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Asociación Nacional de Fabricantes de Fertilizantes

ANFFE

Asociación Española de Fabricantes de Fertilizantes, creada para la defensa de los intereses del sector y para promover la fabricación de fertilizantes de acuerdo con los principios del compromiso de progreso, suministrando productos de calidad y con el máximo respeto al medio ambiente, así como para promover un uso racional de los fertilizantes.

Lobbying Activity

Response to Aligning the biodegradability criteria for polymers in EU fertiliisng products to the REACH restriciton on microplastics

5 Apr 2024

ANFFE, the Spanish National Association of Fertilizer Manufacturers, association that represents the main fertilizer producers established in Spain, appreciates the opportunity to provide comments in relation to the biodegradability criteria for polymers used in fertilizing products. We want to express our support to the comments made by Fertilizers Europe. Regarding biodegradability criteria for coating agents and water retention polymers, we would like to highlight that we do not consider it appropriate to introduce in Annex II a new labelling requirement indicating to users that that they must apply the products at least 3 meters away from surface water bodies. Please find our comments in the attached document.
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Response to Simplification and digitalisation of labels on chemicals (CLP, Detergents, Fertilising Products)

26 May 2023

The National Association of Fertilizer Manufacturers (ANFFE) welcomes the publication of the proposal for the regulation on voluntary digital labelling of EU fertilizer products and asks the Commission to implement as soon as possible the regulation of the technical requirements and the information that can be included in the digital label. However, the proposal does not imply a real simplification of the labelling and a reduction in the size of the physical label (or the accompanying document), and consequently a reduction in costs. Also, there are some points that are not sufficiently clear in the proposal. We want to transmit several comments, that are included in the attached document.
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Response to Agronomic efficiency and safety criteria for by-products in EU fertilising products

14 Jan 2022

The Spanish National Association of Fertilizer Manufacturers (ANFFE) appreciates the Commission's proposals of November 23th, 2021, for the inclusion of by-products and high purity materials as component materials (CMC 11 and CMC 15) in the Fertilizing Products Regulation (EU) 2019/1009. Many of these materials are part of the existing manufacturing processes, which have been developed and optimized over several decades. Their use as raw materials is of great importance for manufacturers and a disruption in their application can affect manufacturing processes both technically and economically and jeopardize the circular economy practices of the industry. Therefore, it is of great importance to establish the requirements for its safe use, thus guaranteeing its future use as a component material of fertilizing products. ANFFE is a member of Fertilizers Europe and collaborates with this European association in various fields, including regulatory and technical aspects. Instead of making a long description of the points on which we wish to comment, we want to state that we fully support all the comments sent to the Commission by Fertilizers Europe in its document dated November 30th, 2021.
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Response to Simplification and digitalisation of labels on chemicals (CLP, Detergents, Fertilising Products)

17 Sept 2021

The Spanish National Association of Fertilizer Manufacturers (ANFFE) wishes to provide the following comments on digital labelling: -It is a very good idea that part of the label could be included in digital form, because otherwise the information may not fit in the label, also taking into account that it is written in several languages. It would help manufacturers to comply with the CLP regulation, especially for bagged and packaged products and facilitate the information to national surveillance authorities and farmers. -There is experience in the fertilizers industry with the provision of digital information (use of websites, apps for mobile devices, etc.) and easily applicable technical solutions are currently available (marker codes, QR codes, Bar codes, printing of an URL, etc. ). -We consider it very important that this option is carried out as soon as possible, since companies are already preparing their labels. If digital labelling is implemented after July 2022, the manufacturers will then have to modify the labels that they have printed at that moment, generating waste and extra economic costs. So it is essential that this option is available before the beginning of 2022. -It is important to specify which are the basic information that must go on the sack, big-bag, container or invoice, and the information that can be in the digital label. The information that we consider should be in digital format is the one that is “new” in comparison with Regulation 2003/2003 (environmental references, ingredients, etc.). So we think that the physical label, at least for mineral fertilizers, should be similar to the labels of current Regulation 2003/2003, and all the “new information” of Regulation 2019/1009 should be included in digital format (as optional).
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

