REA submits to Defra, EBA and ECN its comments on the EU Fertiliser Regs proposals
REA submitted to Defra, EBA and ECN comments on the EU Fertiliser Regs proposed safety and quality requirements on behalf of its members. You can read the comments HERE. We consulted REA's members on these proposals since June 2014.
We highlighted to Defra and the tow European Trade Bodies that the following key issues should be raised to DG ENTR very strongly:
- 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 our national regulatory controls applying to ÂwasteÂ and ÂproductÂ composts and digestates. Since we understand that EU Fertiliser Regs should normally apply only if manufacturers wish to trade fertilisers as "EC fertilisersÂ, Defra should urge the DG ENTR 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 ENTR should provide clarity with a matter of urgency on how the EU Fertiliser Regs will apply to composts and digestates produced to national regs.
- We must urge the DG ENTR to liaise with the JRC-IPTS and the DG ENV and 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 this 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 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 ENTR must also ensure they consider the CommissionÂs 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, it will completely undermine the CommissionÂs objective to move towards a circular economy.
If you wish to discuss our comments or to find out more about the fertiliser regs, please contact Kiara (firstname.lastname@example.org).
Last update: 01/09/2014
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