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Dear Sirs, I represents Fertiberia, the Spanish fertilizer producer. My comments in line with Fertilizers Europe and with ANFFE (National Spanish Association) are: 1) We support digital labelling due to the volume of information required now by the new Regulation and CLP, etc 2) We consider digital labelling permite to save packaging costs, 3) We think digital labelling facilitate the management of changes in the…

EBIC welcomes the Commission proposal on optional digital labelling. EBIC calls for the introduction of a criterion for professional users versus non-professional users, so that digitisation for products intended for professional users can become a reality. As it stands, the proposal on digital labelling does not go far enough, and most EBIC members would not invest in creating digital labels.

Our company’s experience when it has applied for mutual recognition of a fertilising product has been rather negative. The evaluation of the mutual recognition file in the relevant administration, for example in France, is very slow and cumbersome with successive requests for information that makes the process very slow and commercially unoperational.

Filed in Spanish · English published by the European Commission

Please see the contribution from the European Biostimulants Industry Council (EBIC) in the attached file. In summary, while Regulation (EU) 2019/515 remains a key mandatory EU tool and performs well in certain countries, such cases remain rare, and plant biostimulant manufacturers often give up on making use of the principle and problem-solving procedures in place.