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Luftförorenings- och klimatsekretariatet

AirClim

AirClim is a joint venture between four Swedish environmental organisations with the chief purpose of promoting awareness of the problems associated with air pollution and climate change, and thus, in part as a result of public pressure, to bring about the required reduction in the emissions of air pollutants, including greenhouse gases.

Lobbying Activity

Response to Commission Directive amending Annex III of the Nitrates Directive

17 May 2024

While there may be reasonable grounds for subjecting RENURE fertilisers to different regulations than untreated manure, it is perplexing why this change is being rushed through without a proper impact assessment and before the ongoing fitness check evaluation of the Nitrates Directive is completed. Moreover, it is unclear how this change facilitates achieving the overall objectives of the Nitrates Directive. The agronomic benefits of this amendment do not appear significant enough to warrant such expedited treatment. On the other hand, the 170 kg manure threshold serves as an incentive to limit excessively high animal densities, which positively impacts other environmental objectives, such as reducing ammonia emissions. Given that several Member States will struggle to meet the ammonia emission limits set by the NEC Directive for 2030, we need more measures that contribute to reducing livestock densities rather than weakening existing regulations. The requirement in Annex C vii, which states that livestock numbers should not increase due to the application of the specified products, is insufficient. Since the proposal fails to establish a causal relationship between the number of animals and the use of recovered nutrients. AirClim recommends the Commission to withdraw the draft Act. Instead, the regulation of RENURE fertilisers should be addressed within a more comprehensive review of the EU's nutrient policy, for example included in the promised Intergreated Nurtient Management Action Plan.
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