European Sustainable Phosphorus Platform
ESPP
The European Sustainable Phosphorus Platform promotes phosphorus sustainability and nutrient recycling in Europe.
Lobbying Activity
ESPP urges aligned EU Taxonomy rules for phosphorus recovery
4 Dec 2025
Message — ESPP calls for coherence between rules to allow phosphorus recovery from biogas plant digestate. They request including recovery processes that meet specific EU fertilizing product standards.12
Why — Aligning regulations would simplify operator uptake and improve the economic viability of recycling.34
Phosphorus platform urges EU to prioritize nutrient recycling targets
2 Nov 2025
Message — The organization calls for including nutrients in the Act and simplifying rules for secondary materials. They recommend setting targets to reduce the consumption of virgin resources across the Union. They also want financial incentives to help recycled products compete with primary raw materials.123
Why — Reduced regulatory barriers would lower costs and facilitate the market for secondary phosphorus materials.45
Response to Food and Feed Safety Simplification Omnibus
14 Oct 2025
ESPP (European Sustainable Phosphorus Platform) regrets that this Call for Evidence fails to refer to circularity or recycling. EU Food, Feed, Animal By-Product and TSE Regulations today pose significant obstacles to the Circular Economy and to nutrient recycling. Valorisation of secondary materials in the food chain should be facilitated and encouraged, without compromising safety or farmer and consumer confidence. The proposed streamlining of the regulatory framework and simplification of procedures should be widened to ensure coherence with EU Circular Economy objectives. The ABP and TSE regulations should be fully reviewed in the context of the 2026 Circular Economy Act. See joint letter to DG SANTE on circularity of ABP materials April 2024 (16 signature organisations www.phosphorusplatform.eu/regulatory), animal Feed Circularity Catalogue (7 organisations https://fefac.eu/newsroom/ 23/5/25). See also the Joint call for nutrients in the EU Circular Economy Act (30+ organisations) attached. An overall review of the ABP, food and feed regulations should identify how recycling can be facilitated whilst ensuring safety, in particular: - the End-Point process: this does not currently function except for certain specific ABP materials/applications as specified in 1069/2009 and 142/2011 (including via the EU Fertilising Products Regulation), - facilitate EU and mutual recognition of National End-Points and national use authorisations, - rationalise the EFSA process: analysis of families of materials/processes/uses rather than one-by-one case decisions, development by EFSA of risk criteria and risk assessment guidance for different types of secondary material or recycling processes, to guide operators preparing dossiers and national regulator assessments, - improve coherence between ABP End-Points and End-of-Waste. The Animal Feed Regulation Annex III 767/2009 currently excludes use in animal feed of human excreta, sewage, sewage sludge or animal manure, irrespective of how they are processed. This should not apply where the process results in a purified substance with pathogens and contaminants removed to safe levels, e.g. recovery of nutrient minerals from incineration ashes. Certain processes should be considered to achieve a universal end-status, conferring both ABP End-Point and End-of-Waste (EoW), and also exit from any regulation limiting use of certain materials irrespective of their processing (e.g. Nitrates Directive). Such processes could include: incineration (under IED conditions) with recovery from ash ; recovery from offgases. The complexities of the ABP Regulation and daughter regulations are currently inaccessible to anyone other than ABP regulatory experts. This is an obstacle to circularity, preventing investor confidence, problematic for SMEs (active in process innovation, in agri-food and in valorisation of local secondary resource flows). Differences in requirements between different regulations (contaminant limits, testing requirements, authorisation and registration dossiers ) are an obstacle to recycling because of the variability and relatively small production volumes of secondary materials. A review should be engaged to identify: - complexities and difficulties of understanding, legal ambiguities, incoherences of definitions, wordings and terminology, - provisions which pose obstacles to circular economy. This review should include Animal By-Products, Animal Feed and TSE Regulations, taking into account safety and consumer confidence, in coherence with the EU Critical Raw Materials Act, REACH, Waste, Fertilisers, EU Taxonomy, Nitrates Directive, Common Agricultural Policy, IED site permitting This would contribute to regulatory clarity and alignment, thereby supporting innovation and responsible circularity across the agri-food and bio-based sectors European Sustainable Phosphorus Platform www.phosphorusplatform.eu
Read full responseESPP Urges EU to Simplify Rules for Recycled Fertilisers
19 Sept 2025
Message — The platform requests a reduction in certification costs and broader categories for raw materials. They argue current rules are too complex for small-scale recycling operations.12
Why — Simplified rules would reduce compliance burdens and accelerate the roll-out of recycled nutrients.3
Impact — Primary fertiliser producers would lose the regulatory advantage they currently hold over recycled alternatives.4
ESPP urges broader waste list for phosphorus recovery
25 Jul 2025
Message — Include additional phosphorus sources like animal manure, agricultural run-off, and food waste. Remove restrictive technical terms like mono-incineration to support broader nutrient recovery technologies. Request a clear table linking specific waste materials to target critical minerals.123
Why — Expanding this list creates new commercial opportunities for nutrient recycling and recovery.4
Impact — Mineral fertilizer producers may lose market share to sustainable, recycled alternatives.5
Phosphorus group urges EU to prioritize nutrient recycling
21 Jun 2025
Message — The platform demands nutrient recycling be recognized as a strategic priority. They request updated regulations to facilitate authorisation and support innovative recycling processes. New standards and procurement policies should also help create bio-based markets.123
Why — This would reduce strategic dependency and costs through circular and low-carbon innovation.4
Impact — Fossil-based producers would lose their market advantage against cheaper, recycled alternatives.5
European Sustainable Phosphorus Platform urges linking water to nutrient recycling
4 Mar 2025
Topic — The European Water Resilience Strategy will create a plan to ensure sustainable water management.
Message — ESPP requests a circular approach linking water resilience to nutrient management. They call for phasing out industrial chemicals and establishing mandatory recycling rates.123
Why — This strategy would reduce reliance on imported fertilisers and enhance European strategic autonomy.4
Impact — Russian fertiliser exporters lose revenue as the EU moves toward sustainable nutrient management.5
Response to Amendment of the list of products and substances authorised in organic production
25 Feb 2025
ESPP welcomes the proposed authorisation of calcium phosphates derived from sewage sludge ash as fertiliser in Organic Farming, based on the positive EGTOP Opinion of March 2024, and requests that this modification of the Organic Farming inputs regulation 2021/1165 be implemented rapidly, with the text as proposed. This proposal contributes positively to sustainability and productivity of Organic Farming, to stewardship of the EU Critical Raw Material Phosphate Rock (Critical Raw Materials Act 2024/1252) and to EU Circular Economy objectives. As indicated by IFOAM (17/6/2020) https://www.phosphorusplatform.eu/images/download/Joint-letter-ESPP-IFOAM-EU-recovered-phosphates-17_6_20.pdf: The authorisation of phosphate fertilisers from secondary sources (under appropriate conditions) is coherent with the overall sustainability objectives of Organic Farming and corresponds to a need in Organic Farming for phosphorus inputs to maintain crop productivity and an insufficiency of renewable phosphorus sources. ESPP notes that following the authorisation (2023/121) of struvite and precipitated phosphates from sewage and other sources, for use as fertilisers in Certified Organic Farming, products have already been Organic Certified and placed on the market. In order to ensure safety and farmer confidence, ESPP supports the proposal that the recovered calcium phosphate should respect the EU Fertilising Products Regulation quality criteria and contaminant limits. ESPP notes that the wording calcium phosphate can mean any inorganic compound (derived from sewage sludge incineration ash) consisting of calcium, phosphate, hydrogen and oxygen, e.g. monocalcium phosphate, dicalcium phosphate, octacalcium phosphate, amorphous calcium phosphates, hydroxyapatite, single super phosphate, triple super phosphate. In addition to calcium phosphate and precipitated phosphates from sewage sludge, there are today various other routes to recover high-quality, safe phosphates and other nutrients, from sewage and from secondary resource streams, such as food industry wastes, biorefinery streams, digestates, animal by-products ESPP requests that adoption of the proposed regulation (text as proposed) be followed by wider consideration for Organic Farming of recovered nutrients based on safety, quality and agronomic criteria. ESPP particularly requests future consideration, for Organic Farming, of calcium phosphates recovered from ash from animal by-products (certain animal by-products cannot be spread directly on fields and must be incinerated, so recycling of nutrients from ash is the best option) and of Calcined Phosphates from sewage (EGTOP gave a positive opinion in 2016 recommending authorisation for use in Organic Farming). ESPP suggests that EGTOP consider all ash-derived phosphates respecting the EU FPR (PFC1 mineral phosphate fertiliser criteria and CMC13 criteria, possibly subject to other specific Organic Farming criteria such as exclusion of manure from factory farming, solubility criteria ). This would avoid the current one-by-one assessments which are slow and time-consuming.
Read full responseESPP Calls for Equal Treatment of Recycled Manure Fertilisers
14 May 2024
Message — The application limit for recycled materials should match synthetic fertilisers. Product definitions should align with EU regulations to ensure quality and safety. Rules must prevent increased nitrate losses and higher livestock numbers.123
Why — This would eliminate costly labelling and traceability requirements for recycled product manufacturers.45
Impact — Developers of innovative nitrogen recovery technologies are excluded by the restrictive product list.6
Response to Evaluation of the National Emission reduction Commitments Directive
12 Mar 2024
ESPP (European Sustainable Phosphorus Platform) considers that the National Emissions Reduction Commitments Directive (NERCD) is important to ensure continuing reductions of emissions of concerned air pollutants. The Directive should integrate the objective to recover and recycle nitrogen and sulphur. NERCD is important in limiting emissions of the targeted air pollutants across Europe, and is necessary to achieve EU reduction targets, to avoid transboundary pollution and to ensure a level playing field across Europe for concerned activities. ESPP regrets that the call for evidence does not mention EU Circular Economy policy. We suggest that the evaluation of NERCD should consider not only prevention of emissions of nitrogen and sulphur but also recovery/recycling. NOx and ammonia gas abatement systems can be combined with nitrogen recovery, to produce nitrogen salts for fertiliser or industrial use. A revision of NERCD should require N-recovery where feasible, to reduce climate emissions and natural gas consumption related to synthetic ammonia production (so reducing EU dependency on imported natural gas and contributing to fertiliser supply resilience and to food security). This would be coherent with revision of the Industrial Emissions Directive, which increases emphasis on material efficiency and reuse, and with the Communication Ensuring availability and affordability of fertilisers, COM(2022) 590. Sulphur, which is increasingly required in fertilisers to ensure crop fertility, can also be recovered, for recycling, from SO2 abatement processes. For information on nitrogen and sulphur recovery see ESPP nutrient recycling technology process catalogue https://www.phosphorusplatform.eu/techcatalogue and ESPP SCOPE Newsletters 145 and 148 summarising nitrogen : www.phosphorusplatform.eu/Scope145 and www.phosphorusplatform.eu/Scope148 Limits to NOx and NH3 emissions under NERCD should be fixed to avoid risk of deterioration (nitrogen eutrophication by atmospheric deposition) of sensitive terrestrial and aquatic ecosystems, to ensure coherence with water quality and biodiversity objectives (Habitats Directive, Water Framework Directive, Nitrates Directive) and also to avoid negative impacts on soils (proposed Directive on Soil Monitoring and Resilience). The NERC Directive revision should reflect the Zero Pollution Action Plan and the nutrient loss reduction target set by the EU Farm-to-Fork Strategy, EU Biodiversity Strategy and COP15 Convention on Biological Biodiversity (reduce nutrient losses by 50% by 2030). EU agriculture policy (CAP farm funding and CAP National Action Plans) and Nitrates Directive NVZ Action Programmes should be compatible with NERCD nitrogen emissions limits. ESPP suggests that, the NERCD should also cover methane, for which emissions are often related to NH3 (agriculture, livestock, anaerobic digestates). In addition to being a significant climate gas, methane is a precursor of tropospheric ozone (a leading cause of air quality failure and health risks). Methane emissions must be prevented whilst developing EU biomethane production and enabling nutrient recycling from digestates.
