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European Fertiliser Blenders Association

EFBA

EFBA is an association of European Union member states involved in the production of compound fertilisers blended by using various nutrients in a number of regional factories.

Lobbying Activity

Response to Carbon price paid in a third country under the carbon border adjustment mechanism (CBAM)

25 Sept 2025

Please find enclosed the response from the European Fertiliser Blenders Association (EFBA) on carbon price paid in a third country.
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Response to Adjustment of the obligation to surrender CBAM certificates to take account of ETS free allowances phase-out

25 Sept 2025

Please find enclosed the response from the European Fertiliser Blenders Association (EFBA) on the implementing act on free ETS allowances.
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Response to Carbon border adjustment mechanism (CBAM) methodology for the definitive period

25 Sept 2025

Please find enclosed the response of the European Fertiliser Blenders Association (EFBA) to the consultation on CBAM methodology.
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Response to Evaluation of the Fertilising Products Regulation

19 Sept 2025

The EFBA (European Fertiliser Blenders Association) welcome the objectives of the FPR, particularly the drive toward harmonisation and environmental protection. However, several critical implementation issues need to be addressed to ensure the regulation achieves its intended goals without overburdening operators. 1. Complexity and burden of implementation The FPR is highly complex and costly to implement, especially for SMEs. It requires significant changes in practices, investment in equipment, analytical procedures, and additional workforce. This represents a major barrier for small operators who lack the capacity to absorb these costs. Recommendation: Introduce proportionate requirements for small volumes and SMEs. 2. Limited scope reduced innovation No organic fertilisers and few biostimulants are currently placed on the market under the FPR, and fewer liming materials compared to EC Regulation 2003/2003. The rigid regulatory structure of the FPR allows little flexibility or innovation. Rather than encouraging the use of fertilisers with lower environmental impact, the complexity of understanding and implementing the regulation is pushing the market toward standard formulations and prompting manufacturers to revert to national marketing regulations. Recommandation : Simplify, allow more flexibility and limit administrative burden to enable FPR development. 3. Labelling too much information, poor readability Labels are overloaded with information, making them difficult to read and understand for end-users (farmers). This leads to vague or generic statements, reducing their usefulness. While the introduction of digital labelling is a positive step, it currently imposes more constraints than benefits. The most relevant product-use information (instructions, storage) could be digitalised. Recommendation: Simplify labels to focus on essential marketing and agronomic data. Safety aspects are already addressed by CLP hazard labelling. Allow wider use of digital labelling. 4. Poor fit for blended fertilisers The FPR is not well adapted to tailor-made fertilisers formulated in small batches based on soil and crop needs (prescription fertilisation). These are inherently different from mass-produced standard products, yet the FPR imposes the same administrative and conformity requirements. This creates a disproportionate burden, especially for SMEs, It discourages tailor-made solutions that promote efficient and sustainable fertilisation. Recommendation: Easing of constraints for small volumes and small structures. Practical example: Allow the provision of a declaration of conformity by type, i.e. with the same qualitative composition but different proportions. 5. Logistical constraints and product reference inflation The FPRs shift from a nutrient-based approach to a product-manufacturer pairing leads to an explosion in product references, even when the nutrient content is identical. This creates significant logistical issues. Distributors and fertiliser blenders cannot physically store each bulk fertiliser separately, so they must combine products with the same formulation from different manufacturers in one cell, and are seen as manufacturers purely due to logistical constraints. Request for flexibility in the storage of fertilisers with the same formulation and falling under Module A, provided that they have no harmful effects Conclusion The FPR's goals are important, but without adjustments, its complexity, rigidity, and administrative burden may undermine its impact, especially for SMEs. Targeted simplifications and more flexible implementation rules would allow the regulation to better support innovation, sustainability, and real-life farming practices.
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