Integrated Nutrient Management Action Plan

The German phosphorus platform DPP e.V. welcomes the Commission’s initiative to develop an EU action plan for better nutrient management. The DPP supports the Green Deal’s objective of reducing nutrient losses while ensuring that soil fertility is not compromised. This should be supported by the holistic circular closure approach.

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FTS is an industry association representing the Controlled Environment Agriculture (CEA) sector, a fast-evolving emerging solution that potentially offers great improvement for the inclusiveness, sustainability, and competitiveness of all food systems, in line with the EU policy objectives and Green Deal goals. CEA deploys technology that is based on imitating natural processes (i.e.

Dear European Commission, As two-thirds of the excessive nitrogen and phosphorus levels in waters originate from fertilizers in agriculture, our submission (attached) will focus on this aspect. CCB has, for more than 20 years, participated in HELCOM as an observer, with a focus on Baltic Sea eutrophication problems.

A coordinated, integrated nutrient management plan is a very welcome, overdue framework to align existing and future policies to improve the overall performance of the agricultural sector, while considering non-agriculture N and P sources and losses as well.

EEB welcomes the initiative for an EU action plan for integrated nutrient management (INMAP). The war in Ukraine has highlighted the EU’s dependency on imports of fertiliser and livestock feed, but even though our current food system is relying on limited raw materials and fossil gas, we are using these resources in a wasteful way with huge losses from field to plate.

NITROGEN AND PHOSPHORUS, ESSENTIAL NUTRIENTS FOR PLANT GROWTH Nitrogen and phosphorus play a key role in both yields and the quality of cereal production. Farmers are also concerned with the quality and yield of fodder, including grass.

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The increasing use of industrial processes has led to the accumulation of nitrogen and phosphorus in aquatic, terrestrial and atmospheric ecosystems. These anthropogenic forms of inorganic nutrients exceed the natural purification capacity of the air, water and soil. This creates a major imbalance in the overall nitrogen balance and poses growing environmental problems.

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EBIC urges the European Commission to include specific references to the use of plant biostimulants and other fertilising products which directly contribute to enhanced nutrient use efficiency; particularly in the context of the current global food and fertiliser crisis and its wide-ranging and long-term implications for food security.

ECOFI urges the European Commission to include specific references to the use of organic-based fertilisers, including organo-mineral fertilisers, and integrated plant nutrition management practices as well as other fertilising products which directly contribute to enhanced nutrient use efficiency and better nutrient uptake; particularly in the context of the current global food and fertiliser crisis and its…

Attached is a contribution from Friends of the Earth France, who have been working on synthetic fertilisers for several years. Based on this experience, the main levers identified to reduce the consumption of synthetic fertilisers and fertiliser losses are: livestock reduction and exit from industrial livestock farming, investment in organic farming and leguminous production, and the introduction of binding measures…

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Attached is a contribution from Friends of the Earth France, who have been working on synthetic fertilisers for several years. Based on this experience, the main levers identified to reduce the consumption of synthetic fertilisers and fertiliser losses are: livestock reduction and exit from industrial livestock farming, investment in organic farming and leguminous production, and the introduction of binding measures…

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Yara would like to thank the European Commission for the opportunity to contribute to the preparatory work for the EU action plan for better management of nutrients (Integrated Nutrient Management Action Plan, INMAP). Yara helps European farmers to select and manage plant nutrients in a sustainable way, in line with our mission to responsibly feeding the world and protecting the planet.

FOUR PAWS welcomes the initiative from the European Commission for a more sustainable management of nutrients. Given that more than 60% of European land is used to produce feed for farm animals, livestock farming is a significant part of the challenge and can also offer solutions if the necessary changes are encouraged. For this reason, we are glad to provide more feedback on the call for evidence in the attachment.

CIBE, the International Confederation of European Beet Growers, welcomes the opportunity to provide feedback to the European Commission’s call for evidence regarding the initiative "Nutrients – action plan for better management", with the ambition to develop an integrated nutrient management action plan which will look at the entire nitrogen and phosphorus cycles, covering all environmental media and all relevant…

EurEau is the European Federation of National Associations of Water Services and is therefore very much involved in environmental topics and welcomes the holistic nutrient management approach proposed by the European Commission in order to address the nitrogen and phosphorus cycles.

Fertilizers Europe welcomes European Commission’s initiative to provide a comprehensive framework to ensure a more sustainable and efficient use of nutrients throughout and would like to thank for the opportunity to provide our feedback. Fertilizers Europe represents the interests of the majority of mineral fertilizer manufacturers in the European Union.

Excerpts from the attachment: Following the example of the NSPs for the CAP, European legislation should require Member States to implement the “Farm to Fork” strategy nationally in order to establish a comprehensive national strategy for agriculture and food.

