The ESPP stakeholder meeting, Brussels, 5th September 2018, showed a shared concern that the new EU Fertilisers Regulation be rapidly finalised. The meeting also showed general satisfaction with progress on many questions on STRUBIAS, that is the proposed EU-fertiliser criteria for recovered phosphate salts, ashes, biochars (which should be integrated into the new Fertilisers Regulation once this is adopted). Presentations by Fertilisers Europe (mineral fertilisers), ECOFI (organo-mineral fertilisers), Growing Media Europe and EFPRA (animal by products) outlined the importance of the new Fertilisers Regulation for the Circular Economy, progress made, and the need to resolve some outstanding questions (by-products, conformity assessment procedures, …). Companies and industry federations present called on ESPP to catalyse joint action to ask decision makers (European Parliament, Member States in Council) to finalise the Fertilisers Regulation, because companies need it to enable development of new recycled nutrient products and to remove obstacles to placing Circular Economy fertilising products on the market. The importance of maintaining the European Commission “delegation” to adjust Regulation annexes to take into account innovation and new data was underlined by all. Workshop discussions between stakeholders and a webinar with direct dialogue with JRC Seville underlined the considerable positive progress made in the new “Pre-Final” STRUBIAS report (online at www.phosphorusplatform.eu) and identified some significant outstanding questions: need to not exclude Cat1 Animal By-Product Ash (this would block a major phosphorus recycling route which is today operational in the UK, Portugal, The Netherlands, Switzerland …), sewage sludge as input to biochar/pyrolysis/gasification (need for data to show safe elimination of organic contaminants), absence of justification for 3% organic carbon limit for recovered phosphate salts (for coherence, refer instead to limits for “Mineral” and “Low-Carbon” fertilisers in PFCs), proposals for clarification of wording to make understanding easier for industry and users. One important question raised has much wider impacts for implementation of the new Fertilisers Regulation. JRC proposes definitions of “derivates” and “intermediates”, that is chemical processing of a recovered material to produce a fertilising product. This is essential, as was emphasised by ESPP in response to the first STRUBIAS proposals last year: safety criteria for ashes used directly on fields (which must be safe and have agronomic value, e.g. animal by-product disposal ash, poultry manure ash) are different from criteria for ash which is chemically reprocessed (contaminants removed, nutrient forms modified). JRC’s proposal is very positive, but dialogue is needed with industry and legal experts to ensure that the wording is legally unambiguous and compatible with real case examples of recycling – production processes and chemicals used.
JRC “Pre-Final” report and proposed Fertilisers Regulation criteria for recovered phosphate salts and derivates (including struvite), for thermal oxidation materials and derivates (ashes) and for pyrolysis & gasification materials (including biochars). Available for comment at www.phosphorusplatform.eu Deadline for input = final STRUBIAS working group meeting, Sevilla, 25th September. Working Group Members (only) can submit comments until 14th September. So you should ensure that you get your comments to Working Group Members (e.g. ESPP) before then (comments should specify to which line number of report they refer).
JRC webinar presentation, speakers slides and key points from STRUBIAS stakeholders workshops on phosphate salts, biochars and ash criteria: www.phosphorusplatform.eu