Products derived from animal by-products as component materials in EU fertilising products

ESPP (European Sustainable Phosphorus Platform) welcomes the proposal to include a number of animal by-products into the FPR CMC10. These materials have proven their agronomic value and safety by many years of use under national regulations in different Member States.

Submitted on behalf of EBIC, ECOFI, COTANCE, and Assofertilizzanti. The draft Delegated Act (Ares(2026)3815505) represents a meaningful step forward by expanding the list of animal by-products (ABPs) permitted as component materials in EU fertilising products.

Supply chain Italy, the association that supports and enhances the 100 % Italian agri-food chain, welcomes the European Commission’s initiative to gather opinions on the topic of products derived from animal by-products as component materials in EU fertilising products. Please refer to the detailed position paper attached.

Filed in Italian · English published by the European Commission

Coldiretti, the largest farmers’ representative organisation in Italy and Europe, with its 1.6 million members, welcomes the European Commission’s initiative to gather views on Animal by-products products as component materials in EU fertilising products. See detailed position paper attached.

Filed in Italian · English published by the European Commission

ASOPROVAC warmly welcomes and commends the European Commission’s continued efforts to foster a real circular economy. We firmly believe that progress towards circularity necessarily requires a constant review of the legislative framework so that it is updated in line with new scientific evidence and the current health situation, in particular as regards generic restrictions on certain ruminant by-products if they…

Filed in Spanish · English published by the European Commission

FNSEA expressed cautious support for the proposal to extend CMC 10 to include new products derived from animal by-products. We welcome the approach to assess the potential environmental impacts of the proposed materials and the strict conditions of use imposed on each material. We are, however, vigilant about the integration of materials that would present a higher health risk than processed manure.

Filed in French · English published by the European Commission

APAG, a sector group of Cefic, welcomes the opportunity to contribute to the public consultation on Products derived from animal by-products as component materials in EU fertilising products and wishes to highlight a critical inconsistency in the treatment of glycerine streams under Regulation (EU) 2019/1009 and Commission Delegated Regulation (EU) 2023/1605.

ANAFRIC (the Spanish Meat Business Association) welcomes the Commission’s public consultation on the initiative to review and expand the list of products authorised for use as components in EU fertilisers. We support the Commission’s efforts and believe that the proposed amendment contributes to a framework more consistent with the principles of a circular economy and evidence-based decision-making.

Filed in Spanish · English published by the European Commission

We have taken careful note of the draft delegated regulation extending CMC 10 to include new derived products from animal by-products. We welcome the prior assessment approach to identify and document potential environmental impacts and to justify the strict conditions of use imposed on each material.

Filed in French · English published by the European Commission

UECBV welcomes the European Commissions initiative on animal by-products. The European Livestock and Meat Trades Union (UECBV) welcomes the European Commissions initiative to include certain Animal By-Products (ABPs) as component materials in EU fertilising products, through the amendment of Annex II and Annex III to Regulation (EU) 2019/1009, CMC 10, and thanks the Commission for the opportunity to be consulted and…

Proalan, S.A., welcome the inclusion of new animal by-products in REGULATION (EU) 2019/1009 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 5 June 2019 laying down rules on the making available on the market of EU fertilising products.

AFAÏA, representing around 100 members, who market Supports de Culture, mulches, Organ Amendments, Organ and Organo-Mineral Fertilisers and Biostimulants, would like to thank the competent authorities for the opportunity to comment in the context of the consultation on these drafts.

Filed in French · English published by the European Commission

UNIC Italian Tanneries welcomes the Commissions initiative to further support circular economy pathways through the inclusion of additional animal-derived materials within CMC 10 under the EU Fertilising Products Regulation.

1. General Remarks The Spanish Biogas Association (AEBIG) welcomes the Commissions initiative to expand Component Material Category (CMC) 10 under Regulation (EU) 2019/1009. The inclusion of additional derived products represents an important step towards enhancing nutrient recycling, improving soil health, and supporting the EUs circular economy and climate objectives. 2.

Hello Nature International wants to warmly thank the Commission for the publication of the Commission delegated regulation draft related to the CMC10. Indeed, this delegated regulation is highly anticipated by the industry. A thorough reading of the proposed text allowed us to note a few editorial errors that are described in the enclosed text.

The Spanish Meat Industry Association (ANICE) welcomes the European Commissions initiative on animal by-products to include certain Animal by-products (ABPs) as component materials in EU fertilizing products, through the amendment of Annex II and Annex III to Regulation (EU) 2019/1009. ANICE thanks the Commission for the opportunity to be consulted and provide input.