Read full responseESPP urges minimum phosphorus levels in EU Soil Law
1 Nov 2023
Topic — This proposal aims to define healthy soil conditions and provide for sustainable restoration.
Message — ESPP suggests including minimum phosphorus levels to ensure soil fertility and crop productivity. They recommend aligning nitrogen limits with water quality rules and increasing stakeholder involvement.12
Why — Mandating soil fertility levels protects the market for sustainable phosphorus and recycling technologies.34
Response to Processed manure as component material in EU fertilising products
25 Oct 2023
ESPP thanks the European Commission DG GROW for the rapid production of these proposed criteria for Processed Manure which take into account comments made by stakeholders in previous consultations and in the Fertilisers Expert Group, in particular concerning post-processing. We have comments on the following points, detailed in attached pdf. 1) Precipitated phosphates, other nutrients recovered from processed manure The SANTE amending regulation 2023/1605 article 1 suggests that materials reach an ABP end-point ONLY IF they are used as component materials. This appears to imply that the materials do not reach and ABP end-point if they are used as inputs for processing to produce a component material (because they are not in this case used as a component material). This appears to mean that e.g. struvite precipitated from ABP Processed Manure would NOT have reached an ABP end-Point, so would not be eligible for the FPR (under CMC12) whereas that the Processed Manure FROM WHICH the struvite has been precipitated would be eligible (under CMC10). 2) Annex I, wording and ordering for clarity of reading of proposed criteria: 3) Limiting ammonia emissions and odour 4) Emissions and odour limitation when is this applicable ? 5) Herbicide residues 6) Clarification regarding use already today of composted, digested, pyrolysed or combusted (ash) manures 7) PAH limits 8) Minor wording points in JRC report
Read full responsePhosphorus Platform Urges Nitrogen Recovery Inclusion
3 May 2023
Message — They request including nitrogen recovery and expanding the scope to include manure and food waste. They also advocate for technology-neutral wording to ensure various recovery processes qualify.123
Response to Fitness check of how the Polluter Pays Principle is applied to the environment
10 Dec 2022
ESPP (European Sustainable Phosphorus Platform) supports better implementation of the Polluter Pays Principle (PPP), including with EU border compensation mechanisms on imports (e.g. of food, animal feed) to ensure that pollution and resource consumption are not simply exported and that EU industry and farmers are not unfairly penalised. The European Court of Auditors report (2021) emphasises that polluters do not bear the full costs of water pollution, despite reference to the PPP in art. 9 of the Water Framework Directive. Their report refers to diffuse agricultural pollution from nitrates and pesticides. However, phosphorus eutrophication should also be considered. See references on eutrophication societal costs in document attached. The implementation of the Polluter Pays Principle in the Common Agricultural Policy (CAP) is essential for nutrient losses and agrochemicals. This should be supported by the FaST tool (Farm Sustainability Tool for Nutrients) and implemented by requiring cross-compliance with Water Framework Directive River Basin Management Plans for all CAP subsidies, locally verified by river basin management committees and in Member State Water Framework Directive reporting. We note that in the Commissions legislative proposal for revision of the Urban Waste Water Treatment Directive (October 2022) UWWT Extended producer responsibility would be implemented for pharmaceuticals and cosmetics, so that companies placing these on the market must cover full costs of monitoring and quaternary treatment (art.9, Annex III). ESPP regrets that this does not cover industrial chemicals such as PFAS, plastic additives, micro-plastics nor agro-chemicals. This is despite PFAS being identified as a priority sewage sludge contaminant in JRC 2022. ESPP notes the Swedish Water call for a ban on all PFAS chemicals (2022), i.e. full implementation of the Commissions PFAS ban proposal SWD(2020)249. PFAS, pharmaceuticals, microplastics and other industrial and consumer chemicals, present in wastewaters or manure, can be significant obstacle to recycling of nutrients and of organic carbon. PPP should be applied to these chemicals to support the Nutrient Circular Economy. See references in document attached. This is increasingly important in the current fertiliser supply and price crisis (see European Commission Communication Ensuring availability and affordability of fertilisers COM(2022) 590, 9th November 2022 here). ESPP suggests that It is necessary to organise dialogue on how to reduce impacts of pharmaceuticals on nutrient recycling, at the EU level, with farmers, the food and beverage industries, supermarkets and environment and consumer NGOs. This dialogue should aim to share information available; jointly define research, monitoring and risk assessment needs; propose appropriate risk reduction measures and polluter pays mechanisms to cover costs of mitigating pharmaceutical pollution risks in Nutrient Recycling, in manure valorisation and in water treatment. This dialogue is needed at the EU level, because retailers and agri-food companies are global operators, as are pharmaceuticals companies, and in order to enable input to EU policies (Fertilisers Regulations, standards, chemicals policy ).
Read full responseResponse to European Critical Raw Materials Act
25 Nov 2022
ESPP welcomes the proposal to reinforce EU Critical Raw Materials policy. We particularly support the two Roadmap objectives: 1. Define priorities, and 3. Strengthen the EU value chain including recycling. We suggest that, beyond the Roadmap proposals, it is necessary to address the links between energy security, food security and CRM policy. We note that the proposed CRM roadmap already underlines the need to improve resource efficiency and support circularity, in particular by facilitating regulation and investment in recycling. Phosphate Rock is currently on the EU CRM List and is highly critical for the EU. Phosphorus is essential for life and so is absolutely non-substitutable in fertiliser, feed and food uses. The specific form of phosphorus P4 is also on the EU CRM list and the EU is 100% dependent on imports for P4 and derivates. P4/derivates are essential to a wide range of sectors in the EU, including fire safety, lubricants, water cooling, catalysts, production of cobalt (another CRM). See www.phosphorusplatform.eu/Scope136. Potash is also currently under discussion in the EU CRM list update process. The current fertiliser supply crisis: - for nitrogen fertilisers, results from energy insecurity (natural gas price and supply crisis); - for phosphate, results from international trade risks for the CRM Phosphate Rock; - for potassium, price and supply challenges. The European Commission Communication Ensuring availability and affordability of fertilisers, COM(2022) 590, 9th November 2022, recognises the EUs dependency on imports for fertilisers, and the impacts on farmers costs and on food insecurity. It is stated in this CRM policy consultation that energy raw materials (e.g. coal) and agricultural raw materials (e.g. wheat) do not fall under the scope of this consultation. The proposed Roadmap refers to technology and health sectors, but not to food security. This poses the question of how to address the links between energy security, food security and CRM policy. Important relevant EU policies are being developed and the proposed CRM policy should link to these. For example: - The Integrated Nutrient Management Action Plan, which aims in particular to meet the Green Deal target to reduce nutrient losses by 50%, to reduce nutrient pollution and address eutrophication, and to develop the Nutrient Circular Economy. - Revision of the Urban Wastewater Treatment Directive: the Commissions legislative proposal of 26th October 2022 aims to reduce phosphorus and nitrogen losses and to increase recycling. - Climate and air quality policies: nitrogen emissions to air (N2O, NOx, ammonia) are major greenhouse and air quality challenges (National Emissions Ceilings Directive). - Commission Communication Ensuring availability and affordability of fertilisers (see above) - CAP FaST (Farm Sustainability for Nutrients) tool - ESPP underlines the strong synergy between EU energy, food security and CRM resilience policies and reducing environmental and greenhouse impacts. Synergy is possible by improving nutrient use efficiency and increasing nutrient recycling. ESPP suggests, in parallel to defining CRM policy including Phosphate Rock (and possibly Potash), to consider an integrated policy to ensure coherence of CRM policy, agri-food policy (Common Agricultural Policy, food security), energy policy, fertiliser policy and Green Deal objectives - INMAP. This should identify critical interactions and key areas for action to improve EU resilience in sectors which link food security and agriculture, energy and CRMs. In particular, development of nutrient recycling and of nutrient use efficiency (recycling of the CRM Phosphate Rock, but also synergies with recycling of nitrogen and of other nutrients) is a win-win policy action towards all of these policy objectives. Further proposals are in our attached document.
Read full responseResponse to Amendment of the list of products and substances authorised in organic production
19 Nov 2022
ESPP (European Sustainable Phosphorus Platform) welcomes this proposed inclusion of recovered struvite and precipitated phosphates in EU organic production. This corresponds to the general principles of organic farming (2018/848 art.5(c)) the recycling of wastes and by-products of plant and animal origin as input in plant and livestock production. This will help address the phosphorus deficit in organic farming which can limit productivity and compromise the Green Deal targets for expansion of organic production (see Reimer et al. 2020 summarised in www.phosphorusplatform.eu/eNews049 ). This corresponds to the positive EGTOP Opinions 2016 (Final Report on Fertilisers II) and June 2022 (Final Report on Plant Protection (VII) and Fertilisers (V)). ESPP welcomes the wording specifying that recovered precipitated phosphates for organic production must meet the requirements laid down in Regulation (EU) 2019/1009 (EU Fertilising products Regulation FPR). This will ensure quality requirements and limits to organic carbon and contaminants. It should be clarified however: Whether or not this means that Conformity Assessment has been carried out (FPR Annex IV)? This would imply significant costs, not maybe necessary if the material is being used in a local recycling circuit or under national fertiliser rules. Whether this means meeting FPR Annex II CMC12 requirements only, or also Annex I PFC and Annex III labelling requirements? Does this wording cover also the derivates defined in FPR Annex II CMC12? To avoid ambiguity, ESPP suggests to add: Recovered struvite and RECOVERED precipitated phosphates and to retain the word struvite which is well-recognised. ESPP also suggests that the wording factory farming is unclear. Does this include livestock in stables for part of the year? Does it include intensive livestock production where the animals or birds have access to some space outside? Is there some threshold of livestock per m2 of stable or per m2 of outside area? ESPP regrets that this proposed amendment does not cover the following recycled nutrient materials (see detailed document attached) and requests an EFSA Opinion on these: Renewable calcined phosphates (cf. positive EGTOP Opinion 2016 (Final Report on Fertilisers II) Other phosphorus fertilisers recovered from ashes as defined in FPR CMC 13 Potassium fertilisers recovered from municipal waste incineration ashes Recovered elemental sulphur Bio-sourced adsorbents used to treat wastewaters Phosphorus-rich pyrolysis and gasification materials (inc. biochars) Algae and algae products grown to treat wastewater Vivianite Recovered nitrogen from off-gases. ESPP questions the current wording of Annex II of Regulation 2021/1165 which states: Fertilisers, soil conditioners and nutrients(1) listed in this Annex may be used in organic production, provided that they are compliant with - the relevant Union AND national legislations on fertilising products . This suggests that a material may only be used if it is authorised under BOTH national AND EU fertilising products regulations. We assume that this is not what is intended, and that in fact materials may be used if: - respecting EU Fertilising Products Regulation 2019/1009 - OR respecting relevant NATIONAL fertilising products regulation - OR if they are used under national waste or equivalent regulation (e.g. farmyard manure) - OR possibly two or three of the above. In the case of EU 2019/1009 or national fertilisers regulations, it should also be clarified whether compliant with, here, means having obtained certification by a Notified Body (or equivalent process under national regulation) or whether it means is conform to the criteria of the regulation (self-declaration). This is significant, because the certification process can represent a significant cost, so could be an obstacle to nutrient recycling in Organic Production.
Read full responseESPP demands broader nutrient recycling in EU fertilizer rules
24 Oct 2022
Message — ESPP requests including materials like composts and precipitated phosphates in the regulation. They propose replacing restrictive mixing and packaging rules with anti-palatability additives.123
Why — Broadening the rules would expand the market for phosphorus recycling technologies.4
Impact — Environmental targets are undermined because restrictive rules prevent the use of recycled nutrients.5
Phosphorus platform calls for nutrient recycling in circularity framework
2 Jun 2022
Topic — The European Commission is revising its framework for monitoring progress toward circularity.
