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The European Commission Joint Research Centre (JRC) organized a Footprint Family workshop, 14-16 November 2017, Ispra (Italy), bringing together specialists from JRC and 11 invited international external experts on footprints. Footprints covered were the ecological, carbon, land, water, nitrogen, phosphorus, energy, material and biodiversity footprints. ESPP joined as expert and brought in knowledge and ideas from the phosphorus footprint perspective. The workshop aimed at creating an internationally recognized scientific panel to discuss synergies and conceptual differences between the different footprints and methods/data used, and to set the basis for footprints related to food production and consumption in the EU. Footprints are analysis and communication tools to assess the impact is of a person, product, company, sector, country in terms of resource use (depletion) and environmental pressure (pollution). The experts concluded that a combination of footprints (footprint family) would provide additional value for researchers, consumers and policymakers to work on sustainable production, consumption and waste management, with a clear link to environmental EU directives and the new UN Sustainable Development Goals. Furthermore it became clear that whereas for example the ecological, land, carbon and water footprint are well developed, for phosphorus and nitrogen there is a strong need for further development, in particular to take into account the virtual phosphorus consumption by imported products. Input on phosphorus and nitrogen footprints and their further development can be sent to

Outcomes of the finished EU research project One Planet Economy Network (OPEN) that focussed on the challenges Footprint Family as well

Running Our Phosphorus Future research project will cover the phosphorus footprint

See nitrogen footprint work in the Our Nutrient World report, prepared by the Global Partnership on Nutrient Management (GPNM) in collaboration with the International Nitrogen Initiative

“Nitrogen footprints: past, present and future” Galloway et al. 2014, IOPScience
Website Global Footprint Network

A report for the Netherlands Government assesses possibilities for recovery of nutrients (other than phosphorus and nitrogen) from waste streams. Based on criticality of mineral resources and importance for agriculture, priorities are identified as: boron, cobalt, copper, potassium, molybdenum, selenium and zinc. Waste streams considered include sewage, industrial wastes, municipal solid waste, animal by products, coal ashes and other ashes. The report recommends further research into agricultural use of sewage biosolids (after e.g. composting) but notes the need to address possible risks of organic contaminants. The following recovery routes are identified as having potential: bioleaching and phytoremediation (plant uptake of metals), polymer assisted ultrafiltration (PAUF), fly ash wasting / metal separation (FLUWA) and the Ecophos process (recovery of other nutrients in the residue after phosphorus recovery). Particular potential is noted for zinc and potassium from sewage sludge, Ecophos residues and municipal waste incineration bottom and fly ash (MWIP); copper from MWIP; boron, cobalt and selenium from coal ashes.

“Possibilities and opportunities for recovery of nutrients other than phosphorus. An exploratory research”, by Tauw for the Netherlands Ministry for Infrastructure and the Environment, 29 September 2017, project n° 1244882

The new edition number 125 of the SCOPE newsletter is now online here:

Earlier edition can be found here:

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ESPP is facilitating at ManuREsource conference (Eindhoven, NL, 27-28 November) a Round Table on the EU Nitrates Directive and manure “in a processed form".

  • This will discuss the possible process to evaluate whether some recycled manure nutrient products should be treated like mineral fertilisers under the Nitrates Directive. The EU Nitrates Committee and the European Commission are considering engaging such an evaluation, possibly looking at the agronomic behaviour, fertiliser efficiency, risk of nitrate or phosphorus losses, and also other environmental impacts such as atmospheric emissions and overall life cycle analysis. The round table will address which manure recovered products could be concerned, definitions and criteria for such products, what data is available or needed. European Commission participation is expected.
  • This round table, 11h-13h on Tuesday 28th November, will be limited to 40 participants. To participate, you must register for ManuREsource then email the organisers indicating your wish to participate in this round table.


