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Association des Producteurs Europeens de Potasse

APEP

Representation of the EU Potash Industry vis-à-vis the European institutions and national governments in all questions concerning the EU Potash Industry

Lobbying Activity

Response to Evaluation of the Fertilising Products Regulation

19 Sept 2025

We welcome the opportunity to provide input to the Commissions evaluation of the Fertilising ‎Products Regulation (FPR).‎ ‎1. Effectiveness The FPR has achieved important progress in broadening the scope of fertilising products covered ‎and establishing harmonised safety thresholds, thereby improving environmental and health ‎protection compared to Regulation 2003/2003. However, several obstacles remain:‎ Circular economy and innovation: The limited number of Component Material Categories ‎‎(CMCs) and the rigid process for updating them hinder the inclusion of innovative and ‎secondary raw materials.‎ Market access: While CE marking opened the market on paper, many organic, recycled, ‎and biostimulant products still face barriers due to the restrictive CMC system and ‎burdensome conformity assessment requirements.‎ Coherence: Overlaps and inconsistencies with REACH and CLP have created unnecessary ‎complexity. In particular, the FPR imposes REACH+ obligations requiring Annex VIII data ‎and Chemical Safety Reports even for substances produced below 10 t/y. These ‎requirements are disproportionate, not based on impact assessments, and do not ‎demonstrably improve safety.‎ ‎2. Efficiency Compliance costs are excessive compared to the benefits delivered, especially for SMEs. Many ‎substances used in fertilising products at volumes below 10 t/year are manufactured by upstream ‎suppliers, leaving customers unable to verify the level of REACH registration or to convince ‎suppliers to update their dossiers as required.‎ In addition, overlapping labelling obligations from FPR, CLP, and the new digital labelling rules ‎create redundancy, increase packaging waste, and confuse consumers. The combined rules often ‎force manufacturers into costly and impractical label redesigns.‎ ‎3. Relevance The FPR is not sufficiently flexible to support emerging bio-based solutions, efficiency-enhancing ‎fertilisers, and nutrient use efficiency (NUE) products, which are central to EU policy goals on food ‎security, soil health, and circularity. Controlled- and slow-release fertilisers, inhibitors, and NUE ‎products lack an adequate regulatory pathway.‎ ‎4. Coherence The FPRs interaction with other EU legislation is problematic:‎ With REACH: By not recognising normal tonnage bands, low-risk exemptions, or food/feed ‎approvals, the FPR duplicates regulatory burdens without added safety. Safety of fertilising ‎products is already ensured through other EU frameworks (food/feed hygiene, ‎contaminants, residues). We urge reinstating normal REACH requirements and clarifying ‎that impurities and unintended substances are not component materials.‎ With CLP: The new formatting obligations (minimum font size, spacing, colour rules) are ‎impractical for multilingual packaging and small pack sizes. Exemptions for fertilising ‎products or treatment via guidance, not binding law, would better balance safety and ‎feasibility.‎ ‎5. EU Added Value The FPR has harmonised certain product categories, improving internal market access. However, ‎optional harmonisation remains necessary as many innovative products are excluded from the FPR ‎pathway. Without reform, national rules will continue to play a disproportionate role, reducing the ‎Regulations EU added value.‎ ‎6. Recommendations‎ Restore alignment with normal REACH tonnage bands and exemptions; apply stricter ‎requirements only for hazardous or CMR substances.‎ Clarify in Annex II that impurities/unintended substances are not component materials.‎ Introduce science-based criteria to enable faster inclusion of innovative and secondary raw ‎materials.‎ Simplify and harmonise labelling rules by exempting fertilising products from rigid CLP ‎formatting requirements and expanding the scope of digital labelling to reduce packaging ‎waste.‎ Extend the scope of the FPR to cover NUE and efficiency-enhancing fertilisers.‎ Attached are 2 position papers detailing further the input provided.
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Response to Technical updates of the Emissions Trading Scheme (ETS) State aid guidelines

5 Sept 2025

APEP, the Association of European Potash Producers, welcomes the European Commissions initiative to revise the ETS State Aid Guidelines, and calls for the re-inclusion of potash in the updated framework to support decarbonization investments, competitiveness and strategic autonomy for the sector. Please find attached APEP's detailed feedback.
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Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič) and Verband der Kali- und Salzindustrie e.V.

18 Jun 2025 · Potash industry in Europe

Meeting with Veronika Vrecionová (Member of the European Parliament, Committee chair)

1 Apr 2025 · Tariffs to Russian fertilisers

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič), Dārta Tentere (Cabinet of Commissioner Maroš Šefčovič) and Verband der Kali- und Salzindustrie e.V.

23 Jan 2025 · Exchange of views on the challenges faced by the European potash industry and possible ways to address them.

Meeting with Fabien Santini (Head of Unit Agriculture and Rural Development)

21 Jan 2025 · Current situation with regards of potash’ production and market in the EU and possible restrictive measures targeting Russian potash imports

Response to Agronomic efficiency and safety criteria for by-products in EU fertilising products

14 Jan 2022

Please find enclosed APEP's contribution to the public consultation regarding the agronomic efficiency and safety criteria for by-products in EU fertilising products. Best regards, Marco Baldoli Executive Director of APEP
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Response to Climate Law

3 Feb 2020

APEP explicitly supports the aim to limit global warming to 2°Celsius, especially against the background that a major part of the world potash production is used for the cultivation of agricultural crops. The cultivation of agricultural crops will be the commercial sector that will suffer most from climate change. Since 1990, the European potash industry has reduced the emission of CO2 by 80 % by operating efficient technologies. The further reduction of the carbon footprint is pushed forward. To continue in this direction, the European Potash Industry needs reliable politico- economic business conditions on the world potash market. Competing enterprises from Non EU Countries manufacture at higher CO2 emission levels and obviously lower energy and emission costs. Countries such as Russia, Belorussia or Canada lack comparable emission trading systems or similar far reaching climate regulations. The requirements of European Climate Protection Measures shall not be dispropor-tionate compared to Non EU Countries to protect the European Potash Industry from distortion of competition. Thus, it is indispensable that the European Legislator pro-vides appropriate relieve for the European Potash Industry, i. e. electricity and surro-gate fuels at acceptable prices. The aspired transformation process will considerably affect agriculture. It is important to the European Potash Industry to identify suitable criteria for assessing agricultural production systems correctly and to further develop climate-smart agricultural produc-tion systems during this transformation process. To relate key figures such as carbon footprint or water footprint to unit area, as it is common in agriculture, is with regard to climate-smart farming not constructive. When assessing climate compatibility of agricultural production systems, the efficiency of these systems can't be omitted. We recommend to asses agricultural production system by relating the carbon footprint to unit produce, e. g. kilogram CO2 per ton of wheat. Only by using appropriate criteria or key figures, agriculture will be able to reduce CO2 emission instead of exporting the problem to other regions. Furthermore, this approach will then indirectly limit land con-sumption for agricultural use and thus, protect valuable natural land from converting into arable land. Your sincerely, Dietrich Ehle Counsel to APEP
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