Message — ESPP proposes including indicators for nutrient recycling, water reuse rates, and critical raw materials. They argue food waste monitoring should track nutrient content rather than just total tonnage. Additionally, the framework should measure contaminants that obstruct recycling, such as pharmaceuticals and PFAS.123
Why — New indicators would raise visibility for sustainable phosphorus and benefit recycling technologies.45
Impact — Traditional mineral fertiliser manufacturers face increased competition from recycled secondary nutrient sources.6
European Phosphorus Platform urges recycling focus in nutrient plan
21 Apr 2022
Message — The plan should prioritize nutrient recovery and recycling while promoting sustainable diets. The EU must reduce its dependency on imported phosphate rock and gas. New fiscal tools should monetize the environmental costs of nutrient consumption.12
Why — Proposed measures would expand the commercial market for recycled nutrient products.3
Impact — Global raw material exporters would face declining demand for phosphate rock imports.4
Response to Recommendation for strengthened actions against antimicrobial resistance
23 Mar 2022
ESPP (European Sustainable Phosphorus Platform) supports action to address inappropriate use of antibiotics and underlines that contamination of manure and sewage by pharmaceuticals and by ARG (antibiotic resistance genes) is a potential obstacle to recycling of nutrients and return of organic carbon to soil.
Antibiotics, antibiotic resistant micro-organisms and antibiotic resistance genes (ARG) are significantly present in livestock manures, because of use of antibiotics, and also in municipal sewage.
This is a potential obstacle to the nutrient Circular Economy and to the return to soil of organic carbon in manure and sewage sludge.
Scientific studies show that recycling of manure or sewage sludges to land can increase levels of antimicrobial resistance (AMR aka. antibacterial resistance ABR) in soil and in soil organisms, and if manure is applied to soil during crop growth then also in some plants (e.g. during lettuce growth, Zhang 2019 https://doi.org/10.1016/j.envint.2019.104912 ). However, scientific consensus seems to be that soils can naturally adapt, because soil organisms naturally release antibiotics, so that AMR appearing after sewage sludge application seems to be only temporary (Malmö workshop on pharmaceuticals in sewage sludge, 2016, www.phosphorusplatform.eu/Scope123 and refs below).
Manure application has been shown to increase diversity and abundance of indicators of AMR (ARGs and MGEs mobile genetic elements) in soils, with persistence varying from a few days to months (Lima 2020 http://dx.doi.org/10.3390/vetsci7030110). Persistence in soil following manure application varies with type of ARG and environmental conditions, with in some cases recovery only after more than a month or more (Macedo 2020 https://doi.org/10.1016/j.scitotenv.2020.139563).
Despite variable persistence of ARGs following use of treated sewage for fertigation, impact on soil ARG abundance has been found to be negligible (Kampouris 2021 https://doi.org/10.1016/j.watres.2021.116818).
However, the widespread detection of ARG in manure and sewage sludge, possible with today’s analytical methods, leads to negative perceptions of regulators, stakeholders and consumers, which pose obstacles to recycling of the nutrients and organic carbon in these streams irrespective of risk.
The EU’s AMR policy should include:
• As first priority: actions to avoid inappropriate use of antibiotics and in particular to minimise use in livestock.
• Threshold limits for antibiotic release from point sources such as hospitals and relevant livestock production (see Uluseker 2021 https://doi.org/10.3389/fmicb.2021.717809).
• Develop where possible new types of antibiotics which are degradable in sewage treatment systems and/or in anaerobic digesters (widely used to treat manure).
• Harmonised measurement and reporting, to improve data and develop robust risk assessments on AMR in agricultural recycling of manures and sewage biosolids, including persistence of AMR after application, effects on soil organisms and risk of transfer to crops (see Scope123 above).
• Actions to develop, assess and implement technologies to better degrade and remove pharmaceuticals in sewage and manure treatment systems, including composting, anaerobic digestion or a combination of these.
See joint position on the need for research into organic contaminants in sewage biosolids and manure (EEB European Environment Bureau, Growing Media Europe, Eureau, ECN, EBA, ECOFI, ESPP 2017 https://www.phosphorusplatform.eu/images/download/Joint-position-need-research-organic-contaminants-6_10_17.pdf). Significant EU-funded R&D is underway on AMR (e.g. https://repares.vscht.cz/) and this should be continued and extended concerning AMR in manure and sewage sludge and the nutrient Circular Economy.
Please also find a short list of data references in our attached document
Read full responseResponse to Soil Health Law – protecting, sustainably managing and restoring EU soils
15 Mar 2022
ESPP (European Sustainable Phosphorus Platform) supports the need for an EU Soil Health Directive, to address soil deterioration and loss, including nutrient pollution. As indicated in the proposed roadmap document, this should take into account the current exceedance of planetary boundaries for phosphorus and nitrogen, and the Green Deal target to reduce nutrient losses by at least 50% whilst maintaining soil fertility.
ESPP notes that climate change will accentuate pressures on soil health, in particular increasing soil erosion. Combined with increased mineralisation in soil, this is expected to increase phosphorus losses from soil and reduce plant-available phosphorus in soil. See overview and supporting science in www.phosphorusplatform.eu/Scope137
Nutrient recycling offers significant potential to support soil health, by return of organic carbon and nutrients to soil, in particular in digestates, composts and organic fertilisers. At present this is hindered by failure to progress towards inclusion of appropriate animal by-products (in particular manure) into the CMC criteria of the EU Fertilising Products Regulation (implementation and/or definition of ABP End-Points for CMCs for compost, digestate, CMC10, biochars …). Also, the revision of the EU Sewage Sludge Directive should enable return of nutrients and organic carbon to soils whilst ensuring strict criteria for limiting contaminants and applying nutrients according to crop needs – as should manure spreading limitations under the Nitrates Directive and via the Common Agricultural Policy.
ESPP underlines that soil health is key to achieving the EU’s water policy objectives (Good Quality Status under the EU Water Framework Directive) by limiting nutrient loss and soil erosion, and so eutrophication.
Soil health is closely linked to, and should be taken into account in, EU chemicals policies, by risk reduction measures or bans of chemicals susceptible to contaminate soil, in particular PFAS/PFOS, mercury and other remanent industrial or consumer chemicals susceptible to reach soil via air or water, including pharmaceuticals, veterinary pharmaceuticals and agro-chemicals. Continuing research is also needed into analysis of, risk assessment and prevention of micro-plastics.
ESPP considers that a Soil Health Directive is important to ensure fair competition within Europe: companies may otherwise face differing costs between Member States with differing constraints on land take or on pollutant emission limitation, farmers may otherwise face differing land use and nutrient stewardship requirements. The Directive should also ensure comparable constraints, including level cost playing field, for imported products, in order to avoid “export” outside the EU of soil degradation related to EU consumption of food, animal feed or consumer products.
Read full responseResponse to Technical amendments to the Fertilising Products Regulation
8 Mar 2022
ESPP (European Sustainable Phosphorus Platform) welcomes the proposed technical amendment, in particular the inclusion of certain post-processing treatments for digestates CMC4 and CMC5 (solid-liquid separation, dewatering, ammonia recovery).
It is ESPP’s understanding that where raw digestate (“as is”) is used locally on fields the CE-Mark will generally not be relevant. However, where digestate is be placed on the market as a fertilising product, it will generally undergo post-processing.
The proposed amendment to cover post-processing of digestate is therefore important because, as indicated by the European Commission 12/10/2021, in response to a question from ESPP, under the current wording of CMCs 3, 4 and 5: “… post processing is not allowed under the current rules in CMCs 3-5. The additives referred to, for instance, in point 1 in CMC 5 do not cover post-processing additives either.”
ESPP considers positively that the three post-processing treatments included in the proposed amendment are the most widely used and significant for placing digestate on the market as a fertilising product.
We also welcome [in 3a-(b)] the proposed acceptance of additives necessary for solid liquid separation, such as polymers or coagulants.
Various mechanical post-processing of digestate (fractions), such as drying (low or ambient temperature, solar), compacting, pelletising or granulation, removal of fibres … are not cited in the proposed amendment. These are standard fertilising product conditioning processes and should be authorised for composts and digestates. ESPP requests that the eligibility of these processes be clarified in the European Commission’s “Frequently Answered Questions” (FAQ).
Addition of a chemical to adjust the pH of digestate is (to ESPP’s understanding) considered to be a combination of two CMCs (digestate, pH additive), that is the chemical itself must be CMC (e.g. CMC1). ESPP suggests that this should also be explicitly clarified in the FAQ
Non-mechanical post-processing of digestate, such as ion removal by precipitation, ion exchange, adsorption, plasma treatment, electrostatic separation … are NOT cited in the proposed amendment, and (to our understanding) digestate (fractions) after such chemical processing, will therefore continue to be excluded from use in CE-fertilisers. ESPP suggests that this should be addressed for the specific case where phosphate salts are precipitated from liquid fraction of digestate. These salts are eligible for use in CE-fertilisers (subject to achieving CMC12 criteria) but the currently proposed amendment wording would exclude the remaining digestate. ESPP suggests that, to ensure coherence, the amendment wording should be modified to cover the digestate remaining after precipitated phosphate salt recovery, by modifying 3a-(b) as follows: “all or part of the soluble ammonium AND/OR PHOSPHATE has been removed to recover NITROGEN AND/OR PHOSPHORUS, without the intention to otherwise modify the digestate …”
ESPP notes that the recovered nitrogen products (resulting from the ammonia removal cited in the proposed amendment [3a-(b)]) are expected to be covered by the proposed new CMC15 subject to purity and other requirements.
ESPP notes that post-processing of composts CMC3 is are NOT covered by the proposed amendment and that post-processed composts will be excluded from CE-fertilisers. ESPP has received no information from compost operators to indicate that such processes could be relevant for placing composts on the market. However, our comment above concerning conditioning processes (drying, compacting, pelletising, granulation) also applies to compost (clarification needed in FAQ).
ESPP is also favourable to the proposed amendment points concerning magnesia and REACH and concerning PCB limits, because these ensure coherence with other EU regulatory texts.
ESPP has no opinion on the proposed amendments concerning nitrification inhibitors, polymers, biostimulants.
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
22 Feb 2022
ESPP (European Sustainable Phosphorus Platform) supports the need to improve waste prevention and separate collection. In particular, separate collection of (non-avoidable) food waste and organics is important (including from caterers, restaurants), in order to enable recycling of phosphorus, other nutrients and organic carbon, by e.g. composting, anaerobic digestion and valorisation of digestate and/or nutrient recovery.
Legally binding targets for waste prevention, separative collection and reuse/recycling should be introduced, applicable to local authorities responsible for waste management. A legally binding maximum % organics in the residual municipal solid waste stream would be an effective way to ensure separation of valorisable organics and food waste as well as inciting waste prevention.
The legal definitions and status of separately collected food waste, catering waste and green waste should be clarified (inc. for “biowaste”) to avoid obstacles to recycling and to valorisation of recovered nutrients in e.g. fertilisers, animal feed or other applications.
The current WFD definition of “bio-waste” (art. 3.4) is: “biodegradable garden and park waste, food and kitchen waste from households, restaurants, caterers and retail premises and comparable waste from food processing plants”.
ESPP suggests to add organic wastes from animal feed processing plants.
ESPP underlines the need for clear EU Guidance on what is and is not “bio-waste”. We note that the two links to Guidance (“General Guidance” and “Bio-waste Guidelines” on the Commission’s web page are currently ‘down’. (links on this page https://ec.europa.eu/environment/topics/waste-and-recycling/biodegradable-waste_frIn particular, Guidance is needed on the interpretation of “comparable” and on the inclusion or not of materials such as flotation sludges from food or animal feed processing plants.
This Guidance is important because the term “bio-waste” is used in the Fertilising Products Regulation 2009/1009 to define which materials can be taken in to anaerobic digestion (biogas) or compost processes to produce CE-fertilisers.
