Evaluation of the Fertilising Products Regulation

GENERAL DIRECTORATE OF AGRICULTURE AND LIVESTOCK GOVERNMENT OF CATALONIA 1. Regulation 2023/1605 established the ABP endpoints for the use of manure in the production of organic fertilisers. However, in order to promote the circular economy, there is room for these conditions to be made more flexible, and even a modification of the ABP Regulation should be considered. 2.

RHP, knowledge centre for substrates, has been involved in the development of the FPR, and supports basic ideas and ambitions of the FPR when it concerns fertilizers and raw materials with a clear fertilizing value. However, the addition of growing media in situ makes it difficult for growing media producers and most of the growing media raw material producers, to get the CE marking.

Feedback on the specific objectives of the FPR 1) improved functioning of the internal market and a level playing field a) The FPR does provide a structure for the EU marketing of recycling-derived fertiliser products (RDF). Since 2019 it has expanded the Annex II with 4 additional CMC for RDF- materials. This has however not yet resulted in the CE-marking of RDF and organic products.

ESPP welcomes the cited aim of the FPR to enable large-scale production of circular fertilisers. But today the FPR is failing to achieve this: few recycled fertilisers are CE-Mark. Establishing why, and how to resolve this, should be the Evaluation priorities. ESPP (European Sustainable Phosphorus Platform) represents 50+ members in nutrient management (companies, R&D, public bodies).

The German phosphorus platform DPP e.V. welcomes the consultation on the evaluation of the EU fertilising products regulation (EU 2019/1009). As a network of over 80 members from business, academia, administration and the public, the DPP is committed to the sustainable use of phosphorus and its circularity.

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The Sauberer Phosphor e.V. initiative promotes high-quality, environmentally sound phosphorus recycling. In our opinion on the EU fertilising products regulation, we welcome the promotion of fertilisers from secondary raw materials and call for uniform, strict environmental and quality standards, clear certification structures and effective limits for pollutants.

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ICL Group thanks the European Commission for launching the evaluation of the FPR regulation, noting that its implementation is still recent, just over three years, and not yet fully completed to date. ICL is engaged in the evaluation of the EU FPR and submitted a detailed answer to the survey, answering the different aspects of the call for evidence.

1. The main shortcoming of the regulation is that there is no EU-level database of approved (certified) products. This is disadvantageous for buyers and users and makes the supervision work more difficult. Currently, EU crop enhancers are in an unintelligible chaos on the market.

We would like to address two aspects of the Fertilizing Product Regulation 2019/1009: 1. inclusion of biodegradable mulch films in CMC9 and definition of biodegradability criteria for coating agents and water retention polymers 2. possibility to implement other sources and range of feedstocks to be considered as source of fertilizers.

For DAQUAS, the exclusion of sludge in EPR has significant impacts for urban water operators, as it represents a loss of valorization opportunities and it may discourage investment in advanced treatments and recovery technologies.

Regulation (EU) 2019/1009 (FPR) introduces a structuring approach, but its implementation is complex, costly and difficult for SMEs to access. The labelling requirements are cumbersome and impair readability; digitalisation, although promising, is still too rigid.

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Biochar Europe is grateful for the chance to give our feedback. The inclusion of materials from pyrolysis and gasification (CMC14) is a great step towards a sustainable and circular economy but we have some concerns/suggestions: Main concerns 1) The current Fertilising Products Regulation (EU) 2019/1009 (FPR) excludes sewage sludge (urban wastewater treatment sludge, separately collected) as an input to composts…

We welcome the opportunity to provide input to the Commissions evaluation of the Fertilising ‎Products Regulation (FPR).‎ ‎1. Effectiveness The FPR has achieved important progress in broadening the scope of fertilising products covered ‎and establishing harmonised safety thresholds, thereby improving environmental and health ‎protection compared to Regulation 2003/2003.

We submit our position as part of the ongoing consultation on the evaluation of Regulation (EU) 2019/1009. The document presents proposals aimed at enhancing transparency and traceability of fertilising products, strengthening enforcement, and creating conditions conducive to innovation.

AEFA represents the Spanish companies producing specialty fertilising products and plant biostimulants, a sector that plays a key role in agricultural innovation and sustainability. AEFA welcomes the Fertilising Products Regulation (EU) 2019/1009 as a milestone that has harmonised the European market and recognised plant biostimulants as a distinct category.

