EUROPEAN COMMISSION ENTERPRISE AND INDUSTRY DIRECTORATE-GENERAL WORKING GROUP 2 - NUTRIENT CONTENT, PRODUCT COMPOSITION, AGRONOMIC EFFICACY

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1 EUROPEAN COMMISSION ENTERPRISE AND INDUSTRY DIRECTORATE-GENERAL Chemicals, metals, mechanical, electrical and construction industries; Raw materials Chemicals - Classification & Labelling, Specific Products, Competitiveness Brussels, 30 January 2012 WORKING GROUP 2 - NUTRIENT CONTENT, PRODUCT COMPOSITION, AGRONOMIC EFFICACY Subject: Draft Conclusions of the 1 st Meeting on 17 th of January, 2012 Chair: Eric Liégeois (European Commission, DG Enterprise and Industry) Co-chair: Henri Bos (NL) 1. MANDATE OF WG2 The mandate of WG2 is to determine, if necessary, criteria for nutrient content, product composition, and agronomic efficacy. The mandate of WG2 was accepted without any changes. WG 2 recommended that the documents posted in the CIRCA newsgroup be correctly named and/or numbered (e.g. mention WG2 in the heading) in order to facilitate further contributions / referencing / archiving. 2. NUTRIENT CONTENT 2.1. Minimum nutrient content Minimum nutrient content criteria should be set for inorganic and organic fertilisers to guarantee efficacy of fertilisers for users and to distinguish between organic fertilisers and other products which will also fall under the revised Regulation such as soil improvers. Maximum nutrient limits should be set for organic soil improvers. The minimum nutrient content for organic fertilisers will correspond to the maximum nutrient content for organic soil improvers; A minimum content of nitrogen in fertilisers will also help to ensure the efficient and safe use of certain additives such as nitrification inhibitors. Commission européenne, B-1049 Bruxelles / Europese Commissie, B-1049 Brussel - Belgium. Telephone: (32-2) Office: BREY 11/254. Telephone: direct line (32-2) Fax: (32-2) klaus.berend@ec.europa.eu

2 Different minimum nutrient contents should be set for organic and inorganic fertilisers; differentiating also solid and fluid forms; Depending on the preferred options (i.e. option 4), it might be necessary to continue to define minimum nutrient content for specific fertiliser types (e.g. NPK fertilisers) A proposal to replace minimum nutrient content criteria by standardised amounts (per hectare) of nutrients brought to the soil was considered impractical because the future EU legislation will not cover the use phase as good agronomical practices are too dependant of the highly varying soil and climatic conditions across the EU. No minimum nutrient content criteria were deemed necessary for growing media as their primary function is not to deliver nutrients. For certain categories of liming materials (e.g. for magnesian limestone, converter lime,...), minimum nutrient content should be defined as criteria to differentiate them from other types of liming materials. WG 2 reviewed the existing minimum nutrient content values for solid inorganic fertilisers of various national legislations on fertilisers (minimum values are expressed in percentages of dry matter unless otherwise specified). DK DE IT NL PL BE* PT FR* EL FI N 2% >3 3 3 P 2 O > (apatite) K 2 O >3 3 NPK > 3 5% at 12 6 Sum content least for one nutrient 15%, min. 1% for each S CaO MgO 2 * % in product as received WG 2 also reviewed the existing minimum nutrient content values for fluid inorganic fertilisers of various national legislations on fertilisers, which revealed large differences between Member States: ES PL BE DK N 6% 1%(dry matter) P 2 O 5 40% 1% 3% 2% 2% 2

3 K 2 O 6% 1% 3% NPK Sum 7% 1% each CaO 5% Mg0 2% Min 10% Sum >3% 2.2. Declaration of the nutrient content of inorganic fertilisers The actual content of the nutrients N, P, K, S, Ca, Mg should be declared; Declaration in the oxide form. Optionally, in the elemental form 1 ; The nutrient content of fluid inorganic fertilisers should be expressed on the product as received; WG2 is invited to discuss the following issues for solid inorganic fertilisers: Actual values for minimum nutrient contents - based on the information available from the Member States? How should the declaration of the nutrients be expressed: on dry matter or on the product as received? Is there a need to define a minimum nutrient content as a sum of individual components for NPK? WG2 is invited to discuss the following issues for fluid inorganic fertilisers: Actual values for minimum nutrient contents - based on the information available from the Member States? Is there a need to define a minimum nutrient content as a sum of individual components for NPK? 2.3. Declaration of the nutrient content and other specific criteria for organic fertilisers The actual content of the nutrients N, P, K, S should be declared; Declaration in the oxide form. Optionally, in the elemental form; The total nitrogen content should be declared in view of the enforcement of the Nitrates Directive; The way nitrogen is released should be declared (e.g. C/N value, soil incubation test used in FR). Alternatively, a classification system for the kinetics of nitrogen release could be established (slow to rapid nitrogen release, as done in FR and PT); 1 This corresponds to the current rules for mineral fertilisers in Regulation (EC) No 2003/

