ASOCIACION ESPAÑOLA DE FABRICANTES DE ABONOS ORGANO-MINERALES Y ORGANICOS (ORGANIC AND ORGANO-MINERAL FERTILISER MANUFACTURERS´ SPANISH ASSOCIATION)
FOMA
It is an Association of manufacturers which joints the more representative Spanish companies on solid and liquid organic and organo-mineral fertilisers, organic soil improvers, amino acids, humic acids, growing media, biostimulants, etc.
ID: 330966713330-59
Lobbying Activity
Response to Amendment of the list of products and substances authorised in organic production
18 Nov 2022
The Organic and Organo-Mineral Fertilisers Manufacturers´ Spanish Association (FOMA) is leader in Spain in organic fertilisers, organo-mineral fertilisers, organic soil improvers and biostimulants for conventional and organic production. This Association wants to make the following comments about the Annex II of the Regulation (EU) 2021/1165 that has not been contemplated in the draft. Authorised fertilisers, soil conditioners and nutrients referred to in point (b) of Article 24(1) of Regulation (EU) 2018/848 Entry: Wood ash, from wood not chemically treated after felling It is only contemplated in the draft the possibility to use the ashes of wood as input for organic production. However, there is a large volume of ashes from the combustion of herbaceous materials (biomass) for the production of electrical energy or biogas which is mostly destined for landfills with consequent environmental impact-damage, and the occupation of a territory that stops being productive, and also this solution does not present any socioeconomic advantage. Another alternative is to use them as filling for construction materials, cements, concretes, cementation road, etc. but they are not very suitable. Just as not only struvite (already previously accepted by EGTOP) has been included in the draft, but it has also been extended to other precipitated phosphate salts because they have been introduced as CMC 12 in Regulation (EU) 2019/1009, something similar should be done with the ashes. Following the principles of the circular economy and considering that the ashes contain mineral nutrients of agronomical interest, the Commission have amended by the Delegated Regulation (EU) 2021/2087 the Annexes II, III and IV to Regulation (EU) nº 2019/1009 for the purpose of adding thermal oxidation materials and derivates as a component material category CMC 13 in EU fertilising products. An EU fertilising product may contain thermal oxidation materials obtained through thermochemical conversion under non-oxygen-limiting conditions from several inputs materials, among others, living or dead organisms or parts thereof, for example, herbaceous materials or biomass. Such products are niche products that comply with the principles of the circular economy and also comply with the principles of the organic production in a similar way that the wood not chemically treated after felling. Then the ashes from the combustion of herbaceous materials should have the same consideration that the ashes from the combustion of woody materials. Both are in line with the principles of organic production. We propose, accordingly, to include the ashes from herbaceous materials together with the ashes from wood, and then to modify the entry Wood ash of the authorising products in organic production, as vegetable ashes, with the requirements of Regulation (EU) nº 2019/1009: Name Compound products or products containing only materials listed hereunder ////// Description, specific conditions and limits Vegetable ashes from herbaceous or woody material Products must meet the requirements laid down in (not chemically treated after extraction or felling) Regulation (EU) nº 2019/1009 for CMC 13 Please see the attached file. Thank you.
