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Integrated Nutrient Management Action Plan

Environment

Nutrients (nitrogen and phosphorus) are essential for life and important natural resources. Yet, their losses to the environment lead to air, soil and water pollution, biodiversity losses and climate impacts. While the implementation of the existing legislation has allowed for major improvements over the past decades, tackling the inefficiencies in the nutrient cycle, including nutrients pollution, requires additional action at EU level for food security, human health and ecosystem preservation.

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Public consultation

ID: 12899

Lobbying Activity

25 responses

Environmental NGO demands 50% cut in nutrient losses by 2030

European Environmental Bureau, 26 Apr 2022

The organization demands the EU maintain its commitment to reduce nutrient losses by at least 50% and fertilizer use by at least 20% by 2030. They call for a transition away from industrial animal farming towards extensive farming systems and reduced meat and dairy consumption. They also want stricter emission limits and polluter-pays principles applied to nutrient pollution.
This would reduce environmental damage costs and advance their zero pollution agenda.
Industrial livestock farmers face transition costs and reduced production from extensive farming requirements.

Chemical industry urges stricter phosphorus limits in wastewater

European Chemical Industry Council, 20 Apr 2022

The organization requests stricter phosphorus discharge limits in the Urban Waste Water Directive revision. They argue existing limits are insufficient and better results could be achieved with current technologies at no extra cost.
This would increase demand for their coagulant products used in phosphorus removal.
Water utilities face potential costs if upgrading treatment systems beyond current requirements.

European farmers reject 'one-fits-all' EU fertiliser reduction targets

European farmers, 26 Apr 2022

The organization opposes uniform reduction targets for fertilisers across the EU. They recommend focusing on precision farming and efficiency-based advisory services to reduce nutrient losses.
Avoiding mandatory cuts prevents potential yield losses and ensures farmers can maintain soil fertility.
Environmental advocates lose the legal certainty of specific, EU-wide targets for reducing nutrient pollution.

IFOAM Organics Europe urges prioritizing organic farming in nutrient plan

International Federation of Organic Agriculture Movements EU Regional Group, 26 Apr 2022

The plan should recognize organic farming as a key tool for nutrient management. They call for strong support in national strategies and nutrient budget tools. They also want recycled fertilizers to meet organic production standards.
This would expand organic farming and protect farmers from fertilizer price volatility.
Synthetic fertilizer producers lose business as the EU shifts toward organic farming alternatives.

Fertilizers Europe calls for efficiency-based nutrient reduction targets

Fertilizers Europe, 26 Apr 2022

The industry proposes using efficiency indicators rather than absolute volume reductions to measure progress. They argue mineral fertilizers remain essential for food security and must complement organic sources. The group stresses that policy must account for local conditions and economic impacts.
Technical optimization over mandatory application cuts allows the industry to maintain production volumes.
Environmental groups lose if nutrient reduction targets are diluted by complex efficiency metrics.

European Biogas Association urges update to EU Nitrates Directive

European Biogas Association, 26 Apr 2022

The association wants the Commission to update the Nitrates Directive to distinguish digestate from raw manure. They advocate for digestate as a sustainable alternative to energy-intensive chemical fertilisers.
Removing application limits on digestate would expand the market for biogas co-products.
Producers of synthetic chemical fertilisers face reduced demand for fossil-fuel-based products.

Yara urges EU to prioritize nutrient efficiency over usage cuts

YARA BELGIUM S.A., 26 Apr 2022

Yara recommends adopting efficiency metrics rather than volume-based reduction targets for fertilizers. They also want the EU to provide financial incentives for farmers to use precision agriculture technology.
Efficiency-based targets allow Yara to protect its core fertilizer business while promoting its digital services.
Environmental groups lose if the EU avoids setting hard limits on total chemical fertilizer use.

Veolia backs nutrient recovery from wastewater for circular agriculture

Veolia Environnement, 25 Apr 2022

Veolia proposes recovering nutrients from urban wastewater to create a circular economy. They call for updating the Sewage Sludge Directive to better manage pollution risks.
Mandated nutrient recovery creates significant business opportunities for Veolia's water treatment services.
Non-EU mineral fertilizer exporters lose market share to local recycled nutrient sources.

Kemira urges EU to halve phosphorus limits in wastewater

Kemira Oyj, 25 Apr 2022

Kemira asks to further limit phosphorus pollution from wastewater effluents. They propose halving current discharge limits by using established chemical and biological technologies. This would align EU standards with the performance seen in Sweden and Finland.
Stricter discharge standards would increase the demand for Kemira's chemical treatment expertise.
Foreign fertilizer suppliers lose revenue as Europe reduces its reliance on imported phosphorus.

EurEau demands mandatory recycled nutrient blending in fertilizers

European Federation of National Associations of Water Services, 26 Apr 2022

EurEau regrets the lack of revision for the Nitrates Directive and CAP plans. They suggest introducing compulsory requirements to blend recovered nutrients in all mineral fertilisers. They also recommend strong control at source to prevent pollutants entering waste water.
Stricter agricultural rules would reduce the purification costs for water utility companies.
Mineral fertilizer companies would face higher costs due to mandatory blending rules.

