Comments needed on the EU Fertilisers regulations proposals
In our last communication on this subject we told you that a presentation was delivered at the meeting of the EU Fertiliser working group on proposed SAFETY REQUIREMENTS and QUALITY AND LABELLING REQUIREMENTS and we asked for your comments.
Although we received very little feedback, we have drafted detailed comments on the proposed requirements which will send to EBA, ECN and Defra. Please see REA’s draft detailed feedback on the proposals and let us know if you have any comments by lunch time on 27th August.
In addition to the detailed comments in the attachment we will make the following general points:
- It is extremely difficult to provide meaningful comments on the proposed safety and quality requirements when it is not clear as yet how the EU Fertiliser Regs will be implemented across Europe and what impact they will have on national regulatory controls applying to ‘waste’ and ‘product’ composts and digestates. We need to urge the DG ENT to confirm that composts and digestates produced in each country will only have to comply with the new EU fertiliser regs if they are intended to be placed in the market in other European Countries as Soil Improvers, Organics Fertilisers or Growing Media. If this is not the case, the DG ENT should provide clarity ASAP on how the EU Fertiliser Regs will apply to composts and digestates produced to national regs.
- We must urge the DG ENT to liaise with the JRC-IPTS and the DG ENV to learn about all the issues raised during the JRC EoW process (resulting in the release of the JRC End of Waste Proposals for composts and digestates). Numerous issues were raised by different stakeholders during that lengthy process and important negotiations took place. These should NOT be ignored, but should be used to inform this process.
- There needs to be more clarity on how the proposed limit levels have been derived as they are all over the place and completely inconsistent across different materials. We need to make the point that safety and quality requirements must by supported by robust scientific evidence.
- The DG ENT must also ensure they consider the Commission’s new framework to promote the circular economy and boost recycling. If the EU Regs ends up restricting the use of composted and digested materials to land, this will completely undermine the Commission’s objective to move towards a circular economy.
Become a Member!
Join the Organics Recycling Group at the Renewable Energy Association by clicking below.