3R-BioPhosphate Ltd.
3R
3R-BioPhoshate Ltd.
ID: 239501011544-78
Lobbying Activity
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 minimize the high risk of cross- and re-contaminations of animal protein content materials after the material is leaving the production factory, e.g. during the handling, transportation, storage and/or applications of the derived products listed in the Article 4 of the Commission Delegated Regulation. The defined preventive and safety measures are well needed, sufficient, acceptable and providing appropriate response on the public concerns about the safe use of animal protein content materials in open ecological agricultural environment. In this context we fully agree with the defined preventive and safety measure such as: packaging in ready to sell packages of not more than 50 kg in weight for use by the final consumers with maximum inclusion rate of 50% according to Point 2 of the Article 4 of the Commission Delegated Regulation. These measures will prevent the fraudulent use of these derived products in the market of feed in line with the Regulation (EU) 142/2011. Moreover the likelihood of ready-to-sell packaged derived products as a fertilising products being cross-contaminated is low versus products that are transported/handled in bulk. The defined preventive and safety measures in the Paragraph 2 of Article 4 is progressive and well needed solution that aiming to improve the safe use of the material and protect public,- final consumers,- human and animal health.
We are recommending clarifying some legal gaps with further legal harmonisation during the finalisation of this Commission Delegated regulation.
1. Clear reference to the EFSA assessment for several Article 3 and Article 4 derived products needs to be included to the Commission Delegated Regulation:
2. Paragraph 3 of the Article 4 of the Commission Delegated Regulation should be harmonised with the Regulation (EU) 2019/1009.
3. Safety requirement for PAH16 limit is missing from the Commission Delegated Regulation.
4. Article 3 of the Commission Delegated Regulation defines the end point for ash. There are significant differences between the Annex III to Regulation (EU) No 142/2011 and CMC 13 of Annex II to Regulation (EU) 2019/1009 regarding to the processing requirements and functionalities which should be harmonised.
5. Article 3 of the Commission Delegated Regulation defines the end point for compost. There are significant differences between the Annex V to Regulation (EU) No 142/2011 and CMC 3 of Annex II to Regulation (EU) 2019/1009 regarding to the processing requirements which should be harmonised.
6.The determination of End points for certain derived products was based on the processing requirements for production of feed materials. Production of feed materials and fertilising products are very different purposes.
7.There is need for legal harmonisation of Category 2-Category 3 and derived products as input materials for CMC 14 Pyrolysis and gasification materials. Point 4(b) of the CMC14 of Annex II to Regulation (EU) 2019/1009 allows to use Category 2 or Category 3 materials or derived products as an input material for CMC14 products provided that the end point in the manufacturing chain has been determined with article (5)2, third subparagraph of Regulation (EC) 1069/2009. There is need for legal clarification and harmonisation how to ensure this referred end point. There is need for clear legal clarification and harmonisation of Regulation (EU) 2019/1009 and Delegated Regulation with inclusion of legal text that derived products listed in Paragraph 1 of Article 4 of Delegated Regulation could be further processed in CMC 14 of Annex II to Regulation (EU) 2019/1009 with giving an exemption from Paragraph 2 and Paragraph 3. of Article 4 of Delegated Regulation.
Read full responseResponse to EU farm policy - Evaluation of its impact on sustainable management of the soil
4 Aug 2019
Thank you for the consultation opportunity. One of the most important impacts on sustainable management of the soil is the quality and quantity of the input fertilisers to maintain economical food production in the agri sector. In this context the negative impacts of the chemosynthetic mineral fertilisers highlighted, most importantly the Cadmium and Uranium contaminated mineral phosphate, which is mainly imported critical raw material as of COM/2017/0490. Therefore, high legal priority should be given to the bio-based and recovered bio-fertilisers, based on the technical specification as of the new EU Fertilising Products Regulation. In this context, high priority and objective driven focus on the substitution of the chemosynthetic mineral fertilisers, which are to be replaced with recovered and innovative bio-fertilisers at as high degree level as it is possible would result significant positive impacts on the sustainable management of the soil already in short term. The legal priority selection of the recovered bio-fertilisers for sustainable management of the soil providing long list of benefits in all European climatic and soil conditions; including improved food safety, restoration of soil natural balance, enhanced biodiversity, elimination of environmental and climate impacts; while creating new rural economy and progressive sustainable developments.
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