VIER PFOTEN urges livestock reform in EU nutrient plan

VIER PFOTEN International, 26 Apr 2022

VIER PFOTEN highlights that livestock farming is a major environmental challenge. They urge the Commission to encourage changes in how animals are farmed.
Encouraging livestock farming changes would help the organization fulfill its mission of protecting animals.

European beet growers demand funding for precision nutrient management

International Confederation of European Beet Growers, 26 Apr 2022

CIBE insists the plan recognize crops' nutritional needs and successful existing reduction efforts. They request financial support for precision technology and backing for New Genomic Techniques.
Subsidized technology would help growers maintain yields while lowering their fertilizer costs.
Farmers in undersupplied regions lose if regulations ignore regional soil nutrient variations.

Agroecology Europe Urges Shift to Mixed Crop-Livestock Farming

Agroecology Europe, 25 Apr 2022

The organization calls for a redesign of food systems through the integration of livestock and crop production. They advocate for practices like crop rotation with legumes, reduced tillage, and diverse agroforestry.
Transitioning to agroecological systems would make farms more resilient and self-sufficient.
Conventional high-input farms and intensive livestock producers face significant production cuts.

Biostimulant industry urges EU recognition in nutrient management plan

European Biostimulants Industry Council, 26 Apr 2022

EBIC requests that the plan explicitly includes plant biostimulants and prioritizes nutrient use efficiency indicators. They advocate for removing regulatory barriers to nutrient recycling and innovative microorganisms.
Official recognition would facilitate market access and promote the uptake of biostimulant technologies.
Fixed fertilizer reduction targets could undermine EU production capacity and global food security.

Consultation response

DVGW Deutscher Verein des Gas- und Wasserfaches e.V. - Technisch wissenschaftlicher Verein, 26 Apr 2022

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…

Consultation response

Industrieverband Agrar e.V., 22 Apr 2022

The Industrieverband Agrar e.V. appreciates the opportunity to contribute to the consultation on a Nutrients' action plan for better management. Please refer to the document attached for detailed information.

European Marine Board urges inclusion of oceans in nutrient plan

European Marine Board, 19 Apr 2022

The Board believes the marine environment should be included in the integrated approach. They urge finding ways to recycle nutrients rather than mining them to achieve zero pollution. Cumulative pressure assessments should also be used to evaluate nutrient impacts.
Stronger marine protections help prevent the reduction in fisheries caused by nutrient pollution.
Mining companies face lost profits if the EU prioritizes recycling over mineral extraction.

ECOFI urges EU to include organic fertilizers in nutrient plan

European Consortium of the Organic-based Fertilizer Industry, 26 Apr 2022

The group urges the Commission to include specific references to organic-based fertilizers and nutrient use efficiency. They request the removal of regulatory barriers to support the uptake of recycled plant nutrition solutions.
Improved regulatory coherence would facilitate market access and growth for organic fertilizer manufacturers.
Intensive livestock farmers may face restrictions on the over-application of animal manures.

Consultation response

European Compost Network ECN e.V., 25 Apr 2022

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. Bio-waste can be turned through organic…

Stockholm University calls for ecological efficiency in nutrient plan

Stockholms universitet, 25 Apr 2022

The university advocates for ecological efficiency to be the central goal of nutrient management. They recommend replacing chemical fertilizers with manure and limiting livestock numbers in intensive areas.
These measures would protect the Baltic Sea ecosystem, fulfilling the centre's core environmental mission.
Industrial livestock farms and fertilizer manufacturers would face stricter limits and reduced product demand.

Consultation response

Fachverband der Chemischen Industrie Österreichs, 25 Apr 2022

FCIO-Stellungnahme zur EK-Sondierung „Nährstoffe – Aktionsplan für ein besseres Management“ Mit der Farm to Fork- und Biodiversitäts-Strategie sollen nachhaltige Lösungsansätze gefunden werden, die zu mehr Klimaschutz und biologischer Vielfalt beitragen und gleichzeitig die Produktivität der…

European Phosphorus Platform urges recycling focus in nutrient plan

European Sustainable Phosphorus Platform, 21 Apr 2022

The plan should prioritize nutrient recovery and recycling while promoting sustainable diets. The EU must reduce its dependency on imported phosphate rock and gas. New fiscal tools should monetize the environmental costs of nutrient consumption.
Proposed measures would expand the commercial market for recycled nutrient products.
Global raw material exporters would face declining demand for phosphate rock imports.

Consultation response

maki Consulting GmbH, 26 Apr 2022

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. In order to be as directionally reliable…

Consultation response

FarmTech Society, 26 Apr 2022

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…

Consultation response

Luftförorenings- och klimatsekretariatet, 22 Apr 2022

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…