Steve Rowe of Newtrient (see ESPP’s SCOPE Newsletter n°125) will present at ManuREsource the US dairy industry (see ). ESPP is facilitating at ManuREsource conference (Eindhoven, NL, 27-28 November) one-to-one meetings to take forward extension of this catalogue to Europe, evaluation of further treatment technologies. For this, please register for the Conference then use the ManuREsource “matchmaking” page.

ESPP - IFOAM European stakeholder meeting on Acceptance and value of recycled fertilisers in organic farming, 12th December – Brussels.


Orgnaised in collaboration with IFOAM, the International Federation of Organic Agriculture Movements.
All day meeting 12th December 2017, 9h00 - 17h30 followed by neworking drinks.

The meeting will discuss:
 - need for phosphorus inputs to organic farming
 - ecological coherence of using recycling nutrient sources in organic agriculture
 - acceptability of different secondary materials and recycled products for the organic farming movement, organic food distributors and consumers.

Proposals for speakers, input or invitees are welcome.
Posters are invited: please indicate title of your poster in your registration.
Please note that you will receive programme and venue details, later nearer the event date, directly from ESPP, not with the EventBrite registration confirmation.

Newsletter about nutrient stewardship - European Sustainable Phosphorus Platform (ESPP).

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STRUBIAS proposals for EU Fertilisers Regulation
White phosphorus (P4) added to EU Critical Raw Materials list
Swiss Mineral Recycled Fertiliser Regulation
Stakeholder meeting on EU Fertiliser Regulation
ESPP input to EU consultation on microplastics
Media and conferences
German Phosphorus Platform: new board and national conference
EEA blames big livestock farms for ammonia emission violations
ECN Biowaste in the Circular Economy conference
Circular use of by-products in the fertiliser industry
Nutrient circular economy success stories
SPA Webinar on Water Quality Trading In North America
Research and projects
RAVITA post-precipitation, phosphorus and nitrogen recovery from sewage
Low heavy metals in secondary nutrient products
Pharmaceuticals in secondary nutrient products
Adjusting pH of organic materials to improve nutrient availability
1 million US$ for marine macroalgae projects
Water2REturn: nutrient recycling from slaughterhouse wastes
Review of agronomic effects of phosphites
Review of nutrient recovery technologies from digestate
Success stories
Dutch struvite shipped to cacao plantation Dominican Republic
Parisette: sustainable public loos for Paris
Food waste to protein wins BBC food & farming award
Bioenergy wood ash recycling closes nutrient cycle
ESPP Members

ESPP has responded to the European Commission public consultation on policy options to reduce microplastics release to the environment (consultation open to 16th October 2017). ESPP notes that although current concern is principally about microplastics in surface waters and oceans, some microplastics will also be found in organic recycling streams such as sewage biosolids or compost or digestate from food waste. Possible impacts on terrestrial ecology should therefore be studied in order to avoid future obstacles to the nutrient Circular Economy. ESPP suggests to collect data on microplastics in organic recycling streams, develop monitoring methods for microplastics in organic streams and in soils, study their fate and possible impacts in soil/crop systems, investigate possibilities for removing microplastics in organic waste treatment and recycling processes, and develop risk assessments of microplastics in nutrient recycling, in particular to support the EU Fertiliser Regulation.

EU public consultation on microplastics open to 16th October 2017. ESPP input here and at