1 Jun 2021

En la Asociación Nacional de Fabricantes de Fertilizantes (ANFFE) consideramos que el REACH es adecuado para su propósito y cumple sus objetivos. No obstante, entendemos que hay áreas en las que se pueden introducir mejoras, entre las que podemos mencionar las siguientes: • simplificación de los procedimientos de autorización, registro y evaluación de sustancias, • coherencia entre REACH y otras legislaciones, • enfoque proporcionado para el registro de determinados productos, • garantizar el cumplimiento de la normativa y los requisitos de seguridad de los productos importados a la UE. En ANFFE entendemos que en la próxima revisión de REACH los cambios se deben realizar atendiendo a las necesidades detectadas y tras una evaluación de impacto exhaustiva previa, para valorar las consecuencias de cualquier cambio propuesto tanto para el sector químico como para otros sectores afectados. Además, consideramos fundamental el diálogo en todo momento con las partes interesadas. Mas observaciones en el documento adjunto
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

The Spanish National Association of Fertilizer Manufacturers (ANFFE) considers that REACH is suitable for its purpose and achieves its objectives. However, we understand that there are areas where improvements can be made, including the following: • Simplification of procedures for the authorization, registration and evaluation of substances. • Consistency between REACH and other laws. • Proportionate approach to the registration of certain products. • Compliance with regulations and safety requirements for products imported into the EU. ANFFE considers that in the next REACH review, changes should be made in response to the needs detected and after a prior exhaustive impact assessment, to assess the consequences of any proposed change for both the chemical sector and other affected sectors. In addition, we consider essential the dialogue at all times with the interested parties.
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Response to Technical amendments to the annexes to the Fertilising Products Regulation

16 Mar 2021

The National Association of Fertilizer Manufacturers (ANFFE) appreciates the opportunity to express our following comments to the draft Commission Delegated Regulation amending Annexes I, II, III and IV to the Fertilising Products Regulation: ANNEX I PFC 1(C)(II)(a): STRAIGHT INORGANIC MICRONUTRIENT FERTILISER •Point 2. Micronutrient salt fertiliser. The requirement that “10 % by mass of micronutrient salt fertilizer shall consist of a water-soluble micronutrient” has been removed, claiming that some carbonates and phosphates that are not soluble in water would be excluded. COMMENT: Some micronutrients may be immobilized in soils at high pH, and the problem is aggravated by high phosphate additions, so they must be applied in a soluble and available form by the plant. ANNEX III PART I • Point 1 (h). In the case of products in liquid form, it is proposed to declare the nutrients by dry weight, in descending order of magnitude, claiming that in some cases almost everything could be water and there is no sense declaring the volume of water. COMMENT: We propose to eliminate the word “dry” from the sentence. Our proposal is: “in the case of products in liquid form, by weight, in descending order of magnitude”. If only nutrients have to be declared, it could lead to confusion and it may appear that liquid fertilisers have more nutrient content than solid fertilizers. • Point 3. For those component materials for which the European Regulation have established maximum residue limits in food or feed, it is proposed that, if the content of a substance is higher than the limit value, the maximum concentration of that substance in the EU fertilising product shall be indicated, together with a warning that “the EU fertilising product must not be used in such a manner as to risk leading to the exceedance of that limit in food or feed”. COMMENT: There is a lot of information that has to be contained in the label. To include also this information can be detrimental to the clarity of the message to be conveyed to the farmer. The fertilizing product must comply with the contaminant requirements included in the FPR, so there is no need to declare its content in the label. However, it seems correct to us that the proposed phrase is included in the labeling. PART II PFC 1(C)(I)(a): SOLID INORGANIC MACRONUTRIENT FERTILISER • Point 3. A combination of two or more physical forms (granulated, pelletized, powder, pearl) is allowed to be declared, claiming that some fertilizers have a mixture of various forms. COMMENT: We don’t support this modification, because it can be detrimental to quality of products, to agricultural production and to the environment. It will allow, for example, the marketing of fertilizing products with a mixture of granulated and powdered product. These mixtures of products with so different physical characteristics cause problems in mechanized application, generating an irregular distribution of fertilizing products and difficulties in their proper application. PART III Some tolerances have been extended. COMMENT: We don’t support this modification, because it can be detrimental to quality of products and to agricultural production. We propose to maintain in all cases the negative tolerances set out in the Regulation, and to accept the positive tolerances set out in the Commission amendment. In addition, we propose to include the following sentence: "The manufacturer will not be able to systematically benefit from the tolerance margins". Our proposalis in the attached document. ANNEX IV PART I • Point 3.2 - Although inhibitors are already included in point 3.1 a), plant biostimulants are not included in point 3.1. As a consequence, it will not be clear which module would be applicable to plant biostimulants, because they would not have to follow module B+C. We propose to include a new point 3.1 f): “(b) a plant biostimulant as specified in PFC 6”, and accept the amendment of the Commission.
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Response to Pyrolysis and gasification materials in EU fertilising products