The Union of Fertilisation Industries (UNIFA) represents the plant nutrition and soil health industries. Mr UNIFA thanked the European Commission for carrying out an evaluation of this regulation, given that it had recently been implemented, just over 3 years and what was still not complete.

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The FPR is essential in ensuring that a framework is in place to allow the placing on the market of biostimulants across Europe. However, we encourage the Commission to stop national barriers being put in place for products which have already been assessed by the notified bodies and received the CE mark. This is against the principles of the regulation.

The European Biostimulants Industry Council (EBIC) acknowledges the huge benefits brought by the Fertilising Products Regulation (FPR) [Regulation (EU) 2019/1009] through the inclusion of plant biostimulants in its scope, by establishing Product Function Category 6 (PFC 6) according to the function(s) of plant biostimulants, and by allowing plant biostimulants to access the Single Market under harmonised rules.

AFAIA, the professional association representing French players in the fertiliser and growing media sector, welcomes the adoption of Regulation (EU) 2019/1009 (FPR). This harmonised framework represents a major step forward by integrating biostimulants into European regulations, setting stricter safety requirements, and paving the way for the free movement of fertiliser products within the internal market.

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Performance-based inclusion of municipal sewage-sludge gasification materials in CMC 14 Who we are and what we do. Shit2Power operates decentralised fixed-bed gasifiers for dried municipal sewage sludge. Operation typically achieves 800900 °C solid-phase temperatures with 3060 min total solid residence time. Sludge is pelletised (~5 mm) to avoid cold cores.

IFOAM Organics Europe supported the establishment of the Fertilising Products Regulation (FPR) as a central point of the European Commission's Circular Economy Action Plan. Its intention to harmonise rules among EU countries for all fertilizers products (mineral fertilisers but also organic, waste-based fertilisers and biostimulants) was welcome.

Proponowany tekst podsumowania The Polish Chamber of Chemical Industry (PIPC), representing the largest fertilizer companies in Poland, welcomes the opportunity to provide input to the evaluation of the EU Fertilising Products Regulation (EU 2019/1009). Our comments focus on ensuring a level playing field, strengthening market transparency, and maintaining high safety and environmental standards.

The Commission, in cooperation with the Member States, continues to work to improve Regulation (EU) 2019/1009 on fertilising products, helping to make the Regulation dynamic and evolving. Additional amendments are still under negotiation. Belgium welcomes the continuous work. The Belgian authorities have identified reflections on how to improve the Regulation: (1) agronomic cheeses of PFC 1 blends.

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Coldiretti, the largest organisation representing farmers in Italy and Europe, with its 1.6 million associates, welcomes the European Commission’s initiative to gather views on the evaluation of the Fertilising Products Regulation. Please see the detailed position paper in annex.

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Attached is the contribution of France gaz renouvelables. Founded in 2018, France gaz renouvelables brings together AAMF, Biogaz Vallée®, Coénove, Chambres d'Agriculture France, FNSEA, Club Biogaz ATEE, FNCCR, France biométhane, GRDF, NaTran, Gaz et Territoires, LCA, Swen Capital Partners and Terega. Its aim is to promote the role of renewable gases in the French energy mix.

The Finnish Biocycle and Biogas Association (FBB) thanks you for the opportunity to provide comments on the EU Fertilising Products Regulation (FPR). General remarks FBB welcomed the 2019 expansion allowing CE marking for composts and digestates (CMC 3, 4, 5; PFC categories). EU recognition of end-of-waste (EoW) status is important, as Finnish legislation does not yet provide it.

Die Gütegemeinschaft Substrate für Pflanzen e.V. begrüßt grundsätzlich eine einheitliche Regelung für das Inverkehrbringen von Kultursubstraten auf den EU Binnenmarkt, jedoch wird dann erwartet, dass der Verwaltungsaufwand geringer ist als nach dem herkömmlichen Verfahren (nationale Deklaration und gegenseitige Anerkennung gemäß EU-VO 2019-515). Dies ist durch die EU DüPV zur Zeit nicht gegeben.

The European Biogas Association (EBA) welcomes the opportunity to contribute to the evaluation of the EU Fertilising Products Regulation. A key objective of the FPR is to promote the use of recycled nutrients including digestate-derived products. This supports the circular economy, improves resource efficiency and reduces the EUs dependence on nutrient imports.