The European Commission has published an update to the EU Critical Raw Materials list, identifying “raw materials with a high supply-risk and a high economic importance to which reliable and unhindered access is a concern for European industry and value chains”. This third version of the list (first published in 2011, 2014) now lists 27 Critical Raw Materials, following a detailed assessment conducted by external consultants (TNO), Commission expertise and stakeholder consultation, and using a methodology which has been improved to take into account trade factors, different industry sector uses and substitution potential (possible nutrient recycling in the case of phosphate rock). The 2014 list included phosphate rock, representing phosphorus (in any form) essential for food production in mineral fertilisers, animal feed minerals and imported animal fodder. Phosphate rock is maintained in the 2017 list, and following input from ESPP and industry, the specific form white phosphorus (P4) is also added to the list. P4 is essential to a number of added-value chemical sectors, such as fire safety, lubricants, polymer additives, pharmaceuticals, agrochemicals, catalysts, metal processing and is produced in specific production installations. Europe’s last such installation closed in 2012 (Thermphos, NL), leaving these sectors of EU industry totally dependent on imports of P4 or P4 derivatives from Vietnam, China or Kazakhstan. ESPP welcomes the inclusion of P4 onto the Critical Raw Materials list because this will stimulate development of processes to upcycle P4 from secondary raw materials, so contributing to the Nutrient Circular Economy, creating jobs in the EU and reducing import dependency of high-value EU industry sectors. ICL, for example, is developing industrial implementation of the RECOPHOS process, tested at pilot scale in Leoben, Austria, with EU FP7 R&D funding.

COM(2017)490 “Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions on the 2017 list of Critical Raw Materials for the EU”, 13th September 2017

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

The EU-funded LIFE project ENRICH (Enhanced Nitrogen and phosphorus Recovery in the value CHain), Sept. 2017 – Feb. 2021, will design, develop and implement integrated nutrient recovery and recycling in the sewage sludge recycling train of the Murcia Este municipal sewage works, Spain (500 000 p.e.) which operates biological phosphate removal. The project will include sludge elutriation to increase availability of soluble phosphorus and so increase the proportion of total sludge phosphorus recovered by struvite precipitation. Additionally are included ion exchange with zeolites (demonstrated high affinity for ammonium) combined with hollow fibre INPI membrane contactors for the recovery of ammonium salts, promotion of digested sewage sludge as a source of nutrients and organic carbon for agriculture, and optimised mixing of struvite – ammonium salts – digested sludge to correspond to agronomic requirements. The recovered products will be tested in field trials and a replicable business model will be developed. Membership of ESPP enables ENRICH to exchange experience with other relevant projects and companies (recycling technology suppliers, organic and mineral fertiliser industries and R&D centres) and to disseminate project results widely, both in Europe and worldwide, through ESPP’s communication tools (eNews, SCOPE Newsletter, website, Twitter) and specialist networks and meetings.

ENRICH is led by Cetaqua, the Suez – Barcelona Technical University, CSIC water technology research centre. Contact

The European Network for Rural Development (ENRD) announced the launch of a new Thematic Group (TG) on ‘Sustainable management of water and soils’ within the broader multi-annual ENRD priority of ‘Supporting the transition to a green economy in rural areas’. This new TG will build upon the work carried out by the TG on Resource Efficient Rural Economy. In this TG, over the past year key rural development stakeholders actively discussed means of support for the integration of resource efficient activities in the implementation of rural development programmes, including topics such as soil, nutrients, carbon and water management (see eNews n° 11 and final TG report pending). The new TG will further investigate how to improve rural development policy implementation. It will work through 2017 and the first half of 2018 with the aim of providing specific recommendations on how Rural Development Programmes (RDPs) can best address issues related to water management, covering both its supply and quality, and soil management in agriculture as well as relevant aspects such as nutrient management plans. The new TG will bring together representatives of different stakeholder and beneficiary organisations, managing authorities and funding agencies, who will come together at regular intervals for four meetings and one final EU-level seminar. The first meeting of the group is planned for the 24th October 2017 in Brussels.