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Nutri2Cycle urges the European Commission to address the anachronistic requirements of the Nitrate Directive and allow digestate and recovered fertilizers to actively reduce the utilisation of chemical fertilisers, effectively closing the nutrient loop and enabling carbon storage.

Copa and Cogeca are the united voice of farmers and agri-cooperatives in the EU. Together, they ensure that EU agriculture is sustainable, innovative and competitive, guaranteeing food security to half a billion people throughout Europe. Copa represents over 22 million farmers and their family members whilst Cogeca represents the interests of 22 000 agricultural cooperatives.

Nutrients – action plan for better management Call for evidence – DVGW reaction DVGW is the German Technical and Scientific Association for Gas and Water. We are very much involved in the protection of drinking water resources and welcome the holistic nutrient management approach proposed by the European Commission in order to address the emissions of nitrogen losses which we are facing as a very severe threat over…

An essential lever to prevent nutrient leakage from waste water to natural environments (air, soil and water) is the agricultural reuse of nutrients contained in human excrets. The separation of domestic waste water at source is a promising route. This needs to be supported at European level to encourage 1. public research, R & D, public information on the subject, 2.

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In Europe, avoiding nutrient leakage to media (water, soil and air) must be achieved by reinventing sanitation systems, especially urban ones. Indeed, centralised wastewater treatment systems face recurrent saturation. There is also a high footprint in terms of energy expenditure, greenhouse gas emissions (N20) and pollution of aquatic environments (NO3, etc.).

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IFOAM Organics Europe welcomes the Commission’s initiative to develop an EU action plan for a better management of nutrients. This should provide the holistic approach needed to achieve the 2030 target set in the Farm to Fork and Biodiversity strategies to reduce nutrient losses by at least 50%, while ensuring that there is no deterioration in soil fertility.

IMAA (The International Methionine Analogue Association) appreciates the initiative of the European Commission, regarding the integrated nutrient management action plan and the objective to look at the entire nitrogen (and phosphorus) cycles.

FEhS Institute for Building Materials and EUROSLAG appreciate having the opportunity to participate in the consultation. In view of climate change, population growth and the current situation in Eastern Europe, one goal of the initiative must not be lost sight of: the security of supply with food and feed as well as with renewable raw materials.

ECN welcomes the initiative to set up an integrated nutrient management plan with regard to a comprehensive legsilative approach to become carbon neutral by 2050 and to set up a Circular Economy in Europe. Bio-waste plays a key role in the Circular Economy.

Veolia welcomes the initiative to provide the EU with an action plan for better nutrient management, with the aim of ensuring the Union's food security. This includes reducing the dependency of the Union’s agriculture on single supplies, stopping eutrophication of inland and marine waters, and tackling the challenges of climate change and energy transition.

Agroecology Europe, the European association promoting agroecology as a set of practices, a science and a movement across Europe, welcomes the Commission’s initiative to work on an integrated nutrient management action plan. Europe's environmental security is being impacted by the alarming losses and leakage of nutrients from agriculture into the environment.

GWP CEE asserts that nature-based solutions should be integrated into nutrient management and that it is paramount that the current inadequate wastewater collection and treatment in rural areas is bound with the lack of water and nutrients in agriculture in the immediate vicinity. Under the currently valid EU legislation wastewater collection and treatment in small settlements (<2000 PE) is not clearly regulated.

Summary – for more information please read the enclosed document The Stockholm University Baltic Sea Centre (transparency reg no 514687319814-91) strongly supports the Commissions aim of closing the nutrient loops.

This action plan has long been awaited and therefore requires substantive reflection. As regards manure management, this plan could also include the carbon cycle. The various existing European policies (and related scientific research) are still too fragmented and applied independently of each other, which does not facilitate their adoption on the ground.

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Aafa is the professional trade union of actors in the growing media sector, mulching, organic soil improvers, organic and organo-mineral fertilisers and biostimulants. Representing more than 95 manufacturers of innovative fertilising materials and inputs to sustainable plant crops. We thank the competent authorities for their willingness to implement an action plan for nutrient management.

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FCIO Opinion on the EC Study on Nutrients — Action Plan for Better Management The Farm to Fork and Biodiversity Strategy aims to find sustainable solutions that contribute to climate change mitigation and biodiversity while enabling the productivity of European agriculture and the supply of healthy, affordable food.

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The intergrated nutrient management initiative which its holistic apporach to the nutrient cycles will look – among others - on measures how to „stimulating the market for recovered or recycled nutrients“. We welcome, the initiative for improvements of soils and environmental threats against nitrogen and phosphorus surpluss in general.

