EBA sends its comments on organic fertilisers to the European Commission
Digestate producers ask for revised EU Fertilisers Regulation with robust and adequate requirements to boost the production of organic fertilisers and nutrient recycling.
The revision of the Fertilisers Regulation is well under way to include compost and digestate to the products that receive CE marking and thereby can be traded freely across EU borders. This not only will give organic fertilisers equal footing compared to mineral fertilisers (which are already CE marked), but it will also set reliable common standards across the EU allowing for more legal certainty for investors and enabling them to place their products in a larger market. This is particularly interesting for digestate producers operating near national borders, as well as in areas with high nutrient surpluses or a deficit of organic carbon. National legislation will be allowed to prevail in parallel to EU legislation as long as these products are destined for the domestic market; this option ensures that well-functioning national markets will not be disrupted by the revision.
EBA agrees with the general aims of the European Commission’s proposal to revise the existing regulation, particularly concerning the introduction of several organic product categories and the addition of two separate feedstock categories for digestate. Nonetheless, EBA would like to highlight two elements within the proposal which need further fine tuning: (1) add in annex II manure and crop residues to the existing category “CMC4 Energy Crops Digestate” so as to group together low risk farm-based feedstocks in one category; (2) change in annex I the nutrient and organic carbon quality requirements for organic fertilisers and soil improvers from the current fresh mass reference to dry matter, so as to take into account digestate’s current properties.
A full explanation of these points can be found in our recent comments to the European Commission. EBA will keep working on this file with the European Institutions and relevant stakeholders along 2016.