EU public consultation, to 4th March, on draft modifications to the list of authorised inputs to Certified Organic Farming (EU 2021/1165) to allow use as fertiliser of “calcium phosphate” recovered from sewage sludge incineration ash, subject to conformity to the EU Fertilising Products Regulation (FPR, in effect FPR-CMC13). Recovered struvite and precipitated phosphates, from sewage and other sources, were authorised for use as fertilisers in Certified Organic Farming in 2023 (see ESPP eNews n°73), subject to complying to the FPR (in effect FPR-CMC12).
The current proposal is written as follows: “Calcium phosphate: only when derived from sewage sludge ash, only products complying with the requirements of Regulation (EU) 2019/1009”. This proposed authorisation of sewage-ash-recovered calcium phosphate is based on the EGTOP Opinion (EU Organic Farming expert group) of March 2024, see ESPP eNews n°87. ESPP notes that the wording “complying with the requirements of” the EU Fertilising Products Regulation 2019/1009 (FPR) are interpreted by the European Commission to mean “must have the CE-fertiliser mark” whereas EGTOP recommended only that the calcium phosphate should respect the FPR contaminant limits (not necessarily be CE-mark certified).
ESPP regrets that the proposed text excludes calcium phosphates recovered from other ashes, in particular from animal by-products, whereas certain animal by-products cannot be spread directly on fields and must be incinerated, so that recycling of nutrients from ash is the best option.
ESPP notes that the wording “calcium phosphate” is open to interpretation, but suggests that presumably it means any inorganic compound consisting only of calcium, phosphate, hydrogen and oxygen, e.g. monocalcium phosphate MCP, dicalcium phosphate DCP, octacalcium phosphate, amorphous calcium phosphates, hydroxyapatite, single super phosphate SSP, triple super phosphate TSP – despite these compounds having very different water solubilities.
ESPP also regrets that this proposed Regulation modification does not cover “Calcined Phosphates” from sewage, for which EGTOP gave a positive opinion in 2016, recommending authorisation for use in Organic Farming. We suggest that EGTOP should reevaluate and update this 2016 opinion on “calcined phosphates”. However, ESPP suggests that EGTOP consider authorising all ash-derived phosphates respecting the EU FPR-(CMC13 criteria, possibly subject to other specific Organic Farming criteria (such as exclusion of manure from ‘factory farming’, solubility criteria), in order to avoid the current one-by-one assessments which are slow and time-consuming.
The proposal also includes a range of other modifications to authorised inputs to Certified Organic Farming. ESPP notes in particular the authorisation of carbon dioxide, preferably as a ‘by-product’ of other processes or from renewable sources. This can be relevant for anaerobic digesters.
“Organic production – amended list of authorised products and substances”, EU public consultation, open to public input from individuals, organisations and companies, until 4th March 2025. Input = 4 000 character free text plus possibility to submit a pdf document https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14024-Organic-production-amended-list-of-authorised-products-and-substances_en