Grupa Azoty is one of the leading producers on the European fertilizer and chemical markets. We welcome the opportunity to share our initial views on the evaluation of Fertilising Products Regulation. Grupa Azoty calls for efforts to improve the international competitiveness of the fertilizer sector, increase regulatory clarity and reduce administrative burdens, as well as increase the possibility of faster…

Artemis reaction EU Consultation FPR. Artemis appreciates the opportunity to respond to the evaluation of the Fertilising Products Regulation (FPR), which has been in force since July 2022. As Artemis, we represents producers and suppliers of biocontrol and biostimulants in the Netherlands. Our feedback is provided in the attached document.

The EFBA (European Fertiliser Blenders Association) welcome the objectives of the FPR, particularly the drive toward harmonisation and environmental protection. However, several critical implementation issues need to be addressed to ensure the regulation achieves its intended goals without overburdening operators. 1.

Veas (Norway) welcomes the opportunity to contribute to the evaluation of the Fertilizing Products Regulation (FPR) (EU) 2019/1009. Our fertilizer product is certified according to Module D1 for materials belonging to CMC 15, which means that certification must be done by a notified body. At the startup of the CE marking process, there was only one notified body available, located far away.

The Catalan Composters’ Association, COMPOSCAT, would like to provide suggestions, observations and requests for modifiacones, so that they can be assessed by this committee. This COMPOSCAT association is made up of different managers carrying out the R0301 valorisation.

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Thank you for the opportunity to feedback on the performance of the Fertilising Products Regulation. While the Regulation (EU) 2019/1009 has been successful in enabling harmonization across the EU for the CE-mark framework and for new product categories like biostimulants and soil improvers, we believe it has inadvertently created an uneven playing field for manufacturers of chemically unmodified natural mineral…

Opinion on behalf of Ekofol AD (email: [email removed]), member of the Bulgarian Plant Protection Association (non-profit email [email removed]) 1. Regulation (EU) 2019/1009 aimed to simplify access to the European market for fertiliser products.

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Thank you and we welcome the opportunity to express our opinion. The Regulation strictly regulates the manufacturing conditions the production process for certain products, e.g. composts. The possibilities of microbial plant biostimulants are quite limited, only 4 microorganisms are included in the Regulation.

General Assessment of the FPR The regulation advances by providing clear definitions for products, moving away from broad categories like digestate to terms such as organic soil improver. This promotes acceptance and harmonizes regulatory frameworks across EU Member States.

Feedback: Clarify the requirements for documentation when applying to add a new raw material to the list. This would make it easier to get it right the first time and make it easier to apply. Establish an agreement on which types of fertilising products that are covered by the plant health regulations (https://eur-lex.europa.eu/eli/reg_impl/2019/2072/oj) restriction on import to EU of growing medium.

The regulation concerning the use of animal by-products and waste is insufficiently detailed, potentially causing food safety risks. Conversely, the regulatory framework governing composting is excessively stringent, presenting significant compliance challenges. The scope of microorganisms permitted in microbiological biostimulants is highly limited, encompassing only four types of microorganisms.

Regulation (EU) 2019/1009 lays down, from 16 July 2022, new requirements for the making available on the market of CE marked fertilising products within the European Union. Specifically, the standard introduces important novelties, such as: Regulation (EC) No 2003/2003, which until 15 July 2022 regulated only mineral fertilisers on the EU market; a new classification of EU fertilising products supported by new…

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As confirmed in the new Urban Waste Water Directive, sewage sludge is an important resource. In Germany, the Regulation on the reorganisation of sewage sludge recycling already applies the obligation to recover phosphorus contained in the waste water and contained in the sludge. In future, the Commission will also be empowered to set recovery rates for phosphorus by means of delegated acts.

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As the Commission undertakes this evaluation, we believe it is essential that the Regulation keeps pace with strengthened European ambitions on circularity, bioeconomy and sovereignty. Currently, the Regulation has not yet achieved its objective related to the creation of a market for organic fertilisers.

The Italian Composting and Biogas Association (CIC), a non-profit organization founded in 1992, is the national reference organization for the bio-waste recycling sector. CIC members include both public and private recycling companies, and their plants recycle about 80% of the separately collected bio-waste in Italy.

OCP Nutricrops' primary mission is to help farmers access the most efficient and sustainable fertilisers and the latest application expertise, wherever they are in the world. We consider the review of the EU Fertilising Product Regulation (FPR) important for harmonising standards that promote safer, high-quality, and sustainably labelled fertilising products across Europe.

CEN/TC 223 'Soil improvers and growing media' and CEN/TC 260 'Fertilizers and liming materials' have collected insights for the European Commission to take into consideration for future developments of the FPR. CEN is at the disposal of the European Commission to discuss these matters in further detail. Please find attached the whole CEN reply.