ESPP underlines the significance of avoiding food waste and recycling unavoidable food waste for stewardship of the EU Critical Raw Material “phosphate rock” and for climate change:
- global food waste is estimated to contribute 8% of anthropogenic greenhouse emissions www.phosphorusplatform.eu/eNews052
- Papangelou et al. estimated c. 130 tP/y/million people lost in food waste in Brussels = c. 60 000 tP/y for the EU27 www.phosphorusplatform.eu/eNews047
- Nestlé and WRAP UK estimate that phosphorus in food waste represents 120 days of nutrition P requirements www.phosphorusplatform.eu.eNews036
- If the phosphorus footprint (used in upstream production) of food waste is considered, then losses due to food waste are even more significant: Li et al. estimated the P-footprint of food waste in China as 16% of fertiliser use www.phosphorusplatform.eu/eNews040
Read full responseResponse to Agronomic efficiency and safety criteria for by-products in EU fertilising products
13 Jan 2022
ESPP (European Sustainable Phosphorus Platform) thanks the European Commission, DG GROW and JRC, for these well prepared and constructive proposals.
We welcome the recognition, in these proposals, of the importance of authorising the continuation of use in EU fertilising products of quality by-products which are widely used today in the fertilisers industry across Europe, because this is important for the Circular Economy.
We welcome the CMC15 proposal to widen beyond by-products (CMC11) to include certain recovered inorganic materials. In particular, we welcome that, to our understanding, CMC15 (2b) will enable inclusion in EU-fertilisers of recovered nitrogen salts from off-gases, such as ammonium sulphate stripped and recovered from biogas digestates and from certain other processes.
We also welcome that, to our understanding, CMC15 (2a) will enable inclusion of e.g. struvite recovered from treatment of discharge water from phosphogypsum waste stacks.
We note however that neither CMC11 nor CMC15 cover organic by-products Some organic by-products are covered under existing CMCs (CMC2 = mechanically processed plant materials, CMCS 3-5 = composts and digestates, CMC6 = certain listed food industry by-products). Others are not, and are currently excluded from use in EU fertilising products, such as from the pulp & paper industry, biofuels processing, etc.
ESPP fully supports the principle (already applied in the now-adopted “STRUBIAS” criteria, CMCs 12-14), that where by-products or secondary materials used in EU fertilising products are liable to contain specific contaminants not limited in the relevant PFC criteria, these should be limited in the CMC criteria. This is important to fertilising product safety and to ensure consumer and farmer confidence. We support the proposed provision that verification of specific contaminants should not be required if absence or very low levels follow “certainly and uncontestably” from the manufacturing process and input materials.
As an overall principle, we suggest that limits for such CMC-specific contaminants should be defined at the level of the CMC material, not at the level of the final fertilising product (PFC), in order to avoid “dilution” of contaminants, and to avoid the introduction of undesirable contaminants into the fertiliser production chain. Exceptions could be made for contaminants which are also micro-nutrients (copper, zinc, selenium …) but only in the specific case of the CMC material being used in a fertilising product specifically intended to provide the micronutrient in question.
Please find in the attached pdf our detailed comments on the texts and wording.
Read full responseResponse to High purity materials in EU fertilising products
13 Jan 2022
ESPP (European Sustainable Phosphorus Platform) thanks the European Commission, DG GROW and JRC, for these well prepared and constructive proposals.
We welcome the recognition, in these proposals, of the importance of authorising the continuation of use in EU fertilising products of quality by-products which are widely used today in the fertilisers industry across Europe, because this is important for the Circular Economy.
We welcome the CMC15 proposal to widen beyond by-products (CMC11) to include certain recovered inorganic materials. In particular, we welcome that, to our understanding, CMC15 (2b) will enable inclusion in EU-fertilisers of recovered nitrogen salts from off-gases, such as ammonium sulphate stripped and recovered from biogas digestates and from certain other processes.
We also welcome that, to our understanding, CMC15 (2a) will enable inclusion of e.g. struvite recovered from treatment of discharge water from phosphogypsum waste stacks.
We note however that neither CMC11 nor CMC15 cover organic by-products Some organic by-products are covered under existing CMCs (CMC2 = mechanically processed plant materials, CMCS 3-5 = composts and digestates, CMC6 = certain listed food industry by-products). Others are not, and are currently excluded from use in EU fertilising products, such as from the pulp & paper industry, biofuels processing, etc.
ESPP fully supports the principle (already applied in the now-adopted “STRUBIAS” criteria, CMCs 12-14), that where by-products or secondary materials used in EU fertilising products are liable to contain specific contaminants not limited in the relevant PFC criteria, these should be limited in the CMC criteria. This is important to fertilising product safety and to ensure consumer and farmer confidence. We support the proposed provision that verification of specific contaminants should not be required if absence or very low levels follow “certainly and uncontestably” from the manufacturing process and input materials.
As an overall principle, we suggest that limits for such CMC-specific contaminants should be defined at the level of the CMC material, not at the level of the final fertilising product (PFC), in order to avoid “dilution” of contaminants, and to avoid the introduction of undesirable contaminants into the fertiliser production chain. Exceptions could be made for contaminants which are also micro-nutrients (copper, zinc, selenium …) but only in the specific case of the CMC material being used in a fertilising product specifically intended to provide the micronutrient in question.
Please find in the attached pdf our detailled comments on the texts and wording.
Read full responseResponse to European Bioeconomy Policy: Stocktaking and future developments
3 Aug 2021
ESPP welcomes the aim of development of bio-economy policy in line with the Green Deal objectives.
Phosphorus is critical for the Bioeconomy and is recognised on the EU Critical Raw Materials list (phosphate rock and phosphorus – P4).
We welcome that “nutrient overload in soil and water” is specifically cited in the Roadmap aims: this is coherent with the Green Deal Farm to Fork and Biodiversity Strategy target on nutrient loss reduction.
We also welcome the inclusion of nutrient recycling in the 2018 Communication (COM(2018)673) as important for future-proof food and farming systems, and the inclusion in the objectives of the update of the Bioeconomy Strategy (SWD(2018)431) of addressing planetary boundaries, in particular balanced nutrient cycles.
Need for regulatory and economic support policy
ESPP notes that economic sustainability of the bioeconomy will require regulation (e.g. phosphorus recovery obligation from sewage sludge now in place in Germany and Switzerland) or economic support (fiscal and market tools). In particular, because the bioeconomy is creative of local jobs, transfer of taxes and contributions from jobs (social contributions, VAT) to ecotaxes on resources and on nutrient emissions should be engaged.
(developed in attached pdf)
Synergy of nutrient recycling and nutrient supply
The Bioeconomy Strategy needs to consider nutrients both for their recycling potential and for nutrient supply. Development of production of bioresources, terrestrial or aquatic, will not be possible without nutrient supply. Nutrient recycling is therefore essential to support the bioeconomy, including recovery of nutrients in bioresources processing (e.g. recovery of phosphorus in biofuel production) and use of secondary resources to feed bioresource production (e.g. use of wastewater, secondary heat and offgas CO2 to feed algae or biomass production). This should be included in the EU Integrated Nutrient Management Action Plan currently under development.
(developed in attached pdf)
Roadmap text comments
(developed in attached pdf)
Read full responseResponse to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals
29 May 2021
ESPP welcomes the objectives of revising REACH towards Green Deal ambitions but regrets that the Circular Economy is not addressed. In particular, the application of REACH art. 2(7) “recovered” substances needs to be clarified.
This article is important to facilitate recycling, because it exempts from REACH registration substances “which are recovered” in the EU if “the substance that results from the recovery process is the same as the substance that has been registered”. Recovery often takes place in small, distributed sites owned by organisations not accustomed to chemical regulations (e.g. local authorities for sewage works) so that REACH Registration of each producer and site would be a significant obstacle to recycling, both in terms of cost (registration fee) and of administrative burden.
However, the exoneration from Registration means that there is currently no obligation to share costs for the REACH dossier preparation, management and updates, leading to difficulties in ensuring dossier updates for some recovered substances, and free-riders if one recovery operator funds the dossier and update but others do not.
ESPP suggests that the Roadmap should aim to facilitate circularity under REACH:
• clarify the definition of a “recovered” substance under art 2(7)d to ensure that different routes for recycling are clearly covered. Some clarification is currently provided in the ECHA Guidance “in order to benefit from the exemption in Article 2(7)(d) of REACH, it is sufficient that a registration was filed for the substance by any registrant. This registrant does not have to be part of the supply chain leading to the waste generation". Clarification in the REACH regulation would avoid legal uncertainty for operators.
• specify that the obligations for data sharing and cost sharing applicable to REACH registration also apply to producers of “recovered” substances under art 2(7)d. In order to enable implementation and enforcement of this, a system of declaration for all producers of recovered substances could be established. This would also facilitate compliance of all producers with the requirements contained in Article 2(7)(d)(ii).
Read full responseResponse to Agriculture - List of products and substances authorised in organic production
19 Apr 2021
ESPP (European Sustainable Phosphorus Platform) welcomes the inclusion of a number of secondary nutrient sources in the updated annex, in particular source-separated household organic waste, biogas digestate, some animal by-products, non-factory farming manures …
ESPP underlines that Regulation 2018/848 art.5(c) specifies as a “general principle” of Organic Farming “the recycling of wastes and by-products of plant and animal origin as input in plant and livestock production”.
We note that studies (references in attachment) show that Organic farms often have negative balances for phosphorus and potassium, especially in specialist arable Organic farms (without livestock), or rely on manure imports to balance nutrients. Farms which rely largely on BNF (biological nitrogen fixation) have more negative P and K balances. 14% of soils across a sample of Organic farms in Europe showed soil phosphorus below agronomic optimal levels, which will reduce crop production and soil fertility. Organic farms often also have negative sulphur balances, which will inhibit BNF and deteriorate P and K use efficiency.
We suggest that the principle of nutrient recycling from wastes in Organic Farming should be more widely implemented for recycled nutrients, especially phosphorus, to prevent phosphorus deficits from handicapping Organic Farming in Europe, and preventing the realisation of the Farm-to-Fork target of 25% Organic Farming.
Further recycled nutrient materials should be assessed for future addition to the Organic Farming Regulation list of input materials, coherent with Organic Farming principles, quality, safety and consumer confidence
Specifically concerning “struvite” and “calcined phosphates”: ESPP regrets that these are not included in this update of the Organic Farming Regulation annex, in that the EGTOP positive opinion on inclusion of these fertilisers (recovered from municipal waste water) dates from 2/2/2016 and the condition of validation as EU fertilisers is now technically finalised (STRUBIAS annexes of the new EU Fertilising Products Regulation 2019/1009).
We request that the precise criteria for inclusion of these two materials be finalised already now, so that they can be added into the Organic Farming Regulation as soon as the STRUBIAS annexes are formally integrated into 2019/1009.
We also suggest that the inclusion of these two materials from sources other than municipal waste water be considered, in particular from food processing, dairy processing, abattoir wastes (subject to Animal By-Product safety requirements) and from manure (not from factory farming, see comments below).
Please see attached pdf document for further comments on:
- biochars,
- animal by-products Cat3,
- EU-wide definition of "factory farming",
- bio-stimulants,
- molasses and vinasse,
- phosphoric acid.
Read full responseResponse to Precipitated phosphate salts and derivates in EU fertilising products
11 Feb 2021
ESPP (European Sustainable Phosphorus Platform) welcomes the proposed ‘STRUBIAS’ criteria, for the three categories open to consultation. The adoption of these criteria and integration into the EU Fertilising Products Regulation (FPR) is important for the nutrient Circular Economy and for the roll-out of nutrient recycling technologies.
The criteria proposed have been discussed in detail through the JRC STRUBIAS process, with stakeholders, experts and Member States, and the 470-page JRC report was published In September 2019. ESPP circulated widely the JRC initial reports and documents, and the draft criteria, for comment. A wide and thorough consultation process has thus already taken place and inputs have been taken into account. The proposed criteria correspond to the consensus conclusions of this inclusive and thorough consultation process.
