The European Commission JRC has circulated the pre-final STRUBIAS report, proposing EU Fertilisers Regulation criteria for phosphate salts and struvite, biochars - pyrolysis and gasification materials, and thermal oxidation materials (ashes). JRC has circulated the report to members of the official STRUBIAS Working Group and it can be consulted on the ESPP website here. It will be presented and discussed, as well as an update on the EU Fertilisers Regulation proposal, at the stakeholder meeting organised by ESPP in Brussels on 5th September. Please note that JRC will only accept comments on this report from members of the STRUBIAS Working Group (this includes: ESPP, DPP and several other ESPP members), so we invite comments to by 3rd September latest.
This “pre-final” report (450 pages …) includes report, annexes, market study and (pages 34-39) proposals for CMC requirements, labelling and conformity assessment for EU Fertiliser label eligibility of STRUBIAS materials (and for materials derived from them). The 450-page document was circulated on 13th August, and ESPP is now only starting its analysis. Many of the comments made on the “interim” and “market” reports of 2017 are taken into account and JRC has clearly done a lot of work to do this. ESPP wishes to express our recognition and appreciation of this. Many aspects of the proposed criteria for the STRUBIAS materials are considerably different from the 2017 version, taking into account comments, and in ESPP’s view greatly improved. ESPP already notes the following proposals (as we understand it so far … our analysis is still underway):
- Sewage and sewage sludge are accepted as input materials for phosphate salts and for ashes, but not for biochars;
- Raw manure is accepted as input substrate for all three STRUBIAS materials;
- For all phosphate salts and all ashes, the criteria are widened to include “derivate” materials, that is: not only direct use of e.g. struvite or ash onto fields as a fertiliser or liming material (after granulation or blending), but also use of these materials as inputs to fertiliser production processes (with chemical processing);
- This chemical processing can include reaction with any “intermediate” (as defined in REACH: any substance produced for and consumed in chemical processing to produce another substance), without any specific (additional) REACH registration requirements for these intermediate chemicals;
- Phosphate salts (e.g. struvite) precipitated from industrial wastewaters (e.g. fertiliser industry, phosphate rock processing, biofuel production…) appear to be excluded;
- No nutrient plant availability criteria are specified for any of the STRUBIAS materials – this avoids duplicating the proposed Fertiliser Regulation product function categories (PFC) criteria which define such criteria for fertilisers (or neutralising and reactivity criteria for liming materials);
- Minimum phosphorus content of phosphate salts = 16% P2O5, maximum organic carbon = 3%, minimum dry matter = 90%;
- Maximum iron + aluminium content of phosphate salts = 10% (Fe+Al);
- Cat1 Animal By-Product ash is excluded, despite being a known, effective, safe and significantly used fertiliser product;
- For most ashes, the only specific contaminant limits (beyond those applicable to all products in PFCs) are limits for chlorine, for PAH (poly aromatic hydrocarbons) and for dioxins (PCDD/F);
- Similarly, the only specific limits for pyrolysis materials are chlorine, PAHs, dioxins and PCBs;
- A PAH limit is fixed for phosphate salts precipitated from sewage;
- No minimum temperature is defined for biochar – pyrolysis – gasification processes: the H/Corg ratio < 0.7 (under specified testing conditions) is considered sufficient to show that the process ensures pyrolysis;
- All three STRUBIAS materials will be under Module D1 (Annex IV) conformity assessment procedure, that is production process quality assurance system is required, with a quality control system which is validated by a national notified body.
The above are points initially identified by ESPP. These remain to be verified and completed, for which your input is important. Overall, the report concludes that “many STRUBIAS materials provide plants with nutrients, especially P, with a similar agronomic efficiency to mined phosphate rock and processed P-fertilisers”, that they provide an “added value material” for both conventional European agriculture and organic farming, and that they offer the potential to replace 17-31% of mineral phosphate fertilisers” in Europe.
“Pre-final STRUBIAS Report. DRAFT STRUBIAS recovery rules and market study for precipitated phosphate salts & derivates, thermal oxidation materials & derivates and pyrolysis & gasification materials in view of their possible inclusion as Component Material Categories in the Revised Fertiliser Regulation”, European Commission (JRC), circulated 13th August 2018, download online at www.phosphorusplatform.eu/regulatory comments to ESPP by 3rd September 2018 and discussion at stakeholders meeting Brussels and webinar 5th September www.eventbrite.ca/e/eu-fertilisers-regulation-and-strubias-tickets-47156434164