K+S Aktiengesellschaft

The European Commissions proposal to amend the EU Organic Regulation has so far not taken into account one important issue: the removal of salt from Annex I of the Regulation. We therefore call on the European Parliament and the Council, in the ongoing legislative procedure, to delete salt from Annex I in order to ensure legal certainty for the salt sector and to avoid misleading consumers.

K+S Aktiengesellschaft is the leading European salt producer, providing rock salt, vacuum salt and sea salt for consumers. K+S welcomes the European Commissions initiative to update and simplify the EU Organic Regulation 848/2018. A key priority must be to completely remove sea salt and other salts for food and feed from Annex I of the Organic Regulation 2018/848.

K+S Group is an internationally oriented raw materials company based in Germany with production sites in Europe and North America that supplies the strategic minerals POTASH and SALT to European agriculture (potash fertilizers), industry, the pharmaceutical sector and consumers.

1 PUBLIC CONSULTATION ON DRAFT PROPOSAL IN GENERAL Today sufficiently transparent, valid and reliable methodologies and standards are still lacking to determine the efficiency of carbon removal and carbon farming measures. Therefore, the European Commission published a proposal for a certification framework for carbon removals as part of the Circular Economy Action Plan of the EU Green Deal.

As K+S, we see ourselves as pioneers in environmentally friendly and sustainable mining. Our constant efforts to set global standards resulted in several developments of new techniques and processes to better protect the environment and reduce our products footprints and these efforts are on-going.

K+S welcomes the opportunity to provide feedback on the Revision of benchmark values for free allocation under the EU ETS. K+S raises concerns and strongly recommends to change the proposal and to freeze the benchmarks at the 2025 level as the proposed reduction of the heat and fuel benchmarks is technically not achievable with best available technologies in the potash sector.

The Commission aims to improve the communication of labelling information and provide economic operators the flexibility to opt for the rules that are most appropriate for their specific products. In principle, this approach is heavily supported by industry including K+S as it may help save resources and costs, contribute to sustainability and facilitate communication.

The proposed inclusion of boric acid as well as borate salts into annex I part 1 does not serve the purpose of PIC Regulation. There are no expected benefits as all products potentially affected by an export notification are already assessed as safe in handling. Additional burdens for fertilizer producers endanger nutrient supply and thus compromise food security.