Key messages: the FPR provides a solid framework but is still only marginally applied. The FPR has successfully introduced criteria for Cd and biodegradable polymers but is far less ambitions in relation to other substances of concern.

Wastewater treatment plants recover essential nutrients (nitrogen, phosphorus, organic matter) that can replace imported mineral fertilisers and support the EUs circular economy, food security, and climate goals. However, the current FPR framework still limits market access for many safe and effective recovered products.

All details can be found in the attached file. In the assessment of the negative impact of the Regulation, we pay particular attention to issues such as: 1. Reach+ for CMC1 and its impact on innovation 2. Obligation to disclose know-how 3. Short list of micro-organisms in CMC7 and lack of clear criteria to assess further strains to add them to List 4.

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We introduce on the market several fertilizing products, as PFC 1, PFC6 and PFC 7, despite the lack of components in CMC 7 and 10. Its very disappointing that this regulation was cited as the priority of the circular economy package and 6 years after its publication, were still waiting the update to include the Animal By-Products and enlarge the list of microrganisms.

EUROFEMA welcomes the opportunity to provide input to the public consultation on the evaluation of the EU Fertilising Products Regulation 2019/1009 (FPR). The Commission must be aware that there is only little experience in practice since the process of implementing is still young and continuing as is the development of the FPR.

EasyMining, welcomes the Commissions initiative to evaluate the Fertilising Product Regulation. We agree with the objectives of the evaluation, especially the aim to review the limit values for cadmium content in phosphate fertilisers but have some additional recommendations and input. Cadmium.

Euroseeds welcomes the opportunity to contribute to the evaluation of the Fertilising Products Regulation (FPR) (EU) 2019/1009. The seed sector plays a vital role in European agriculture, and it is essential that regulatory frameworks support innovation, sustainability, and the internal market.

I think the labelling requirement needs to be revised. Companies selling in the EU now need two bags of each product to comply with the law instead of one. I do not understand why we can not just mention the chemical composition and have an QR code with all the language labels. I do not believe the application sentences on the bag give any value.

Evaluation of the European Regulation on Fertilising Products (Regulation (EU) 2019/1009 FPR) – Call for evidence. While welcoming the entry into force of a European regulation on fertilising products, which has the stated aim of encouraging free trade in organic products and, in particular, the recovery of waste materials with high agronomic value, the experience of these six years has highlighted a number of…

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The Fertilising Products Regulation (EU) 2019/1009 (FPR) was announced as a key milestone in promoting sustainability and circularity in agriculture. However, six years after its adoption, it still fails to enable equal market access for bio-based and circular inputs. This delay has caused market exclusion, regulatory deadlocks, and mistrust towards circular fertilising products.

ECN Feedback on the Evaluation of the EU Fertilising Products Regulation (EU FPR) The ECN, which represents the circular bioeconomy in Europe and produces quality compost and digestate from over 48 million tonnes of separately collected biowaste per year in more than 4,500 composting and anaerobic digestion plants across Europe, welcomes the initiative to evaluate the EU Fertilising Products Regulation, which came…

The IVG fully supports the European objective of a harmonised market for fertilising products. However, without adjustments, the FPR risks driving manufacturers back to national frameworks, undermining the level playing field and fragmenting the single market.

While the FPR has been successful in setting a harmonised framework, its current structure risks slowing innovation and circularity. Currently, the FPR has too strict requirements for CMCs and too narrow list of allowed CMCs, which limits the use of new materials (particularly waste) and the development of new types of products.

Overall, FPR has had positive impact on the EU market access for fertilising products, allowing access to all 27 member states upon a single conformity assessment. Inclusion of proven-efficient plant biostimulants has also added great value.

Growing Media Europe AISBL (GME), representing the growing media industry at the EU level, welcomes the ambitions of the Fertilising Products Regulation (FPR). We strongly support the creation of a European internal market for fertilising products, where harmonised rules ensure fair competition, regulatory clarity, and sustainable innovations.

The Government of the Canary Islands welcomes Regulation (EU) 2019/1009 on fertilising products, given its contribution to market harmonisation, user safety and environmental protection. However, it identifies some adjustments that are necessary to ensure their full effectiveness in outermost regions (ORs) such as the Canary Islands, characterised by insularity, territorial fragmentation, smallholder and heavy…

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We recommend that the EU FPR adopts a new definition of "plant nutrients" that has evolved in recent years and is widely supported by the scientific community. The file attached provides the new definition and its rationale. Table 1 in that paper illustrates current inconsistencies of EU FPR 2019 with the scientific understanding of plant nutrients.