Kemira welcomes progress towards integrating the EU’s nutrient policies, with the development of INMAP (Integrated Nutrient Management Action Plan). Kemira also supports the Green Deal objective to reduce nutrient losses by 50% while ensuring that there is no deterioration in soil fertility.

EasyMining supports an EU nutrient policy. However, the INMAP will not be a sustainable nutrient action plan if efficient use and recycling of safe nutrients is not a target with clear goals and actions. The transition to a circular economy is crucial in building a sustainable society.

COMIFER (France): our scope of investigation, our principles the French Committee for the Study and Development of Reasoned Fertilisation (COMIFER) brings together institutional, technical, scientific, industrial and economic stakeholders on issues of fertilisation and soil fertility management at French level. It has several hundred members.

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We welcome the goal to halve nutrient losses. It will have great benefits through improved air quality, improved water quality, biodiversity and reduced N2O emissions. Halving NH3 emissions alone would bring health benefits that would outweigh the costs for reducing emissions(1). In the Farm to Fork strategy, a reduction of fertilizer use by 20 % by 2030 is mentioned.

Please find attached UNIFA’s contribution to the Call for Evidence for an initiative “for better nutrient management”. As you may know, the Union of Fertilisation Industries (UNIFA) represents 36 companies that produce mineral, organo-mineral and organic fertilisers, liming materials and biostimulants.

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ESPP (European Sustainable Phosphorus Platform) welcomes progress towards integrating EU nutrient policies, with the development of INMAP (Integrated Nutrient Management Action Plan). ESPP supports the Green Deal objective to reduce nutrient losses by 50% without deteriorating soil fertility, as fixed by the Farm-to-Fork and Biodiversity Strategies, in synergy with nutrient recycling.

As an agricultural trader, we are quite surprised in some cases about the return, the lack of knowledge of the institutions about the alternatives to mineral fertilisers that exist, for which we have a strong feedback on assimilation, the environment, interest, etc.

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The European Marine Board (EMB) Secretariat supports the European Commission’s Nutrient Action Plan for Better Management to help reduce nutrients by at least 50% and hope that it will complement the Zero Pollution Action Plan. The problem statement highlights the importance of an integrated approach on nutrient pollution including air, water, soil and climate.

Fertilisers Efficiency Enhancers, a Sector Group of Cefic, appreciates the opportunity to contribute to the consultation on a Nutrients' action plan for better management. Please refer to the documents attached for detailed information about urease and nitrification inhibitors and their contribution towards the achievement of the ambitions of the Action Plan and the green Deal in general.

Dumipro. Urgency It is important to see the urgency of dealing with this issues raised. Failure to do so will result in biodiversity and soil condition is only more pressurised and erodes the quality of life in the back. It is up to the sector to make a transition give.

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Dumipro Producers of Sustainable Minerals, which are the entrepreneurs we represent! A young ambitious interest organisation established in 2018 due to the need for the interests of this particular group to better represent entrepreneurs.

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Nutrient-Recycling is inevitably for a sustainable nutrient management. There are already several technologies which are able to solve the problems. Also lots of new technologies and measurements are developed constantly in the EU and in the world. My feeling is, that sometimes it is not technologies, which are missing, but holistic strategies that have to be encouraged.

Closing the nutrient cycles as N and P in agriculture is a general requirement in the EU member states (MS) practices and several technologies are available in the plant cropping sector as intercropping, applying cach crops, agro-forestry, crop residue management, crop fertilisation practices e.g. application of processed or unprocessed manure, application of N inhibitors and others.

Better nutrient management with the aim of reducing nutrient losses guides the efficient use of mineral fertilisers. In principle, these have a relatively high efficiency, but there are still possibilities for optimisation, for example by adding nitrification and urease inhibitors to mineral nitrogen fertilisers.

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Nutrient use in agriculture is based on maximum production without regard to the health of pets or to take into account emissions to the environment. This poses many problems due to the unacceptable pollution of soil, water and air. Natural ecosystems are demonstrably affected (see also the Nitrogen Directive, the Habitats Directive and the Water Framework Directive).

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Integrated Agriculture (IF) and aquaculture (IMTA) production methods have been thoroughly studied and demonstrated their efficiency to recover and recycle nutrients while increasing and diversifying productions, in sustainable ways, and contributing to food sovereignty and security.

Pure nature knows no waste! There are just cycles for closing loops and valuable substances within the "biological cycle" are not wasted. During industrialization a "technical cyle" was established which affects the "biological cycle" by its emissions.

I believe it is crucial to bring together environmental actions by linking them functionally, using models that simulate the combined action of agronomic activities, climate, plant and land, it is possible to guide interventions to: — reduce the use of fertilisers without reducing production; — identify the ideal periods for distribution; — measuring GHG emissions; — decide which land and how many land should be…

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