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Lobbying Activity

Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

9 Mar 2022

C-Resource GmbH has the following comments on the draft directive concerning soil health, its protection, sustainable management and restoration in the EU. In view of the existing and impending threats to humanity, we propose measures that can be implemented immediately. • Indicators of soil health and their range of values As an indicator of soil health, the weight ratio between carbon (C) and nitrogen (N), the so-called C/N ratio, as well as the humus content of soils are generally acknowledged measurands. This C/N ratio can be applied to different soil types and is given as a dimensionless ratio. The C/N ratio of a consistently healthy soil in grassland is about 11:1, in arable land about 14:1 and in forestry even about 21:1. The content and composition of humus are essential parameters for soil fertility. Even at low content, humus has a diverse and decisive effect on biological, chemical and physical soil properties as well as on the most important processes in the soil itself. • Measures that can help reduce nutrient losses by at least 50% without degrading soil fertility (which would lead to a reduction in fertilizer use of at least 20%) C-Resource has already developed a fertiliser, the C-Humus fertiliser according to the new Fertiliser Regulation (EU) 2019/1009. This humus fertiliser exceeds all requirements. The challenge is to implement the production of the C-Humus fertiliser on a large scale. The fertiliser concept is based on combining the properties of biomasses and plant carbon to produce a stable fertiliser that, on the one hand, continuously releases nutrients to the soil and, on the other hand, stably stores carbon in the soil in the form of plant carbon. The fundamental difference between a mineral NPK fertiliser and our C-Humus fertiliser is the carrier material of the nutrients: Mineral fertiliser: Water-soluble salts. C-Humus fertiliser: Water-storing plant carbon. Translated with www.DeepL.com/Translator (free version) • In addition to the policy options listed above, the impact assessment will also consider alternative, non-legislative policy instruments such as self-regulation, voluntary agreements and governance, standardization, financial incentives and economic instruments In these areas, we have already initiated activities on financial incentives by ourselves (e.g. an implementation of voluntary CO2 avoidance certificates for farmers). Furthermore, there is already a market for humus build-up certificates in the agricultural sector in Germany and Austria. One of the economic instruments can be the obligation of the farmers to allocate their farm manure surplus to a nutrient recycling under the premise of water recovery against payment of the nutrient value. A regulation that would result in the farm manure being put into a material form worthy of transport in order to make it mandatory to move it economically from nutrient surplus areas to nutrient demand areas. This measure would lead to a reduction in fertilizer use far beyond the 20% reduction envisioned by the EU.
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