15 Feb 2021

ANFFE, the Spanish association of fertilizers producers, is pleased to give the feedback to the following point of the draft Commission Delegated Regulation on STRUBIAS: PYROLYSIS AND GASIFICATION MATERIALS The updated EU rules on fertilising products (Regulation 2019/1009) will apply from 16 July 2022. They lay down an exhaustive list of materials allowed in fertilising products. The initiative would extend this list by adding pyrolysis and gasification materials (‘biochar’). COMMENTS: A. -In the text of ANNEX I, the process conditions to be met are indicated (temperature, residence times, gas temperatures, etc). Is it necessary to require a certificate from the supplier of the ashes in which this compliance is justified? B. -Does the ash supplier also have to provide the customer the analysis that is required, like any other raw material? C. -Is the Reach registration also going to be required for these products?
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Response to Thermal oxidation materials and derivates in EU fertilising products

15 Feb 2021

ANFFE, the Spanish association of fertilizers producers, is pleased to give the feedback to the following point of the draft Commission Delegated Regulation on STRUBIAS: THERMAL OXIDATION MATERIALS AND DERIVATES 1. The updated EU rules on fertilising products (Regulation 2019/1009) will apply from July 2022. They lay down an exhaustive list of materials allowed in fertilising products. The initiative would extend this list by adding thermal oxidation materials and derivates (‘ash-based’). COMMENTS: A. In the text of the ANNEX I, the process conditions to be met are indicated (temperature, residence times, gas temperatures, etc.). Is it necessary to require a certificate from the supplier of the ashes in which this compliance is justified? B. Does the ash supplier also have to provide the customer the analysis of the ash that is required, like any other raw material? C. Is the Reach registration also going to be required for these products? 2. “An EU fertilising product may contain thermal oxidation materials obtained through thermochemical conversion under non-oxygen-limiting conditions exclusively from one or more of the following input materials: (b) vegetable waste from the food processing industry and fibrous vegetable waste from virgin pulp production and from production of paper from virgin pulp, AND/OR FROM FORESTS OR CROPS BIOMASS, if not chemically modified;” COMMENTS: We propose to either add the new text that has been included in capital letter, or to add two new points: “k) Products obtained from forest biomass” “l) Products obtained from biomass from agricultural crops”
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Response to Precipitated phosphate salts and derivates in EU fertilising products

15 Feb 2021

ANFFE, the Spanish association of fertilizers producers, is pleased to give the feedback to the following point of the draft Commission Delegated Regulation on STRUBIAS: PRECIPITATED PHOSPHATE SALTS AND DERIVATES IN EU FERTILISING PRODUCTS 1. The updated EU rules on fertilising products (Regulation 2019/1009) will apply from July 2022. They lay down an exhaustive list of materials allowed in fertilising products. The initiative would extend this list by adding precipitated phosphate salts and derivates (‘struvite’). “The precipitated phosphate salts shall contain: (a) a minimum phosphorus pentoxide (P2O5) content of 16 % of the dry matter content;” COMMENT: We propose to reduce the minimum P2O5 content to 10% - 12% P2O5, as long as the material meets the other requirements (heavy metal limits, process conditions, etc). The fertilizer industry should be able to use salts with lower concentration of P2O5. We also think that it is important to indicate the quality of the P2O5, requiring that at least part of it should be assimilable.
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