Read full response22 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 in paragraph 1, shall be packaged in ready-to-sell packages of not more than 50 kg in weight for use by the final consumer with a content of derived products of not more than 50 % in volume. The reason of this measure is to exclude the subsequent use of the product for feeding purposes according to the Regulation (EU) nº 142/2011.We think that the supposed risk of diversion to animal feed would be exactly the same if the container is 50 kgs. bags or 500-600 kgs. big-bags, because when the product reaches the end user, the 50 kg bag or the big-bag must be opened or broken to be used or to be able to apply it in the field, so there is no justification to restrict the type of packaging, also taking into account that in big-bags it means less application work for the farmer, lower transport costs and greater sustainability of the entire process (consumption of plastic, emissions, etc.). Then this measure does not mitigate any risk for reaching the end point and should be removed. The solid products are frequently presented in big-bags on the market. Regarding mixtures, in the paragraph 3, it says that they may be mixed with any material of non-animal origin which is not listed in the catalogue of feed materials set out in the Annex to Regulation (EU) nº 68/2013. For manufacturing organo-mineral fertilisers, animal proteins are usually mixed with other materials such as mineral fertilisers, and sometimes with processed manure. The mixture with mineral fertilisers as ammonium sulphate, monoammonium phosphate, potassium chloride, potassium sulphate, magnesium sulphate, etc. which are listed into annex of Regulation (EU) nº 68/2013, are very frequent. Then it is impossible to comply the paragraph 3 of the article 4. We propose to remove this requirement because it is not possible to manufacture organo-mineral fertilisers without these mineral fertilisers. Moreover, for example, monoammonium phosphate or potassium chloride, are very used with a sufficient minimum proportion. These materials are unpalatable, according to the scientific knowledge, therefore “the component renders the mixture unpalatable to animals or it is otherwise effective in preventing misuse of the mixture for feeding purposes” as is indicated into chapter II, section 1, paragraph 3(b) of the Annex XI of Regulation(EU)nº 142/2011.Then the measure of packaging in ready-to-sell packages of not more than 50 kg in weight for use by the final consumer is not necessary, because they are unpalatable and excludes the subsequent use of the mixture for feeding purposes, and it does not mitigate any risks for reaching the end points. Regarding to hydrolysed proteins, they are products without health risk due to their production process with strong hydrolysis to reach high concentration in free amino acids, and they are included for animal feeding into Annex IV of Regulation (EC) nº 999/2001 without risk on the transmission of BSE, and also included into the Commission Regulation (EU) 2017/1017 catalogue de feed materials, and therefore we propose to include them into the article 3, namely, that they must be considered as having reached the end point as organic fertilisers and they do not need additional mitigation measures. Moreover on the market are frequent in liquid form and the supply in drums of 80-200-1000 lts. specially for industrial clients and big properties, and also with frequency they are concentrated hydrolysed proteins (amino acids) with a content of derived products of more than 50 % in volume, without mixtures, then it is impossible to comply with the measures of the article 4. We propose to include them into the article 3. To see the attached file for more details.
Read full responseResponse to Agriculture - List of products and substances authorised in organic production
22 Apr 2021
We would like to submit our feedback on behalf of the Organic and Organo-Mineral Fertilisers Manufacturers´ Spanish Association (FOMA), observer on the Commission Expert Group. This Association is leader in Spain in organic fertilisers, organo-mineral fertilisers and organic soil improvers for conventional and organic production.Our feedback is referred to the Annex II about authorised fertilisers:
1.Wood ash, from wood not chemically treated after felling
It is only contemplated in the draft the possibility to use the ashes of wood as input for organic production. However, there is a large volume of ashes from the combustion of herbaceous materials (biomass) for the production of electrical energy or biogas which is mostly destined for landfills with consequent environmental impact-damage and also this solution does not present any socioeconomic advantage. Following the principles of the circular economy and considering that the ashes contain mineral nutrients of agronomical interest, the Commission will amend by delegated acts the Annexes II, III and IV to Regulation(EU)2019/1009 for the purpose of adding thermal oxidation materials and derivates as a component material category in EU fertilising products, An EU fertilising product may contain thermal oxidation materials obtained through thermochemical conversion under non-oxygen-limiting conditions from several inputs materials, among others, living or dead organisms or parts thereof, for example, herbaceous materials or biomass. Such products are niche products that comply with the principles of the circular economy and also comply with the principles of the organic production in a similar way that the wood not chemical treated after felling. Then the ashes from the combustion of herbaceous materials should have the same consideration that the ashes from the combustion of woody materials. We propose, accordingly, to include the ashes from herbaceous materials together with the ashes from wood, and then to rename the entry of the authorising products in organic production, as vegetable ashes, with the requirements of Regulation(EU)2019/1009.
2.Crude potassium salt, product obtained from crude potassium salts with a minimum content of 9 % water-soluble K2O and 2 % water-soluble MgO
Although the term kainite (indicated in the Regulation EC nº 889/2008) has been removed from the draft, this type of crude potassium salt with the requirements of the draft, only is possible to find it in Germany deposits (Leopoldshall, Stassfurt, Sachsen-Anhalt among others), as kainite, potassium and magnesium sulphates with high concentration of halite (sodium chloride). These mineral deposits contain more than 60 % of sodium chloride, then is difficult to admit the CE marking due to agronomical efficiency and high salinity. The German company that commercialise this mineral, requested in 2013 to Commission Working Group on Fertilisers, the revision of the entry in Regulation(EC)2003/2003 about the content of potassium.But the majority of the crude potassium salts that we can find in Europe only contain potassium, not magnesium (or low quantities). Then to facilitate the availability of crude potassium salts in Europe for use in organic production and avoid monopolistic actions that distort the market, we consider that it is advisable to modify the characteristics of the crude potassium salts, removing the requirement of 2% of water-soluble magnesium oxide. In this way, it would be possible for other European companies to supply crude potassium salts for organic production and would benefit the availability to end users of these inputs. This would allow the use of crude potassium salts of numerous natural European deposits that comply with the principles of the organic production as sylvite, carnallite, etc., sometimes with with physical processes to separate harmful salts for the soils (e.g. halite), to use directly or as raw material. You can check the attached file with the full feedback.