Meat Industry Ireland (MII) welcomes the Commissions Delegated Regulation amending the EU Fertilising Products Regulation (EU) 2019/1009. While MII does support the adoption of this draft Delegated Regulation, we believe the current draft is somewhat limited in its scope. We advocate for the inclusion of a broader range of materials derived from animal by-products (ABPs).

Green Has Italia opposes the proposed total chromium limit of 400~mg/kg for hydrolyzed proteins because it lacks scientific justification and fails to distinguish between essential trivalent chromium (Cr(III)) and toxic hexavalent chromium (Cr(VI)).

Danish Agency of Green Transition and Aquatic Environment (SGAV) welcomes the Commissions proposal to include additional animal by products as component materials in EU fertilising products, supporting circular economy.

The Belgian authorities support the proposal to add CMC 10 to the FPR, in particular as regards the establishment of quality criteria to ensure the protection of human health and the environment. 2 comments: — the Paps are still in category 3 – The reference to other parts of the text should be better worded [e.g.: 6. Where compliance with the requirements set out out in point 5.2 and 5.4 = > set out in point 5.

Filed in French · English published by the European Commission

[FULL FEEDBACK ATTACHED] EFFOP has the following recommendations to the Commission: (1) Clarify the scope of CMC 10 with respect to fish-derived proteins. The Commission should include, in the regulatory text or in updated FAQ guidance published alongside the adopted regulation, whether fishmeal and fish-derived hydrolysed protein fall within the scope of CMC 10 PAP (point 1(c)) and/or hydrolysed protein (point…

The Centre for Feed Innovation (CFI) welcomes the Commission's efforts to support circular nutrient systems and more sustainable fertiliser pathways within the EU bioeconomy. Organic and recycled fertilising materials may improve resource efficiency, reduce dependence on synthetic fertilisers, and strengthen resilience within European food and agricultural systems.

The European Institute for Animal Law & Policy welcomes the opportunity to contribute to the Call for Evidence on Products derived from animal by-products as component materials in EU fertilizing products. This submission addresses the proposed inclusion of additional animal by-products as component materials in EU fertilizing products, its implications for the structure of industrial farm animal production, and the…

UNIFA (France Fertilisants) represents the plant nutrition and soil health industries. It brings together more than 30 companies producing all fertilization solutions (mineral, organic and organo-mineral fertilizers, organic soil improvers, liming materials and biostimulants), over 80 production and storage sites in France.

We welcome the proposed amendments to Annex II (CMC 10) and Annex III of Regulation (EU) 2019/1009. The inclusion of additional derived productssuch as processed frass, glycerine from Category 2 and 3 materials, processed animal protein, meat-and-bone meal, blood products from Category 3, hydrolysed protein, dicalcium and tricalcium phosphate, as well as horn- and hoof-derived materialsrepresents a positive step…

We welcome the proposed amendments to Annex II (CMC 10) and Annex III of Regulation (EU) 2019/1009. The inclusion of additional derived productssuch as processed frass, glycerine from Category 2 and 3 materials, processed animal protein, meat-and-bone meal, blood products from Category 3, hydrolysed protein, dicalcium and tricalcium phosphate, as well as horn- and hoof-derived materialsrepresents a positive step…

In February 2025, the Clean Industrial Deal set rules to enhance decarbonisation and competitiveness of the EU Common Market, aiming to position Europe as the leader of the circular economy by 2030. With a presence in 17 Member States and more than 131,000 employees within the European Union, Veolia, the world leader in environmental services across water, waste and energy, is a key European player in this…

Ragn-Sells welcomes the Commissions delegated regulation on products derived from animal by-products as component materials in EU fertilising products. We do, however, regret the regulations limited scope. At present, it remains unclear whether fish sludge is classified as an animal by-product.

Organic PRODUCTION, a company specialising in the production of organic fertilisers that have been produced for more than 150 years, welcomes the proposed amendment to CMC 10, which extends the list of materials derived from animal by-products that may be used in fertilisers in the European Union.

Filed in French · English published by the European Commission

The documents argument on manure classification directly supports the broader regulatory treatment of products derived from animal by-products (ABPs) used in EU fertilising products. If animal manure under LoW 02 01 06 is clarified as a by-product rather than waste when destined for lawful agricultural use, it aligns conceptually with how ABP-derived materials are already treated under EU fertilising product…

Ecco la traduzione in inglese: In June 2024 and November 2026, SAFE Food Advocacy Europe delivered two scientific presentations to EFSAs Stakeholder Emerging Risks group on the risk of microplastic contamination in soils.