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ESPP has submitted comments to the European Commission’s draft proposals for EU criteria for recovered struvite and phosphate salts, recycling of ashes and for biochars, as CE Fertilisers under the revision of the EU Fertilisers Regulation (STRUBIAS). ESPP’s comments include input from stakeholder meeting in Brussels last week, organised by the platform, at which over 100 participants from industry, regulators, EU services, environmental and agricultural NGOs and research discussed the STRUBIAS proposals (slides).  ESPP welcomes that progress is being made towards Europe-wide authorisation of these materials as fertilisers, because this will facilitate the Nutrient Circular Economy, and open the EU market for nutrient recycling technologies. ESPP fully supports the need to ensure that all recycled fertilisers are safe for health and the environment, and offer agronomic qualities for farmers, but suggests that the criteria for recycled products (in CMCs) should not duplicate criteria already applicable to all CE Fertilisers placed on the market (PFCs). ESPP also expresses concern about unnecessary complication and multiplication of criteria which will prevent innovation and confuse implementation, for example for process/time for biochars (instead of using simple indicators of process efficiency in degrading organics, or complex mineral ratios for types of ashes which are already widely used as fertilisers such as meat and bone meal ash). ESPP expresses particular concerns about the proposed criteria for recycling ashes into industrial fertiliser production. This should be an important phosphorus recycling route, as legislation comes into place in Germany and Switzerland requiring phosphorus recycling from sewage, because 2/3 and 100% respectively of sewage sludge is incinerated in these countries, so that phosphorus recovery will be from ash. The wording currently proposed will exclude all phosphorus recycling routes from sewage sludge incineration ashes which are today operational (Zurich process via phosphoric acid production, AshDec thermal recovery, Ecophos process via hydrochloric extraction, use of ash in existing phosphate rock processing fertiliser factories) – not for any reason of safety, but because of inappropriate wording (excluding use of various chemicals in processing) and because of the mechanism of criteria application. This problem is indicative of fundamental cracks in the architecture of the Fertilisers Regulation, similar to overlooking the use of industrial by-products in mineral fertiliser production: the current wording of the Regulation will exclude most phosphate fertilisers currently sold in Europe, because sulfuric acid used in their manufacture is a by-product of oil refining. A European Parliament amendment (IMCO 281) attempts to “patch over” this emission for industrial by-products, but the same flaw poses problems for processing ashes. ESPP believes that use of ashes in fertiliser production processes, to replace imported phosphate rock, should be facilitated by applying the same criteria as for manufacture of fertilisers from virgin materials, subject to ensuring that possible incineration-generated contaminants (dioxins, PAH) are monitored in the ash and not introduced into the environment. This is an important route to accelerate the Nutrient Circular Economy and reduce EU dependency on imported phosphate rock, which is on the EU Critical Raw Materials List.

The European Commission’s STRUBIAS proposals for EU Fertiliser Regulation criteria for struvite / phosphate salts, ashes and biochars, and ESPP’s comments are available at

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