We thank the European Commission, DG GROW and JRC, for their commitment in bringing these criteria to finalisation, in time, hopefully, for integration into the Fertilising Products Regulation (FPR) before this comes into application in 2022.
ESPP has the following comments:
- use of manure and 'derived' animal by-products (ABP) as inputs for STRUBIAS materials. This will not be possible until ABP End-Points are defined, but this process has not yet been started, despite that the necessary information is in the JRC final STRUBIAS report 2019. We do not understand why a mandate has not yet been given by DG SANTE to EFSA. This should be engaged rapidly.
- we regret that sewage sludge is excluded from biochars / pyrolysis materials. The JRC report suggests to undertake further scientific research into safety and effectiveness of such sewage sludge derived materials. We request that this be engaged.
- we propose a wording clarification for the CMC1 point 1 exclusion for recovered precipitated phosphates and ash materials. We support this in principle, but the wording requires minor adjustment. See our attached document.
Read full responseResponse to Thermal oxidation materials and derivates in EU fertilising products
11 Feb 2021
ESPP (European Sustainable Phosphorus Platform) welcomes the proposed ‘STRUBIAS’ criteria, for the three categories open to consultation. The adoption of these criteria and integration into the EU Fertilising Products Regulation (FPR) is important for the nutrient Circular Economy and for the roll-out of nutrient recycling technologies.
The criteria proposed have been discussed in detail through the JRC STRUBIAS process, with stakeholders, experts and Member States, and the 470-page JRC report was published In September 2019. ESPP circulated widely the JRC initial reports and documents, and the draft criteria, for comment. A wide and thorough consultation process has thus already taken place and inputs have been taken into account. The proposed criteria correspond to the consensus conclusions of this inclusive and thorough consultation process.
We thank the European Commission, DG GROW and JRC, for their commitment in bringing these criteria to finalisation, in time, hopefully, for integration into the Fertilising Products Regulation (FPR) before this comes into application in 2022.
ESPP has the following comments:
- use of manure and 'derived' animal by-products (ABP) as inputs for STRUBIAS materials. This will not be possible until ABP End-Points are defined, but this process has not yet been started, despite that the necessary information is in the JRC final STRUBIAS report 2019. We do not understand why a mandate has not yet been given by DG SANTE to EFSA. This should be engaged rapidly.
- we regret that sewage sludge is excluded from biochars / pyrolysis materials. The JRC report suggests to undertake further scientific research into safety and effectiveness of such sewage sludge derived materials. We request that this be engaged.
- we propose a wording clarification for the CMC1 point 1 exclusion for recovered precipitated phosphates and ash materials. We support this in principle, but the wording requires minor adjustment. See our attached document.
Read full responseResponse to Pyrolysis and gasification materials in EU fertilising products
11 Feb 2021
ESPP (European Sustainable Phosphorus Platform) welcomes the proposed ‘STRUBIAS’ criteria, for the three categories open to consultation. The adoption of these criteria and integration into the EU Fertilising Products Regulation (FPR) is important for the nutrient Circular Economy and for the roll-out of nutrient recycling technologies.
The criteria proposed have been discussed in detail through the JRC STRUBIAS process, with stakeholders, experts and Member States, and the 470-page JRC report was published In September 2019. ESPP circulated widely the JRC initial reports and documents, and the draft criteria, for comment. A wide and thorough consultation process has thus already taken place and inputs have been taken into account. The proposed criteria correspond to the consensus conclusions of this inclusive and thorough consultation process.
We thank the European Commission, DG GROW and JRC, for their commitment in bringing these criteria to finalisation, in time, hopefully, for integration into the Fertilising Products Regulation (FPR) before this comes into application in 2022.
ESPP has the following comments:
- use of manure and 'derived' animal by-products (ABP) as inputs for STRUBIAS materials. This will not be possible until ABP End-Points are defined, but this process has not yet been started, despite that the necessary information is in the JRC final STRUBIAS report 2019. We do not understand why a mandate has not yet been given by DG SANTE to EFSA. This should be engaged rapidly.
- we regret that sewage sludge is excluded from biochars / pyrolysis materials. The JRC report suggests to undertake further scientific research into safety and effectiveness of such sewage sludge derived materials. We request that this be engaged.
- we propose a wording clarification for the CMC1 point 1 exclusion for recovered precipitated phosphates and ash materials. We support this in principle, but the wording requires minor adjustment. See our attached document.
Read full responseResponse to Towards a strong and sustainable EU Algae sector
17 Jan 2021
ESPP (European Sustainable Phosphorus Platform) welcomes the proposal of coherent EU actions to develop algae production and use. However, we regret that the proposed Roadmap does not actively address the important potential for recycling of secondary nutrients and CO2 to feed algae (Circular Economy), that is combining algal production with wastewater and/or offgas cleaning.
Growth and valorisation of algae offer significant potential for efficient production of a wide range of products, including fertilisers and crop biostimulants, animal feed or aquaculture feed, and this can be combined with use of algae to treat waste streams, in particular municipal wastewater.
Algae production is already used full scale to treat municipal wastewaters. Algae can also be used to treat other wastewaters, including digestate from food waste or manure or industrial wastewaters (e.g. removal of pathogens, heavy metals, phenols, endocrine disruptors, …). Algae production can also contribute to air-cleaning and CO2 capture
Subject to appropriate attention to possible contaminants which may be transferred to the algal biomass, the algae can then be valorised to energy or in production of fertilisers, biostimulants or other products.
The regulatory obstacles and lack of clarify are particularly important for algae grown on wastewater substrates or manure (Animal By-Products = ABPs) and these need to be addressed, for example:
- Under what circumstances are algae grown in wastewater or in manure considered waste or subject to End-of-Waste or ABP End-Point requirements?
- Consequently, can algae grown in wastewaters be used as a CMC1 material in the new EU Fertilising Products Regulation?
- Are waste-grown algae excluded from Animal Feed by art 6(1) and Annex III of Regulation 767/2009?
We underline that the use of materials derived from algae grown using wastewaters in fertilising products or in animal feeds imperatively must be subject to appropriate safety requirements (contaminants, pathogens).
The proposed Roadmap recognises that algae require nutrients to grow. A US National Academy of Sciences report concluded that 1-2 million tonnes of phosphorus and 6 – 15 million tonnes of nitrogen would be needed to grow sufficient algae to produce biofuels for 5% of US fuel demand.
The proposed Roadmap recognises that algae require nutrients to grow. A US National Academy of Sciences report concluded that 1-2 million tonnes of phosphorus and 6 – 15 million tonnes of nitrogen would be needed to grow sufficient algae to produce biofuels for 5% of US fuel demand. For this reason, EU policy on algae should promote recycling of nutrients from algae processing (where nutrients are not required or not desirable in the product, e.g. biofuels) and should prioritise production of algae using either secondary nutrients (from wastewaters) or excess nutrients from eutrophic surface waters.
Please find references and proposals for actions in our PDF attachment.
The European Sustainable Phosphorus Platform (ESPP) promotes the implementation of sustainable phosphorus management in Europe, in particular phosphorus recycling. ESPP is a non-profit organisation, funded by its members. The Platform has over 40 members from a range of different industries (water and waste companies, mineral and organic fertilisers, chemicals, recycling technologies), knowledge institutes and public establishments. www.phosphorusplatform.eu
Read full responseResponse to Feed additives - revision of EU rules
30 Dec 2020
ESPP regrets that the proposed Roadmap does not address the obstacles posed to the Circular Economy by the animal feed and feed additives regulations.
Reference is twice made in the proposed Roadmap to better or more efficient “use of resources”, but no reference is made to the EU Circular Economy Action Plan, nor in any way to the circular economy or recycling
It is our understanding that any feed additive which is derived, even after intensive chemical reprocessing (e.g. incineration, chemical extraction, acid or other chemical reactions, purification …), from secondary materials derived from from manure or wastewater, is apparently excluded from use in production of animal feeds (see detail in attached document).
ESPP fully supports strong safety requirements to prevent any risk of pathogen contamination in the animal feed chain. However, for certain routes of chemical recovery of nutrients, there are clearly no such risks (see detail in attached document).
ESPP suggests that a revision of the Feed Additives Regulation 1831/2003 should proactively address the circular economy, and consequently Annex III of 767/2002 should also be modified.
We note that this would be coherent with the objective stated in the Roadmap to address legal clarity and consistency.
Read full responseResponse to New EU Soil Strategy - healthy soil for a healthy life
8 Dec 2020
ESPP (European Sustainable Phosphorus Platform) welcomes the proposal to develop a new EU Soil Strategy, because of the importance of soil to food production, climate and biodiversity, and because of the need for comprehensive and coherent EU policy to protect land and soil.
Phosphorus, and other plant nutrients, are critical to soil quality and fertility. At the same time, soil quality (biological, physical and chemical aspects) is critical to nutrient function in soils, and so to limiting nutrient losses and ensuring soil fertility for food production.
ESPP supports the Roadmap objectives of healthy and sustainable food systems. This must include ensuring a fair income for farmers, including rewarding farmers who ensure stewardship of land and soil. The CAP is probably the EU policy with the most impact on soil quality. Better monitoring of nutrient flows and stocks is essential to improving soil fertility whilst reducing nutrient losses (Farm-to-Fork objective to reduce nutrient losses by 50% by 2030) and the proposed CAP FaST tool is strategic for achieving this.
We support the emphasis on increasing soil organic carbon proposed in the Roadmap, both for climate objectives, and because soil organic matter is important for nutrient stewardship, soil fertility and crop resilience to weather conditions. The return to soil of organic carbon in secondary materials (manure, digestate, sewage biosolids, other organic wastes and by-products) should be supported, where recycling at a higher level in the waste hierarchy is not possible, whilst ensuring safety.
Problematic contaminants in organic wastes should be addressed at source where feasible, in particular by restriction of industrial chemicals found as contaminants in sewage biosolids (e.g. PFAS, persistent plastic additives …) and by strong limitation of veterinary pharmaceuticals in livestock management (and so in manure).
The objectives of nutrient and organic carbon recycling to soil, with safety guarantees, should be embedded into EU water policy (EU Water Framework Directive, Urban Waste Water Treatment Directive, Nitrates Directive).
EU regulation should actively facilitate nutrient and organic carbon recycling in products with recognised quality, safety and agronomic performance. This is already positively engaged for some organic materials in the new EU Fertilising Products Regulation, and this work should be extended. However, ESPP regrets the absence of progress on Animal By-Products in this context. Dialogue should also be engaged on wider use of recycled nutrient and organic carbon materials in Organic Agriculture, in coherence with the different principles of Organic Farming.
Manure, digestates, sewage sludge and fertilisers should be recognised as major sources of organic carbon and nutrients to soil, and not only as sources of “diffuse soil contamination”, as currently worded in the Roadmap.
The European Sustainable Phosphorus Platform (ESPP) promotes the implementation of sustainable phosphorus management in Europe, in particular phosphorus recycling. ESPP is a non-profit organisation, funded by its members bringing together companies, knowledge institutes and public organisations, in sectors including chemicals, fertilisers, water and waste management and recycling technologies. ESPP acts through stakeholder and inter-sectoral industry dialogue, networking, information dissemination and elaboration of joint proposals to policy makers.
Read full responseResponse to Industrial pollution - revision of the European Pollutant Release and Transfer Register
18 Oct 2020
ESPP (European Sustainable Phosphorus Platform) considers that the E PRTR is an important and effective tool for ensuring public access and transparency of environmental data.
ESPP welcomes the Roadmap proposal to improve the contribution of E PRTR to Circular Economy objectives by including data on resource consumption. We would suggest to also include data on resource recycling with the objective of moving towards an “E SRTRR” Substance Release Transfer and Recycling Register.
ESPP regrets that at present large poultry, pig and fish farm installations but not cattle farms are covered, and suggests to add cattle production (LSU equivalent to the current E PRTR 750 sows threshold).