Please find AIPSAs feedback to the EUS Fertilising Products Regulation evaluation attached. AIPSA brings together leading companies in the growing media sector in Italy. It members have decades of experience in developing, producing and marketing Substrates and related products for both professional and non-professional use.

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Attached is our evaluation of the FPR with respect to Plant Biostimulants (PFC6), prepared by 28 scientists who are actively working in agronomy and horticulture. In our view, the way the FPR is currently implemented using CEN standards results in market available products that are ineffective. This outcome runs counter to the FPRs stated objectives, as explained in the attached document.

The European Consortium of the Organic-Based Fertilisers Industry (ECOFI), founded in March 2014, provides producers of organic fertilisers, organo-mineral fertilisers, organic soil improvers and fertilisers incorporating components derived from organic materials with a representative voice at the European level.

The Swedish Chemicals Agency (KEMI) welcomes this opportunity to comment on the evaluation of the Fertilising Product Regulation (FPR), specifically regarding the review of the limit values for cadmium content in phosphate fertilisers. Cadmium exposure via food from agricultural land contributes to adverse human health effects.

The objective of the RSF was to harmonise the European market and stimulate sustainable innovation. The sector shared this objective, but regulation knows in practice too complex and costly (especially for SMEs and blends them). 1. Complexity of labelling The lack of harmonisation of interpretations between Member States weakens legal certainty.

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Please find Group De Ceuster's feedback to the EU's Fertilising Products Regulation evaluation attached. Group De Ceusters (GroupDC) plant care division De Ceuster Meststoffen (DCM) has more than 45 years of experience in developing, producing and marketing organic and organo-mineral fertilisers and is a European market leader in this field.

We would like to address one aspect that is not yet in the regulation but could significantly enhance its effectiveness and relevance: the provenance of raw materials. The evaluation aims to consider external factors that have emerged since the FPR's application, and in this context, we believe the origin of fertiliser components is an important point for consideration.

After a few years of practical application of the FPR, it is clear that it is coherent and works in the internal market. However, there are considerable costs and red tape associated with the implementation of manufacturers and medium-sized traders. In this way, guidance on use could be omitted, especially as farmers are themselves competent and are best placed to assess the needs of their crops.

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Feedback on the evaluation of the EU Fertilising Products Regulation (FPR) The Fertilising Products Regulation (FPR) has potential for important harmonisation benefits and to create a clear framework for products that obtain CE-marking and free circulation in the internal market.

This was the feedback from the members of the Belgian pottery federation (BPF) at a meeting of members: — Not applicable – Added economic value – Major workload on staff – Those duration – Tackling – No demand for – Complex – More textual adjustments and too extensive text reference for labelling.

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Our business group welcomes the possibility to comment on the state of the FPR. As a business group we see many benefits and possibilities in the free entry to the EU-market for CE-marked products. However, in reality the FPR hasnt worked for most of the fertilising products, especially products made of organic or recycled materials.

The Federal Quality Association for compost (BGK) welcomes the extension of the EU fertilising products regulation (EU FPR) to include or Fertilising products so that compost and fermentation products may be included as component material categories (CMC 3, 4 or 5) in the Product Function Categories (PFCs).

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On behalf of Ibero Massa Florestal (IMF), as an EBC-certified biochar producer in Portugal, I support the Fertilising Products Regulation (FPR) because it creates a harmonised market and improves safety standards. However, it currently overlooks the wider ecosystem services of biochar.

Unfortunately, the FPR is not delivering on its objectives as expected- which in principle are strongly supported by industry. From the point of view of an expert in growing media, who has worked for decades in R&D as well as in developing European standardards, there are reasons why growing media manufacturers have little or no interest in obtaining the CE mark. Please view the attachment for more information.

Opinion of the Chambers of Agriculture of France Public consultation on Regulation (EU) 2019/1009 on EU fertilising products The Chambers of Agriculture of France would like to make the following comments in the context of the evaluation of Regulation (EU) 2019/1009: 1. Application of IFR: a limited impact to date.

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Regulation (EU) 2019/1009 was intended to simplify access to the European fertilising products market. In practice, its implementation has been transformed into an excessively complex system, particularly penalising organic and organo-mineral fertilisers incorporating animal by-products (ABP).

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