4 The forms of nitrogen present in the organic fertiliser should be declared (ammonium form, nitrate, organic N); The following proposal for minimum content of nutrients in organic fertilisers was submitted as a starting point for discussion (values are expressed on dry matter). Nitrogen (N) 1.5 Phosphorous (P 2 O 5 ) 0.5 Potassium (K 2 O) 0.75 Sulphur (S) 0.3 Minimum values (% w/w) A minimum organic matter content should be defined and the real organic matter content should be declared; WG2 is invited to discuss the following issues for organic fertilisers: Actual values for minimum nutrient contents in solid and fluid organic fertilisers - based on the information available from the Member States? Is there a need to foresee a specific exemption for bio-digestates, which normally have lower nutrient content than other organic fertilisers? How should the declaration of the nutrients be expressed: on dry matter or on the product as received? Actual values for minimum content of organic matter for solid and fluid organic fertilisers based on the information available from the Member States? How should the actual content of organic matter be expressed: - on dry matter or on the product as received? 2.4. Soil improvers Soil improver category should be divided into three sub-categories: o organic soil improvers, o liming materials, o other soil improvers such as sand, clay, stone meal... Farmers need to be well informed of the characteristics of the soil improvers they use. 4

5 2.4.1 Organic Soil Improvers The following criteria should be declared for organic soil improvers: o ph ( in accordance with CR 13456) o Organic matter content ( in accordance with CR 13456) o Total nutrient content o Water-soluble nutrient content The maximum nutrient content for organic soil improvers should be the same as the minimum nutrient content for solid organic fertilisers. WG2 is invited to discuss the following issues for organic soil improvers: How should the declaration of the nutrients be expressed: on dry matter or on the product as received? Liming materials The following criteria should be declared for liming materials: o Neutralizing value o Fineness o Total nutrient content (CaO and MgO) Declaration of the actual values for the quality criteria on the product as received Other soil improvers WG2 is invited to discuss the following issues for other soil improvers: A name for this third category of soil improvers (sand, clay ): "soil conditioner"? Which criteria should be declared and how? 2.5. Growing media Criteria that should be declared for growing media: o Electrical conductivity o ph o Quantity (mass or volume) As the sources of raw materials for the manufacture of growing media are very broad, it is not possible to set minimum quality criteria. The declaration of the actual value for the criteria mentioned above will be however required. WG2 is invited to discuss the following issues for growing media: Is there a need to set additional criteria compared to those above? How should they be declared? 5

6 2.6. Bio-Stimulants Not discussed at the first meeting of WG2 3. AGRONOMIC EFFICACY CRITERIA Only initial discussions took place without firm conclusions during the first meeting of WG2; WG2 recognised that a differentiation could be made between products which are already on the market and new ones: for the latter agronomic efficacy might be less obvious; Variability of raw materials for organic fertilisers or soil improvers (e.g. compost) makes standardisation of testing difficult. WG 2 recognised that, requiring generalised agronomic efficacy testing for any new types, products or ingredients, might lead to enormous burden for both manufacturers and labs or institutes while not being proportionate; WG 2 recognised that the provisions of the future Regulation should allow all users to easily access any document demonstrating the efficacy of the product and/or justifying the declared claims. WG2 is invited to discuss the following issues with regard to agronomic efficacy:: What should be considered as a new fertiliser, or new soil improver or new growing media as compared to well-established products? What should be considered as major composition change potentially justifying testing for agronomic efficacy? What should be the reason triggering the need for testing: product claims or product ingredients? Which tests should be used? Is standardisation possible? How should efficacy for 'new' products be documented: records to be kept by manufacturers/importers or certificates from verification bodies? How can barriers to innovation be avoided? 6