ESPP welcomes the Roadmap proposal to widen the list pollutants to include emerging pollutants. In particular, we underline the need to monitor and to inform the public concerning PFAS/PFOS (perfluoroalkyl chemicals), following the new EFSA safety limit (Opinion 9 July 2020), pharmaceuticals (human and veterinary) and microplastics.
A mechanism should be established to ensure that the E PRTR list is automatically updated to reflect updates to the Water Framework Directive Priority Substances List (2013/39/EU) which includes substances not in E PRTR: PFOS and its derivatives, a number of pharmaceuticals, brominated flame retardant HBCDD
The European Sustainable Phosphorus Platform (ESPP) promotes the implementation of sustainable phosphorus management in Europe, in particular phosphorus recycling. ESPP is a non-profit organisation, funded by its members. The Platform has over 40 members from a range of different industries (water and waste companies, mineral and organic fertilisers, chemicals, recycling technologies), knowledge institutes and public establishments. www.phosphorusplatform.eu Email info@phosphorusplatform.eu
Read full responseResponse to Revision of the Urban Wastewater Treatment Directive
8 Sept 2020
ESPP (European Sustainable Phosphorus Platform) welcomes the evaluation of the Urban Waste Water Treatment Directive (UWWTD) and the importance indicated for sewage sludge, considering both treatment / decontamination and “subsequent use as a fertiliser”.
The proposed revision of the UWWTD is intrinsically linked to the Sewage Sludge Directive, for which the evaluation roadmap was submitted to public comment until 25th August 2020, and the two consultation and evaluation processes should input into one another.
As specified in the proposed Roadmap, the UWWTD revision should specifically consider “extended producer responsibility”, in particular for contaminants of emerging concern (industrial chemicals, pharmaceuticals, micro-plastics).
ESPP welcomes the aim (in key problems to address) to embed the UWWTD in the clean and circular economy (sludge management, nutrient recovery) and the reference to the Circular Economy Action Plan. In particular, the evaluation should ensure coherence with the Integrated Nutrient Management Action Plan (INMAP) proposed in the new EU Circular Economy Action Plan. The EU Chemicals Strategy for Sustainability (Toxic-free EU Environment) should also be taken into account.
We suggest that to emphasise that “sludge be used in such a way that account is taken of the nutrient requirements”, as proposed in the roadmap for the Sewage Sludge Directive. Sewage sludge contains valuable crop nutrients, in particular phosphorus, but over- or mis-application of nutrients is not effective recycling. The contribution of sludge use to soil carbon should also be considered.
Under contaminants of emerging concern (CEC), ESPP underlines the problem of certain industrial chemicals, in particular perfluorinated chemicals (PFOS, PFOA), identified by many stakeholders and scientists as particularly problematic. The UK UKWIR CIP2 studies, for example, identified perfluorinated chemicals and fluoranthene, brominated flame retardants, cypermethrin and TBT as priority industrial contaminants (see https://ukwir.org/the-national-chemicalinvestigations-programme-2015-2020-volume-3-wastewater-treatmenttechnology-trials ) The evaluation should assess how industrial and consumer chemicals can be addressed at source by appropriate restrictions or bans.
ESPP also welcomes the recognition under problem definition that eutrophication remains an issue to be addressed in much of the EU. ESPP welcomes the identification of storm overflows, agglomerations < 2 000 p.e. and autonomous wastewater treatment (septic tanks) as issues to be addressed: inadequate treatment of each of these three is currently a significant local contributor to eutrophication and to local surface water quality failures in some places.
Finally, ESPP welcomes the recognition that the UWWTD has been effective in reducing pollution to the environment and in improving water quality, so making an important contribution to environmental protection, to quality of life (clean bathing waters, countryside and leisure activities) with strong economic benefits (reduced drinking water treatment costs, tourism) as well as European world leadership in water treatment know-how and technologies.
Please note that ESPP requests to be consulted in the stakeholder consultations planned to take forward both for this UWWTD evaluation and for the Sludge Directive (recent evaluation Roadmap consultation).
Read full responseResponse to Evaluation of the Sewage Sludge Directive 86/278/EEC
25 Aug 2020
ESPP (European Sustainable Phosphorus Platform) welcomes the evaluation of the Sewage Sludge Directive (SSD) and the priority indicated of “contributing to resource efficiency (through the recovery of useful nutrients such as phosphorus)” in the context of the Green Deal and the Circular Economy Action Plan.
We welcome the emphasis that “sludge be used in such a way that account is taken of the nutrient requirements”. Sewage sludge contains valuable crop nutrients, in particular phosphorus, but over- or mis-application of nutrients is not effective recycling. The contribution of sludge use to soil carbon should also be considered.
ESPP welcomes the recognition of concerns about emerging contaminants, in particular “organic chemicals such as pharmaceuticals, PAH and PFAS, cosmetics and microplastics”. Although the SSD addresses sludge use, the evaluation should also consider reduction at source of such contaminants where possible: regulatory bans on problematic industrial or consumer chemicals such as perfluorinated chemicals PFOS/PFOA or non-biodegradable cosmetics ingredients, possible reduction actions or improvements in sewage treatment to reduce contaminants which cannot simply be prohibited (pharmaceuticals, microplastics from abrasion …). The UK UKWIR CIP2 studies, for example, identified perfluorinated chemicals and fluoranthene, brominated flame retardants, cypermethrin and TBT as priority industrial contaminants.
The “Purpose and Scope” should assess what policies, financial tools and technologies have been effective or offer potential to reduce, at source or in sewage treatment, levels of emerging contaminants in sewage sludge.
The evaluation of the SSD should consider three objectives (1) developing circularity of secondary resources in sewage sludge, and (2) optimising nutrient recycling whilst ensuring safety (3) improving economic feasibility of resource recovery and recycling.
ESPP suggests that stakeholder and public consultations proposed should be concomitant with those for the Urban Waste Water Treatment Directive, for which the inception impact assessment of the evaluation is also currently out for public comment.
In order to ensure regulatory coherence, the evaluation should assess whether revision of the SSD is pertinent or whether these objectives can be better achieved by:
- End-of-Waste policies, including progressive inclusion of sewage-derived materials into the new EU Fertilising Products Regulation for nutrient products, and further specific EU End-of-Waste product approaches for other sewage-derived materials. These policies should enable adaptation to new technologies, products and markets, in order to facilitate the Circular Economy.
- further integrating sewage sludge management into water policy, including defining both recycling objectives and safety criteria, in particular in the Water Framework Directive and the Urban Waste Water Treatment Directive. This should be coherent with the EU Chemicals Strategy for Sustainability (Toxic-free EU Environment).
The SSD evaluation should ensure coherence with the Integrated Nutrient Management Action Plan (INMAP) proposed in the new EU Circular Economy Action Plan.
Under “European Added Value”, it should be assessed whether the SSD is coherent with objectives or actions in Member States or regions towards recycling of nutrients in sewage (e.g. German phosphorus recovery ordonnance, Sweden phosphorus recycling policy, HELCOM sewage sludge handling Recommendation …) and how the SSD can facilitate further such actions in other Member States.
We request that the reference to the Ramboll et al 2019 study on digestate and compost be removed. The conclusions of this study and the “Risk Reduction” measures proposed are not justified by the study content and a request has been made that the Commission accompany the publication of the study with a statement to this effect, or that the Commission submit the study to SCHER.
Read full responseResponse to EU rules on industrial emissions - revision
20 Apr 2020
ESPP supports the suggested widening of the IED scope to cover intensive cattle farms and aquaculture, in coherence with the inclusion today of large pig and poultry farms.
ESPP supports that the IED process should better take into account EU Circular Economy objectives. BREFS should better integrate recycling, both use of secondary raw materials in production, recovery of materials in processes, and recycling of waste or by-product streams, as well as reducing raw materials consumption. This should particularly target EU Critical Raw Materials.
Resource efficiency and recycling, including nutrients, should be integrated into the Key Environmental Indicators (KEIs) for BAT
As a member of the IED Forum, we see as challenges to ensure update of the BAT BREF documents to take into account technical progress. The BREF process is slow and demanding of human resources. Perhaps the formal BAT requirements could be separated from the examples, emerging processes and explanative texts. These have an important role in promoting progress and innovation, so need to be flexible and up-to-date. Possibly the current formal adoption process could be maintained for the BREF specifications, but the examples etc could be moved to a separate non-regulatory document, with status similar to a Commission Guidance, enabling more flexible and frequent update.
The role of the horizontal BREFs (including the proposal for a horizontal “Resource Efficiency” BREF) needs to be clarified. Perhaps these could have a role for application to concerned installations not covered by current BREF categories? Or they could be reorientated as guidance/innovation documents and made more flexible for permanent update.
The European Sustainable Phosphorus Platform (ESPP) promotes the implementation of sustainable phosphorus management in Europe, in particular phosphorus recycling. ESPP is a non-profit organisation, funded by its members. The Platform has over 40 members from a range of different industries (water and waste companies, mineral and organic fertilisers, chemicals, recycling technologies), knowledge institutes and public establishments. www.phosphorusplatform.eu Email info@phosphorusplatform.eu
Read full responseResponse to Farm to Fork Strategy
15 Mar 2020
ESPP welcomes the objective of a holistic EU approach to “farm to fork”, taking into account sustainable development, climate change, farmers’ incomes through to dietary choices and human health impacts.
We welcome that one of the four proposed strategy objectives is “the shift towards healthy, sustainable diets”. This will require concerted and proactive EU action on food policy. The EU will need to influence dietary choice not only by “promotion” (including education and information) but also by effective policies (with Member States) possibly including fiscal policies and regulatory market intervention for certain types of food product. Links should be made to Horizon Europe, in particular to the “Soil Health and Food” mission
We welcome the statement that the Farm to Fork Strategy should “feed into the European Commission’s circular economy objectives”. Links should be made to the Commission’s “Circular Economy Strategy”, in particular to the new EU Fertilising Products Regulation 2019/1009. Links should be made to the Horizon Europe stated objective of “A comprehensive EU policy to balance nutrient cycles …”
One of the four defined objectives is to “Reduce food loss and waste”. Food waste policy should take into account the nutrient value of food waste losses, which is more significant for environmental and economic impact than “tonnes of waste”.
ESPP welcomes that proposal “providing better food information such as on where the food comes from and its nutritional value.” Phosphorus levels in food products are extremely important for kidney disease patients (CKD). The EU should assess whether consumer information on phosphorus levels in certain food products is appropriate, and if so whether this should be ‘front of pack’ or rather via an online bar-code linked data base available for concerned publics.
ESPP welcomes the link made in the proposed Roadmap to the CAP. We underline the importance of the proposed FaST (Farm Sustainability Tool for Nutrients), included in the Commission’s CAP revision proposals..
The Roadmap proposes to develop measures “to significantly reduce the use and risk of chemical pesticides, as well as the use of fertilisers and antibiotics”. Chemical herbicides should also be targeted (not only pesticides). For “fertilisers”, a reduction in total use at the EU level is probably not compatible with maintaining levels of food production and quality. The objective should be an optimised use of fertilisers, including both synthetic mineral fertilisers and organic fertilising materials (manure, biosolids, recycled nutrient products …) with reduced losses to air and water, and increased circularity. Implementation of the new EU Fertilising Products Regulation should be referred as a key tool to increase nutrient recycling and ensure quality and safety of fertilising products. Similarly, animal feed nutrition should continue to be optimised.
We welcome the mention of Aquaculture. The Advisory Council on Aquaculture should include in its remit addressing aquaculture feed nutrition efficiency and sustainability, and nutrient recovery / loss mitigation, and should be widened to address all non-meat/dairy protein production routes: insects, algae, bacteria …
Read full responseResponse to A new Circular Economy Action Plan
19 Jan 2020
ESPP www.phosphorusplatform.eu welcomes the new Commission’s commitment to accelerate the development of the Circular Economy, as a core aspect of EU industry and environment policies.