Read full responseResponse to Technical amendments to the annexes to the Fertilising Products Regulation
8 Mar 2021
We would like to submit our feedback about tolerances, on behalf of the Organic and Organo-Mineral Fertilisers Manufacturers´ Spanish Association (FOMA) with identification number in the EU Transparency Register nº 330966713330-59 and Observer on the Commission Expert Group on Fertilising Products. In recital 25 of the draft the Commission justify to modify the tolerances of mineral nutrients for inorganic fertilisers. This issue is the same reasoning for the organic fertilisers, organo-mineral fertilisers and organic soil improvers. The tolerances set for these PFCs are also very narrow given the existing technical capacities. This is especially the case for declared nutrients where the content of the nutrient might be relatively low when compared to the whole product. A low nutrient content means that the deviation of its declared value is also small, as it is declared as a percentage of the nutrient content. Moreover, as we know about the standardisation processes running on the working groups of the CEN, are very frequents the interferences of the organic matter with the analysis of the mineral nutrients, then the tolerances must be widened to ensure a fair balance between the technical capacities of the manufacturer and the need for correct information to be provided to the end-user.And in recital 26, the Commission propose to modify the tolerances of carbon for soil improvers. This issue is also the same reasoning for the organic fertilisers and organo-mineral fertilisers. They may have also a significant content of organic carbon and allowing for a deviation in absolute terms of only two percentage points is very restrictive. It is therefore appropriate to allow a bigger deviation in absolute terms while maintaining the existing relative deviation. Moreover the organic raw materials are usually from natural origin and wide fluctuations of carbon contents are habitual.
Then, our modification proposals (not new proposals, but similar to the Commission´s nutrient proposal for inorganic fertilisers and carbon for organic soil improvers) are:
Organic fertilisers PFC 1(A)
Organic carbon: up to a maximum of 3,0 percentage points in absolute terms.
Primary macronutrients: Nitrogen forms (total and organic), total phosphorus pentoxide and total potassium oxide, up to a maximum of 2,0 percentage points in absolute terms.
Secondary macronutrients: Total and water-soluble magnesium oxide, calcium oxide, sulphur trioxide, -50 and +100 % relative deviation of the declared content of those nutrients up to a maximum of -2 and +4 percentage points in absolute terms.
Total and water-soluble sodium oxide, - 25 % of the declared content up to a maximum of 0,9 percentage point in absolute terms + 50 % of the declared content up to a maximum of 1,8 percentage points in absolute terms.
Organo-mineral fertilisers PFC 1(B)
Organic carbon: up to a maximum of 3,0 percentage points in absolute terms.
Primary macronutrients: Total phosphorus pentoxide and total potassium oxide, up to a maximum of 2,0 percentage points in absolute terms.
Secondary macronutrients: Total and water-soluble magnesium oxide, calcium oxide, sulphur trioxide, -50 and +100 % relative deviation of the declared content of those nutrients up to a maximum of -2 and +4 percentage points in absolute terms.
Total and water-soluble sodium oxide, - 25 % of the declared content up to a maximum of 0,9 percentage point in absolute terms + 50 % of the declared content up to a maximum of 1,8 percentage points in absolute terms.
Micronutrients: If concentration is below o equal to 2 %, ± 50 % of the declared value.
If concentration is more than 2 % and below or equal to 10 %, ± 50 % of the declared value
Soil improvers PFC 3
Primary macronutrients:Nitrogen forms (total and organic), total phosphorus pentoxide and total potassium oxide, up to a maximum of 2 percentage points in absolute terms.
You can check the attached file with the full feedback and the proposed tables.
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