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Laying down a list of animal by-products that can be used in fertilizers without additional official controls

Food safety

This draft supplements existing rules on fertilizers with detailed conditions for placing on the market certain fertilizers containing animal by-products without further official controls needed.

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Public consultation

ID: 13478

Lobbying Activity

18 responses

European Biogas Association Urges Simpler Rules for Organic Fertilizers

European Biogas Association, 24 Oct 2022

EBA requests aligning the regulation with existing fertilizer standards to remove redundant sanitation requirements. They seek recognition for alternative transformation parameters to facilitate the trade of digestate across the EU.
Streamlining these rules would reduce compliance costs and expand market access for biogas producers.
Synthetic fertilizer manufacturers could face increased competition from more accessible organic digestate products.

Danish Agriculture Council urges removal of fertilizer packaging limits

Landbrug Fødevarer - Danish Agriculture and Food Council, 21 Oct 2022

DAFC supports recycling nutrients but opposes the 50kg package size and 50% volume limits. They argue these rules create unnecessary regulatory obstacles for professional farming operations.
This would lower transport costs and reduce the environmental impact of plastic packaging.
Regulators might struggle to prevent animal by-products from being illegally reused as animal feed.

Yara urges EU to scrap restrictive fertilizer packaging and concentration limits

YARA BELGIUM S.A., 24 Oct 2022

Yara requests deleting or reformulating rules regarding packaging size and ingredient concentrations to reflect market realities. They argue that current limits on content and bag size are counterproductive and burdensome.
This allows Yara to maintain efficient bulk distribution and avoid product dilution costs.
Farmers face higher costs and logistical burdens from smaller, less effective fertilizer packaging.

Italian chemical lobby urges EU to scrap restrictive fertilizer rules

Federazione Nazionale dell'Industria Chimica italiana, 21 Oct 2022

The association requests the removal of packaging limits and mixing bans for animal-based fertilizers. They also want more manufacturing methods recognized as safe for protein-based products.
Removing these restrictions would protect industry operations and avoid unsustainable waste disposal costs.
Organic farmers lose access to essential materials for maintaining healthy soil fertility.

Insect producers welcome EU rules for upcycling insect frass

International Platform of Insects for Food and Feed (IPIFF), 21 Oct 2022

The organization supports defining an end point for processed insect waste to be used as fertilizer. This reform would allow these products to be sold across the European Union. They also request the future integration of insect waste into general fertilizer legislation.
The industry would generate new profits by selling waste products instead of paying for disposal.
Traditional mineral fertilizer manufacturers may lose market share to these sustainable biological alternatives.

France Nature Environnement urges less restrictive organic fertilizer rules

France Nature Environnement, 24 Oct 2022

The organization seeks more flexible rules to encourage recycling organic waste. They recommend using additives to prevent fraud instead of imposing strict restrictions.
This change would support environmental objectives by promoting a circular economy.
Regulatory bodies may face increased risks regarding the fraudulent use of fertilizer.

Consultation response

European Biochar Industry Consortium, 24 Oct 2022

The European Biochar Industry (EBI) Consortium welcomes the Commission’s initiative to move towards the achievement of Green Deal in terms of nutrient circularity and thus support the EC aim to determinate end-points for certain derived products in the manufacturing chain. Therefore, allowing them…

Biostimulant industry slams "unworkable" rules on animal by-products

European Biostimulants Industry Council, 21 Oct 2022

The industry requests deleting unworkable mixing restrictions and packaging requirements. They also demand reclassifying hydrolysed proteins as safe based on existing scientific risk assessments.
This would allow manufacturers to maintain standard operating procedures and reduce unnecessary costs.
Environmental goals suffer as the proposal fails to support circular economy ambitions.

Consultation response

Union Nationale des Industries de la Fertilisation, 24 Oct 2022

See the document downloaded

Organic fertilizer industry urges deletion of 'unworkable' by-product rules

European Consortium of the Organic-based Fertilizer Industry, 24 Oct 2022

The industry demands the removal of unworkable mixing and packaging restrictions. They also want rules to include all organic fertilizer categories.
Removing these restrictions would allow companies to maintain standard bulk delivery practices.
Regulators focused on preventing fraud in the food chain would lose specific oversight measures.

Consultation response

European Compost Network ECN e.V., 21 Oct 2022

ECN welcomes the draft ‘Commission delegated regulation supplementing Regulation (EC) No 1069/2009 of the European Parliament and of the Council as regards the determination of end points in the manufacturing chain of certain organic fertilisers and soil improvers’, in order to make them available…

Consultation response

Suomen Biokierto ja Biokaasu ry, 24 Oct 2022

Finnish Biocycle and Biogas Association welcomes the proposal to determine the end point in the manufacturing chain for certain products that can be used as organic fertilizers and soil improvers. We would like to provide the following comments. We agree that the end point in the manufacturing…

ESPP demands broader nutrient recycling in EU fertilizer rules

European Sustainable Phosphorus Platform, 24 Oct 2022

ESPP requests including materials like composts and precipitated phosphates in the regulation. They propose replacing restrictive mixing and packaging rules with anti-palatability additives.
Broadening the rules would expand the market for phosphorus recycling technologies.
Environmental targets are undermined because restrictive rules prevent the use of recycled nutrients.

Consultation response

Afaïa, 24 Oct 2022

AFAÏA est le syndicat professionnel des acteurs de la filière des supports de culture, paillages, amendements organiques, engrais organiques et organo-minéraux et biostimulants. En tant que représentant pour la France des entreprises fournissant les matières fertilisantes et intrants innovants des…

Consultation response

Industrieverband Garten e.V., 24 Oct 2022

IVG-Kommentierung zum Entwurf einer delegierten Verordnung „zur Ergänzung der Verordnung (EG) Nr. 1069/2009 hinsichtlich der Bestimmung von Endpunkten in der Herstellungskette von bestimmten organischen Düngemitteln und Bodenverbesserungsmitteln.“ Düsseldorf, Oktober 2022 Der von der…

Consultation response

3R-BioPhosphate Ltd., 24 Oct 2022

Defining an end-point for derived products within the meaning of Regulation (EC) 1069/2009 for fertiliser use is very much welcomed. We and our associates very much welcome and fully agree on to take the needed preventive and risk mitigation measures to protect public and animal health, to…

Consultation response

ASOCIACION ESPAÑOLA DE FABRICANTES DE ABONOS ORGANO-MINERALES Y ORGANICOS (ORGANIC AND ORGANO-MINERAL FERTILISER MANUFACTURERS´ SPANISH ASSOCIATION), 22 Oct 2022

About the measures of risk mitigation which are necessary for reaching the end point of certain organic fertilisers and soil improvers and they are referred to in paragraphs 2 and 3 of the article 4, we want to make some allegations.In the paragraph 2, it says that the derived products referred to…

Consultation response

European Organic Fertilizers Manufacturers Association, 22 Oct 2022

EUROFEMA asks the Commission to take into consideration the following amendments:  Allow validated alternative processing parameters for the determination of end points for compost, biogas digestion residues and processed manure and processed frass;  Waive the limit for ABP derived…