In addition to the industrial target sectors cited in the Roadmap, ESPP welcomes the continuing engagement towards “closing loops for biological materials”.
Recycling of nutrients, organic carbon and other materials in biological sources, such as animal by-products, food waste, sewage sludge, manure and agriculture and forestry by-products offers important potential for reducing EU dependency on the Critical Raw Material phosphate rock, for returning organic carbon, nitrogen and other nutrients to soil, and for creating jobs and added value, especially in agriculture and rural communities. The new EU Fertilising Products Regulation is a significant step forward, but further actions are now needed, in particular on animal by-products, on circularity in agriculture (CAP) and to address at source pollutants contaminating biological material streams (PFAS, microplastics, pharmaceuticals …).
ESPP therefore regrets that the proposed Roadmap does not identify links with the EU bioeconomy strategy, CAP, soil and water policies.
The Roadmap identifies the problem that secondary raw materials are currently often less price competitive, but regrets the absence of actions to address this. The decentralised, small scale structure of recovery and recycling and their employment-intensive nature are positive (job creation, rural communities), but have price impacts. Measures should be considered to balance this, such as legal recycling obligations, recycled content quotas in products and transfer of social contributions from employment to taxation of energy and resource consumption. We suggest that the Roadmap includes engaging discussions with Member States to define and implement such measures, either at the EU level or in concerted fiscal actions by Member States (EU Semester).
Read full responseResponse to European Partnership for a Circular bio-based Europe
27 Aug 2019
The European Sustainable Phosphorus Platform (ESPP) supports the proposal for a Horizon 2020 ‘Partnership on Circular bio-based Europe’, and welcomes the approach of grouping the two linked objectives of circularity and bio-based economy. We support the recognition that the bio-economy is based on not only agri-forest bio-resources, but also organic wastes and by-products.
Nutrients are a key link between circularity and bio-based economy, both as a valuable product to be recovered and recycled from bio-wastes, biorefineries and in processing of bio-materials, but also as an input essential to “feed” sustainable production of bio-resources. Sustainable biomass production and waste and water management require limiting nutrient losses (eutrophication, atmospheric ammonia …). Phosphate fertilisers are the principal use of the Critical Raw Material ‘Phosphate Rock’. For these reasons, EU water policy and Critical Raw Materials policy, should be cited (as well as climate change, already cited). Links to EU chemical safety and sustainable chemicals policies should also be cited.
ESPP has contacts with several actions of the BBI-JI, and considers that this has facilitated industry engagement with R&I towards implementation. Projects have shown a pragmatic approach to integrating bio-sourced, recycled nutrients into industrial fertiliser production and markets. It is positive that a high proportion of funding is going to industry, inc. SMEs. We agree with the Interim Evaluation conclusion that BBI-JI has created a stimulating R&I environment.
ESPP welcomes the widening of the proposed ‘Partnership’ approach to include stakeholders and public bodies. We recommend identifying the role of networks in this approach, to facilitate dialogue and information exchange and experience transfer, with a significant aspect being the capacity to ensure long-term cooperation beyond the time-scale of R&D programmes.
The administrative processes for engagement of stakeholders, networks and public organisations in ‘Partnerships’ will need to be flexible, in that their operation is different from that of research institutes or companies. In particular, conditions need to be defined whereby their participation costs ( ‘out of pocket’ such as travel, salaried staff and volunteer time) can be compensated, without this becoming a distorting financial resource (funding dependence).
Under “A. problem the initiative aims to tackle” we suggest to add the following challenges:
Societal prices and externalities: processing of bio-sourced and recycled materials will often remain more expensive than fossil or extractive-resource based, often because sustainable bio-production and recycling are employment-intensive. Economic models should propose routes to address this.
Social acceptance must be ensured. The public, food industries, supermarkets or media, can be negative towards bio-sourced or recycled products, considered not as “clean” or “safe” as virgin, new materials. This needs to be addressed by both science (data on contaminants, risk assessments, LCA) and by developing positive image actions. This requires dialogue with the food industry and supermarkets.
Production for the bio-economy must not impede sustainable food production to feed the world (and must not be perceived as doing so). Links between the food industry and the bio-economy should be developed (food waste recycling, nutrient recycling, food sustainability criteria, on-farm food and bio-resource production synergies …)
Better knowledge of flows of nutrients must be developed, with reliable and agreed indicators, to ensure sustainable “feeding” of bio-resource production and to identify nutrient recycling potential
Partnership actions should propose, where appropriate, routes to integrate circularity and bio-economy into other EU strategies and policies
Please see further comments on the roadmap text in the attached document.
Read full responseResponse to EU farm policy - Evaluation of its impact on sustainable management of the soil
27 Aug 2019
The European Sustainable Phosphorus Platform (ESPP) supports the proposal to evaluate the impact of EU farm policy on soil management, because soil resources, both quantity (limitation of soil erosion) and quality (soil fertility potential and contamination avoidance) are critical to ensuring future food production and rural prosperity.
We suggest, in $A. Context, para. 2, after “soil erosion, compaction, organic matter, biodiversity, pollution or salinization” to add “nutrients (macro- and micro-nutrients)”.
For plants, the soil offers physical support and acts as a store for water and nutrients. Nutrients are thus fundamental to crop, forestry and grassland productivity and to soil health. Their supply by and via the soil is critical and complimentary to essential supply via mineral and organic fertilising materials (fertilising products, manures, crop residues …). Both nutrient content and nutrient form in soils impact immediate fertiliser application requirements, longer term crop fertility (quantitative yield, plant health and resilience, crop quality) and fertiliser needs, soil metabolism and health, possible nutrient losses to water and final food quality (e.g. taste, micronutrients in food products, nutrition).
This significance is recognised in the current proposal for a FaST (Farm nutrient Sustainability Tool) in the CAP revision.
We suggest adding to the list of stakeholder organisations consulted (under $B – Consultation):
- Water management / water quality organisations
- Food health and nutrition experts (crop quality, micronutrients)
- Fertilising products supply industries
It would be appropriate to link to the proposed Horizon Europe “Soil, food and health” Mission.
Read full responseResponse to Evaluation of the Industrial Emissions Directive
4 Dec 2018
The IED is a key piece of EU legislation to ensure environmental quality in industry, in intensive agriculture and in food & beverage processing, in order to preserve the environment, to ensure a level playing field and to push forward environmental progress.
The priority must be to continue improving implementation, with BAT BREF documents which are pragmatically applicable by permitting authorities.
Concerning the scope of the evaluation, this should assess how to better take into account in the IED scope and process, and in BAT BREFs, EU policies on the Circular Economy, resource efficiency and on Critical Raw Materials. These are not clearly considered in the current IED, which was developed in particular from the IPPC (pollution/emissions) and waste legislation. These themes need to be integrated into IED monitoring and reporting processes.
As a recent member of the IED Forum, we see as challenges to ensure update of the BAT BREF documents to take into account technical progress. There is currently a backlog of BREFs meriting update, and the BREF process is slow and demanding of human resources. It is unrealistic to expect NGOs and difficult for many industries to participate in five day meetings, especially in Seville. The proposed evaluation should assess how the BREF process can be streamlined to continue to ensure stakeholder participation and consultation, maybe by separating the processes for the formal BAT recommendations from the process for the examples, emerging processes and explanative texts. These informal texts have an important role in promoting progress and innovation, but for this purpose need to be flexible and up-to-date.
The role of the horizontal BREFs/documents (waste treatment, energy, cooling systems, economics/costs, proposal for a horizontal “Resource Efficiency” BAT BREF) needs to be clarified. Are these useful for implementation by permitting authorities? If yes, then these should be completed and updated. If not, then they should be reorientated as guidance/innovation documents and made more flexible for permanent update.
Concerning stakeholders to be consulted for the evaluation, this should include NGOs and smaller industry organisations which have not engaged with the IED/BAT process, in order to identify obstacles to this engagement, and to propose alternative modes of engagement in the BREF process adapted to their potential input, capacities and resources.
The European Sustainable Phosphorus Platform (ESPP) promotes the implementation of sustainable phosphorus management in Europe, in particular phosphorus recycling. ESPP is a non-profit organisation, funded by its members. The Platform has over 40 members from a range of different industries (water and waste companies, mineral and organic fertilisers, chemicals, recycling technologies), knowledge institutes and public establishments. www.phosphorusplatform.eu Email info@phosphorusplatform.eu
Read full responseResponse to Environmental Implementation Review 2019: common implementation challenges across the EU
26 Nov 2018
We welcome the continuing emphasis placed on environmental implementation by the Commission. European Commission monitoring, incitement and enforcement actions have, in particular, played a key role in moving towards better protection and improved quality of Europe’s surface and ground waters. European action has been essential to addressing from eutrophication, especially through implementation of the Urban Waste Water Treatment Directive and the Nitrates Directive – although in both cases, further action is needed. European implementation actions will also be critical in achieving the Water Framework Directive objectives.
We support the statements in the proposed review Roadmap that weak environmental implementation generates high societal costs and creates an uneven playing field for sustainable business.
We welcome the proposed approach of the Environmental Implementation Review (EIR): country reports and local examples, identification of important implementation gaps, assessment of causes of these failures, sharing of best practices, dialogue on possible solutions.
The importance of interactions between EU environmental policies and other policies and sectors is recognised in the proposed Roadmap. This is very important, and the review should aim to identify aspects of other EU policies which directly or indirectly counter environmental implementation.
In particular the review should assess the impacts of the Common Agricultural Policy (CAP): agriculture is mentioned in the proposed Roadmap and in the 2017 EIR communication COM(2017)63, but not the CAP. Whereas, the CAP has a major impact on the EU’s environment, and on environmental policy implementation and compliance: e.g. achievement of water policy objectives, as cited above; air quality objectives: National Emission Ceilings Directive.
We welcome that EU tax/fiscal policies, which also significantly impact environmental implementation, were discussed in the EIR communication COM(2017)63. They are not mentioned in the proposed Roadmap but should be added as a key factor to address.
We welcome the widening of scope proposed to cover climate change, industrial emissions and chemicals. We suggest that:
- chemicals should include pharmaceuticals and microplastics, both of which are of significant concern as regards water policy and circular economy (contaminants posing obstacles to organics and nutrient recycling)
- waste should be widened to consider the Circular Economy package, resources and Critical Raw Materials.
The European Sustainable Phosphorus Platform (ESPP) promotes the implementation of sustainable phosphorus management in Europe, in particular phosphorus recycling. ESPP is a non-profit organisation, funded by its members. The Platform has over 40 members from a range of different industries (water and waste companies, mineral and organic fertilisers, chemicals, recycling technologies), knowledge institutes and public establishments. www.phosphorusplatform.eu Email info@phosphorusplatform.eu
Read full responseResponse to Evaluation of the impact of the CAP on water
26 Nov 2018
Agriculture has major impacts on water, including input of nutrients (phosphorus, nitrogen) to surface and ground waters. Phosphorus-related eutrophication is one of the main causes for surface water failures to achieve Water Quality Framework quality status objectives. These nutrient losses are not only a major problem for water, but also represent a loss of value for farmers (costs of mineral fertilisers or organic amendment application) and often reflect soil loss.
The Commission’s proposal for the CAP after 2020 include the “Farm Sustainability Tool for Nutrients” (presented now as ‘FaST’). This is a potentially important tool to improve nutrient management, to facilitate access to information for farmers, as well as improving reporting. The proposed evaluation should identify existing similar tools and systems (e.g. balanced fertilisation requirements), assess their effectiveness in reducing impacts on water, and derive possible recommendations for the future FaST tool.
The overall objective of the evaluation should be to consider whether the different mechanisms of the current CAP (and those proposed for the 2020 CAP) are compatible with achievement of the Water Framework Directive quality objectives, and if not to make proposals to improve the compatibility. This should also take into account other sustainability objectives, such as Critical Raw Materials, Circular Economy, greenhouse emissions and National Emissions Ceilings Directive, soil conservation …
The proposed Roadmap states that this evaluation will contribute Data collection and methodology: The proposed evaluation should consider the Commission “Nitrates Directive implementation reports” and other relevant documentation.
