ESPP European Sustainable Phosphorus Platform

ESPP (European Sustainable Phosphorus Platform) supports the need for a Circular Economy Act to accelerate recycling, facilitate the market for secondary materials and incentivise their use. This Act should address nutrients and the biobased economy, as well as EU Critical and Strategic Raw Materials.

ESPP welcomes the announced aim to revise EU rules on public procurement towards sustainability and resilience. This should be coherent with the EU Circular Economy Act, planned for 2026, and with implementation of the EU Critical Raw Materials Act.

For coherence, the Taxonomy Climate criteria for anaerobic digestion should be modified to allow phosphorus recovery as per the criteria of the Taxonomy Environment (Circular Economy) criteria. The Climate criteria (2021/2139) currently require that digestates from eligible AD processes are used as fertilising materials, meeting the requirements of the EU Fertilising Products Regulation 2019/1009 CMCs 4-5: - pages…

ESPP welcomes the Phosphorus recovery from waste water (Taxonomy Environment criteria 2023/2486 Annex II $2.1) coherent with the inclusion of phosphate rock on the EU list of Critical Raw Materials (CRM Act 2024/1252) and with the principle of phosphorus reuse and recycling targets of art. 20 of the revised Urban Waste Water Treatment Directive (2024/2049).

Elemental Phosphorus P4 and Purified Phosphoric Acid should be on the EU Strategic Raw Materials List. Both are essential for all identified Strategic industries: batteries, renewable energy, electronics-data, aerospace. All these sectors need phosphorus flame retardants to meet fire safety requirements. The EU is import-dependent for P4 on China, Vietnam and Kazakhstan.

ESPP welcomes the proposal to reinforce EU Critical Raw Materials policy. We particularly support the two Roadmap objectives: 1. Define priorities, and 3. Strengthen the EU value chain including recycling. We suggest that, beyond the Roadmap proposals, it is necessary to address the links between energy security, food security and CRM policy.

ESPP (European Sustainable Phosphorus Platform) supports the need to improve waste prevention and separate collection. In particular, separate collection of (non-avoidable) food waste and organics is important (including from caterers, restaurants), in order to enable recycling of phosphorus, other nutrients and organic carbon, by e.g.

ESPP welcomes that the Call for Evidence for the BioTech 2 consultation of 10th June identified fertilisers as an area for action, citing creation of lead markets and simplification of legislation. This is coherent with the EU Fertiliser Action Plan (19th May 2026) which states that the Biotech Act will prepare measures to create lead markets for bio-based fertilising products.

ESPP welcomes that the Biotech II Call for Evidence identifies fertilisers as an area for action, citing creation of lead markets and simplification of legislation for (bio-derived) fertilisers. Biotech II should recognise the Importance of recycled nutrients for fertiliser supply resilience, food security and EU competitiveness, and engage actions for a single market for secondary nutrients across Europe, support…

ESPP welcomes the clarification of Taxonomy criteria for nutrient recycling in composting and anaerobic digestion of biowaste, but regrets that other proposed clarifications and facilitations for nutrient recycling are not taken into account.

ESPP supports the suggested widening of the IED scope to cover intensive cattle farms and aquaculture, in coherence with the inclusion today of large pig and poultry farms. ESPP supports that the IED process should better take into account EU Circular Economy objectives.

ESPP (European Sustainable Phosphorus Platform) underlines the need to maintain and pursue the objectives of the EU Green Deal to achieve both environmental and economic sustainability objectives. Green Deal objectives for climate change, energy consumption and nutrient loss reduction are key to EU strategic resilience by making industry, agriculture and food production more efficient and less dependent on imported…

ESPP welcomes the objectives of revising REACH towards Green Deal ambitions but regrets that the Circular Economy is not addressed. In particular, the application of REACH art. 2(7) “recovered” substances needs to be clarified.

ESPP (European Sustainable Phosphorus Platform) welcomes the evaluation of the Urban Waste Water Treatment Directive (UWWTD) and the importance indicated for sewage sludge, considering both treatment / decontamination and “subsequent use as a fertiliser”.

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.

ESPP (European Sustainable Phosphorus Platform) regrets that the proposed text addresses only certain technical wastes, and not organic wastes, nutrients and fertilisers. . This is regrettable given the current EU fertilisers supply and price crisis (resulting from Russias was on Ukraine and now the Hormuz Strait crisis), impacts on farmers incomes and on food security, and the emphasis on developing nutrient…

ESPP welcomes the proposal to establish a Critical Raw Materials Centre to support CRM projects in accessing public and private finance and address market and supply chain challenges. There are currently a confusing number of EU initiatives and EU-funded centres: Critical Chemicals Alliance, CRM Facility, Strategic Projects, CRM Alliance, SCRREEN (1, 2 and 3), EIT Raw Materials, Fertilisers Action Plan, Raw…

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).

ESPP (European Sustainable Phosphorus Platform) welcomes that the proposed update on Battery Labelling maintains and clarifies the obligation to declare Critical Raw Materials present at > 0.1% w/w (this obligation is already included in the Annexes of 2023/1254). We note that the CRM Act 2024/1252 Annex II (list of CRMs) includes both Phosphate Rock and Phosphorus.

For the CRM Phosphate Rock (P), the European Sustainable Phosphorus Platform ESPP notes that the following materials, potentially significant for phosphorus recovery and recycling, are missing in the list proposed in the draft regulation annex: - Animal manures and slurry these contain in total a similar quantity of P to that used in mineral fertilisers. - Agricultural run-off water, e.g.

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.

ESPP (European Sustainable Phosphorus Platform) considers that the E PRTR is an important and effective tool for ensuring public access and transparency of environmental data. ESPP welcomes the Roadmap proposal to improve the contribution of E PRTR to Circular Economy objectives by including data on resource consumption.

ESPP (European Sustainable Phosphorus Platform) considers as positive this initiative and supports EU action in favour of the Circular Economy, for which policy at the European level is important to ensure a dynamic and operational single market and to remove barriers for recycled nutrient products, for recycling technologies and for recyclable waste/secondary raw materials.

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.

ESPP regrets that the proposed Roadmap does not address the obstacles posed to the Circular Economy by the animal feed and feed additives regulations. Reference is twice made in the proposed Roadmap to better or more efficient “use of resources”, but no reference is made to the EU Circular Economy Action Plan, nor in any way to the circular economy or recycling It is our understanding that any feed additive which is…

ESPP considers it important that the Farm Sustainability Data Network (FSDN) should progressively deliver complete and harmonised datasets across all Member States, including for nutrient management (Tables NM1, NM2 and NM3 of the Annex VIII tables and new FSDN variables).