The European Commission (JRC) circulated on 20th December 2017, for comment, a DRAFT “market study” (165 pages) for the ‘STRUBIAS’ recycled nutrient products (precipitated phosphate salts, ashes and processed ash products, biochars and pyrolysis products). This document provides the economic and market assessment necessary to justify future addition of these products to the (revised) EU Fertilisers Regulation annexes (as additional CMCs). This is the second part of JRC’s ‘STRUBIAS’ draft report, in complement to a first technical report (“draft recovery rules”, circulated May 2017).
The JRC draft “market study” assesses the possible sources of raw materials for nutrient recycling, STRUBIAS technologies and economic aspects (fertiliser prices, market for STRUBIAS products, economic externalities). Conclusions are that STRUBIAS recycled nutrient products could potentially substitute 25-40% of EU mineral phosphate fertiliser use. Meta-analyses conclude that struvite offers very good fertiliser effectiveness (as good as or better than mineral fertiliser) but that calcium phosphates are less effectives (total 26 studies for phosphate salts), that most ashes/ash based products are reasonable effective fertilisers (17 studies) except for steel slag based materials and non-processed sewage sludge incineration ash, and that data on biochars is inadequate.
JRC requests both detailed comments on the report text (corrections or additional information, line by line) and answers to the following questions. All input should be supported by references to publications or to provided documents:
- sale prices for STRUBIAS materials
- costs of regulatory procedures (REACH registration, national fertiliser regulation dossier, industry site authorisation to take in waste materials …)
- laboratory analysis costs (for the different product criteria, contaminants, etc. proposed in the draft “recovery rules” report)
- economic impacts of nutrient recovery to STRUBIAS products (environmental benefits, job creation, soil carbon restauration
- information on metal industry slags (contaminants, fertiliser value …)
- STRUBIAS nutrient recover routes or raw material sources which are not included in the report, where these are economically feasible and at technology readiness level 6-9
- market potential of STRUBIAS products other than as P-fertilisers (e.g. as liming materials, soil improvers)
The JRC draft STRUBIAS “market study” open for comment and the detail of JRC’s questions are available on ESPP’s website: www.phosphorusplatform.eu/regulatory (also the May 2017 JRC “draft recovery rules” report and ESPP’s detailed submitted comments 14/9/17). Comments to the draft “market study” are requested by JRC for 15th March 2018. However, comments are not accepted directly by JRC and must be transmitted via a member of the STRUBIAS working group (which includes: ESPP, DPP and several ESPP members). Please therefore transmit your comments to by 28th February latest. For all comments please specify either page number and line number of document, or number of question addressed, and provide justification (references, documents).