Consultation of citizens and stakeholders: Stakeholders consulted should include water basin management organisations, both at the national/regional and at the local levels. Furthermore, proactive communications effort should be made to encourage local water basin management committee members to respond to the internet consultation.
Coherence: in order to ensure coherence of evaluation, not only the CAP itself should be evaluated, but also other related policies, for example the specific “agriculture” R&D funding under Horizon 2020 and the Rural Development “Operational Groups”.
The European Sustainable Phosphorus Platform (ESPP) promotes the implementation of sustainable phosphorus management in Europe, in particular phosphorus recycling. ESPP is a non-profit organisation, funded by its members. The Platform has over 40 members from a range of different industries (water and waste companies, mineral and organic fertilisers, chemicals, recycling technologies), knowledge institutes and public establishments. www.phosphorusplatform.eu Email info@phosphorusplatform.eu
Read full responseResponse to Towards an EU Product Policy Framework contributing to the Circular Economy
1 Jun 2018
ESPP (European Sustainable Phosphorus Platform) considers as positive this initiative and supports EU action in favour of the Circular Economy, for which policy at the European level is important to ensure a dynamic and operational single market and to remove barriers for recycled nutrient products, for recycling technologies and for recyclable waste/secondary raw materials.
Food and beverage and agriculture sectors:
We underline the importance of the food & beverage products (see footnote 7 of the proposed Roadmap). As discussed in our supporting document, an initiative at the EU level is necessary to engage the multinational companies concerned by products in these sectors (agriculture, crop trade, food & beverage, supermarkets) and we suggest that this initiative be led by DG SANTE.
Agricultural and rural development policies:
ESPP considers that the Circular Economy in food & beverage products should be better supported through CAP/RDF (EU agriculture and rural development funding), including e.g. processing and recycling of manure and agricultural crop by-products or food processing by-products, nutrient balances and use of recycled nutrient products.
Fiscal policies:
ESPP emphasises that to be effective, EU Circular Economy product policy must include tax shift, from tax burden on jobs to environmental and resource taxation, to enable a non-marginal move from linear to circular economy. Recycling and resource conservation is often more employment-intensive than linear consumption of raw materials, so that the job potential of the Circular Economy will largely only become economically viable with tax shift.
Listed initiatives:
We suggest to add the following to the list of initiatives cited in $C of the Roadmap:
- EU Fertilisers Regulation revision
- EU Critical Raw Materials policies
- European Semester objectives to increase proportion of revenue from environmental taxes
- CAP (Common Agricultural Policy) and RDF (Rural Development Funding)
- assessment of water policies : potential to incite nutrient recycling and not only nutrient removal
- Paris commitments: 4/1000 organic carbon in soil (recycling organic carbon materials), reducing diffuse GHG emissions from agriculture and turning agriculture into a CO2 sink instead of being a CO2 emitter
- pharmaceuticals strategy – reducing contaminants in sewage
- SANTE – food labelling, diet, food waste
- EU funding of nutrient recycling R&D under Horizon 2020/HorizonsEurope, LIFE, InterReg
- EU BioEconomy Strategy
Read full responseResponse to Update of the 2012 Bioeconomy Strategy
20 Mar 2018
ESPP suggests that the Bioeconomy strategy should more closely integrate Circular Economy policy (in particular, the Nutrient Circular Economy) and Critical Raw Materials (phosphate rock is on the EU Critical Raw Materials List). Nutrient recycling and nutrient stewardship are essential both to “feed” the bioeconomy (fertiliser nutrients are essential for biomass production) and to limit impacts from nutrient losses (eutrophication, atmospheric emissions).
Also, the roadmap should make clearer that renewable resources considered as input to the Bioeconomy should prioritise organic wastes and by-products, in order to avoid resource and land competition with food production. Reuse of organic by-products in animal feed or fertiliser (under appropriate safety requirements) or recovery of nutrients for recycling (to fertilisers, to feed biomass production, or for industrial applications) should be a core foundation of the Bioeconomy Strategy.
An important challenge in recycling and upcycling of organic wastes and by-products, which should be actively addressed in the BioEconomy Strategy, is that of contaminants and safety (pathogens, plant diseases and invasive species, organic contaminants such as pharmaceuticals or consumer chemicals). Better data, scientific understanding and risk assessment are essential. It is however equally important that the Bioeconomy Strategy engage dialogue with farmers and landowners, the food & beverage industry, retailers, consumer and environmental associations to address risks, safety and perception of contaminants and to reduce the risk of rejection of organics recycling (e.g. refusal of use of sewage or manure derived recycled nutrients in food supply chain or bio-product criteria).
We note that the revision of the EU Fertilisers Regulation (underway) is an important tool to facilitate recycling of nutrients and return of organic carbon to soil, but that issues remain to be resolved concerning organic materials and by-products in this regulatory text. The Bioeconomy Strategy should include a link to sustainable fertilization, which is key to feed biomass production.
We note that the reference to “malnutrition” should be clarified in the proposed Roadmap. A key societal challenge today in Europe and in much of the world, directly linked to resource, nutrient and land requirements for biomass production, is dietary choice, and “overnutrition” with consumption of meat, protein and calories higher than dietary requirements or health recommendations.
Read full responseResponse to Evaluation of the Urban Waste Water Treatment Directive 91/271/EEC (UWWTD)
9 Nov 2017
We consider that the UWWTD is a key piece of EU environment policy, and has largely contributed to reducing P levels in rivers and lakes, improving surface water quality, with considerable benefits for biodiversity and for users. Further work is however needed to reduce P emissions, both from municipal wastewater and from agricultural losses, because very many water bodies are still today not achieving P levels required for WFD Quality. In many ecosystems, eutrophication impacts occur even with very low P levels, accentuated by climate change and by the presence of legacy stocks of P in both soils and aquatic sediments.
We therefore consider that the UWWTD requirements should be fully maintained, and that – as at present - these should be extended and reinforced locally by catchment management plans under the WFD (Water Framework Directive) where this is necessary to achieve status objectives.
In particular, it should be clarified that “appropriate” treatment (agglomerations < 2000 p.e.) should ensure P removal in eutrophication sensitive areas, subject to catchment permitting (see below).
We note that addressing eutrophication will in many cases require further reductions in P emissions beyond current UWWTD requirements, both to reduce water-body P concentrations, and also to avoid accumulation in sediments. In order to optimize cost-effectiveness and minimize environmental impacts (energy consumption, chemicals inputs) catchment permitting or catchment level nutrient emissions trading should be implemented, subject to ensuring that quality objectives are achieved at all points in the catchment.
We support the EU Court of Auditors recommendations (special report n°2, 2015) to tighten discharge limits to take account of technological progress, and to improve cost-recovery to ensure sustainable financing of wastewater infrastructure.
Achieving lower P emissions, and P removal in smaller sewage works, will imply energy consumption, materials and chemicals, and will both increase and modify the nature of sewage biosolids (dewaterability, nutrient content, chemical content such as polymers, flocculants, reactants). This should be considered when defining P discharge consents, in particular implications of valorization of sewage biosolids (methane production, return of stabilized organic carbon to soil, nutrient recycling).
P consents for small sewage works may in some places be necessary (discharge into small, sensitive water courses) but in other cases may be disproportionately expensive (economic, energy and resource costs) and catchment nutrient permitting may be preferable.
We support the EU Court of Auditors recommendations (special report n°2, 2015) call to require appropriate valorization of sewage biosolids, including energy recovery, return of stabilized organic carbon to agricultural soils (important for soil productivity, crop drought resistance and climate resilience, and for the Paris 3/1000 soil carbon objective) and nutrient recovery and recycling (P and N). This should be included into the UWWTD and Sewage Sludge Directive objectives, and implemented through conditionality of EU subsidies (as suggested by the Court of Auditors).
We emphasise that further data collection and research is necessary into:
- P and N flows in sewage / sewage treatment / biosolids
- cost-effective and sustainable removal of P down to very low discharge limits (including reliability in varying sewage works operation conditions, storm flows) and removal of P in small sewage works, taking account impacts on biosolids production and valorisation
- levels of, risks, fate in treatment and in soils of organic contaminants in sewage biosolids valorization (pharmaceuticals, perfluoralkyl substances, household chemicals …). See the joint position between ESPP – EEB – Eureau and others attached.
- Catchment permitting / nutrient emissions trading, including both point and diffuse emissions
ESPP: www.phosphorusplatform.eu
Read full responseResponse to Strategic approach to pharmaceuticals in the environment
12 May 2017
The possible presence of pharmaceuticals in processed sewage biosolids and animal manures is a significant potential obstacle to the Circular Economy for nutrients (recycling to agriculture of phosphorus, nitrogen, other nutrients) and to the return of carbon from these sources to soil (important for productivity, climate resilience, greenhouse carbon removal).
The European Sustainable Phosphorus Platform (EU Transparency Register n° 260483415852-40) brings together companies (in the water industry, fertilisers, chemicals, recycling), regional and national authorities, knowledge institutes to promote sustainable use of phosphorus and phosphorus recycling.
Pharmaceuticals (and their breakdown products) tend to be more present in sewage works aqueous discharge than in biosolids (because they are often polarised molecules), and they can be partially removed or broken down by treatments such as composting or anaerobic digestion. Nonetheless, their presence in processed sewage biosolids and animal manures is a significant potential obstacle to the Circular Economy for nutrients (phosphorus, nitrogen, other nutrients) and to the return of carbon from these sources to soil (important for productivity, climate resilience, greenhouse carbon removal). At present there is a lack of information and of risk assessment concerning pharmaceuticals and their metabolites in these organic recycling streams and of their fate in soils, and consequently inadequate risk assessment information concerning possible impacts on soil micro-organisms (including possible antibiotic resistance), soil fauna, crops and human health (see attachment, summary of workshop “Pharmaceuticals in sewage biosolids”, Malmö, November 2016, in SCOPE Newsletter n°123 http://www.phosphorusplatform.eu/images/scope/ScopeNewsletter123.pdf submitted). This contributes to challenges to confidence (of farmer, supermarket, food industry, regulator and consumer), potentially threatening future recycling of these valuable organic secondary materials to agriculture. A better evidence base is necessary to provide that sewage biosolids and manures can be recycled safely, so ensuring the circular economy, cost and environmental benefits.
For these reasons, ESPP welcomes the roadmap proposals to:
• address pharmaceuticals not only in water, but also in the environment more generally and in particularly in soil
• fix as a priority to identify and address knowledge gaps.
ESPP further suggests to:
• include risk assessment of pharmaceuticals in use of differently treated sewage biosolids and manures in different agricultural/crop systems, development of priority pharmaceuticals lists for biosolids and manures and of practical monitoring programmes to reduce and control risk
• develop knowledge of pharmaceutical breakdown metabolites and impacts of typical pharmaceutical “cocktails”, of fate of pharmaceuticals in soil systems, and on how different sewage/manure treatments (urine/faeces separation, different sewage works configurations, anaerobic digestion processes, different composting processes) can more effectively remove pharmaceuticals and their metabolites
• specify support under Horizon 2020 and within the EU Circular Economy package the knowledge and risk assessment development above
• assess possible actions to reduce upstream pharmaceutical input to and residual presence in sewage and manures, including changes in use, separation of certain wastestreams, more degradable molecules …. (whilst as specified in the proposed roadmap, safeguarding access to effective and appropriate pharmaceutical treatments)
• organise dialogue at the EU level with farmers, the food and beverage industries, supermarkets, environment and consumer NGOs, with the objective that the risk assessments, monitoring and actions engaged should respond to their concerns about safety of recycling to agriculture of sewage biosolids and manures
Read full responseMeeting with Jyrki Katainen (Vice-President) and European Biogas Association and
16 Nov 2015 · Circular Economy