676/EEC as regards the use of certain fertilising materials from livestock manure as a major step on the road towards zero-emission agriculture through utilization of technological developments and good agri-environmental practices as mentioned…

RENURE has been discussed for a long time, and it is good to finally see a proposal. The proposal can be supported from the Finnish point of view, although it does not have much significance in Finland for the time being.

The directives need to be strengthened in the sense of improving soil elegation and potential aquifer contamination, reducing where necessary the input of N, based on scientific studies. The limit of 170 kg nitrogen per hectare per year in nitrate vulnerable zones should not be minimised, nor should higher contributions from organic fertilisers (manure and equivalents) be allowed.

Filed in Spanish · English published by the European Commission

Active efforts should be made to create more legal possibilities to make the best use of existing agricultural residual flows. An important step in this direction is the development and promotion of RENURE fertilisers, which contributes to the revaluation and upgrading of livestock manure.

Filed in Dutch · English published by the European Commission

This initiative runs counter to the purpose of the Directive and is formulated before the usual effectiveness and impact studies of the Directive are available (it aims to remove the limit of 170 kg of nitrogen per hectare per year in zones vulnerable to nitrate pollution, in order to allow higher inputs from organic fertilisers such as manure and equivalents).

Filed in Spanish · English published by the European Commission

A directive written in a language that farmers do not understand! IF the directive is addressed to farmers, it must be written in such a way that they can understand it. First of all, we need to ask a basic question: what is currently called manure? The original version of the directive was created a long time ago.

Filed in Polish · English published by the European Commission

First of all, implementation of the RENURE in the ND is an important step in the recycling of nutrients. The technology to recuperate nutrients is market ready, uptake is hindered by the lack of the RENURE implementation. In the ANNEX to the proposed directive, under (i), (1), the ammonium salts are specified. The last word of this definition can be problematic: off-gases.

Ecologistas en Acción Guadalajara is very concerned about the new Nitrates Directive prepared by the European Commission, which could increase the maximum permitted fertiliser load on crops, which is now 170 kg per hectare. We believe that this limit should not only not be increased, but should be lowered.

Filed in Spanish · English published by the European Commission

It seems to me to be a barbarity to extend the limits beyond 170 kg N per hectare, which I consider to be excessive in itself. In the case of Spain and specifically Castile-La Mancha, these limits have not served anything because of excessive and the total lack of administrative and scrupulous checks on some livestock farmers.

Filed in Spanish · English published by the European Commission

The provisions of the Nitrates Directive should be fundamentally changed - the nitrogen limitation of 170 kg/ha is too abstract and far from reality. Since 1991, both fertilization technology and fertilization planning, as well as nitrogen utilization efficiency=yield of agricultural crops have advanced significantly.

Hello, the management of nitrogen waste through land application remains entirely acceptable, if not desirable, as long as soil and groundwater are not endangered by these practices. Therefore, these supplements should not be authorised in sensitive areas as defined by the Nitrates Directive, or generally in areas where the good environmental status of waters is not achieved as a result of excess nitrates, or that…

Filed in French · English published by the European Commission

What it is proposed does not represent any improvement in replacing synthetic fertilizers with manure and processed manure neither an improvement of the nitrate directive RENURE is a mineral fertilizer so that it is not clear why we have to consider it as an improved manure base fertilizer.