If you are interested in participating in this new TG or wish to be kept informed, please contact , or register at as soon as possible (preferably by 28th August 2017)

The JRC ‘STRUBIAS’ proposed criteria for integrating ashes (as recycled nutrient fertilisers) into the revised EU Fertiliser Regulation effectively exclude sewage sludge incineration ash. The JRC proposals target only the use of ash directly on fields (e.g. after granulation or blending) but do not cover the use of ash as an input ingredient into a chemical / industrial process. The JRC proposals therefore fix contaminant limits and nutrient plant availability requirements which are appropriate for ash being used directly on fields, but are irrelevant if the ash is being chemically processed (contaminants can be removed, nutrients transformed into different forms). However, fertilisers using ashes as a production ingredient are currently excluded from the revised Fertilisers Regulations (CMC1 excludes wastes as inputs). ESPP has therefore developed proposed criteria for “ash as a process ingredient” to propose to the EU Fertiliser Regulation process. These raise questions concerning End-of-Waste, REACH, fate of removed contaminants and intermediates (e.g. phosphoric acid is recovered from ash, then re-processed to produce fertiliser). Input and comments to these ESPP proposals are invited by email:

JRC proposed Fertiliser Regulation criteria (“nutrient recovery rules”) for struvite (and other phosphate precipitates), biochars and ash (STRUBIAS) and ESPP proposals for “ash-as-an-ingredient” in the revised EU Fertilisers Regulations, for comment

The EU Nitrates Directive specifies application limits for manure “even in a processed form” which are lower than those for mineral fertilisers. This is currently implemented differently across EU Member States, e.g. digestate or compost where manure is only a trace input can be limited as “processed manure”, or mineral fertiliser products produced from manure such as precipitated phosphates or ammonia salts from gas stripping can be subject to lower limits than similar mineral fertilisers produced from virgin materials. This can discriminate against recycled nutrient products made from or partly made from manure, by creating regulatory uncertainty, incoherence between different countries and regions or by more favourable application limits for virgin mineral fertilisers. ESPP is developing proposals to address this, whilst continuing to support the Nitrates Directives objectives of environmental protection and prevention of nutrient losses to surface and ground waters. Input to ESPP’s proposals is invited by email:

For further explanation see SCOPE Newsletter n° 100 - draft ESPP proposals concerning recycled nutrient products from manure (manure in a “processed form”) under the Nitrates Directive - for comments

Budenheim is a global specialty chemicals company with long-term phosphate expertise. The company has production sites in Budenheim (Germany), Shanghai (China), Monterrey (Mexico), Columbus (USA), La Zaida and Valencia (Spain). Building on an innovative portfolio of products and services, Budenheim offers sustainable solutions for a broad range of applications. These include the fields of nutrition, health, safety, and preservation of resources. Budenheim generated revenue of several hundred million over the past year and has a worldwide workforce of around 1.100 employees. Budenheim has joined the European Sustainable Phosphorus Platform (ESPP) because it brings together companies and stakeholders to address the need to secure phosphate resources for the future. In this community of like-minded partners, Budenheim is setting a new benchmark in raw material recycling by re-introducing phosphorus in the nutrient cycle, through the ExtraPhos® process (see below). As a member of ESPP, Budenheim acts to save global resources and to help secure the basis of our existence.

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Newsletter about nutrient stewardship - European Sustainable Phosphorus Platform (ESPP).

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Input to policy
For comment: Nitrates Directive recycled nutrient products from manure
For comment: proposals for ash-based products in the EU Fertiliser Regulation
EU consultation on micro-plastics
New ESPP members
Policy and media
Key Environmental Indicators for BAT
Sri Lanka acts for agricultural climate and phosphorus resilience
Water industry calls to address nitrate pollution and pharmaceuticals
World leaders address eutrophication at Ocean Conference
UNEP project for nutrient stewardship in Romania
Research and innovation
Networking nutrient recycling R&D
EU R&D funding opportunities
LIFE TL-Biofer nutrient recovery from sewage by microalgae
Budenheim ExtraPhos® pilot phosphorus recycling plant inaugurated
Italmatch LIFE-Trialkyl sustainable industrial phosphorus chemistry
SYSTEMIC project kick-off meeting
Ivaco piggery: biogas, fertiliser and nitrogen recovery
French phosphorus recycling conference conclusions
VTT container solution for small-scale resource and water recovery
Producing organo-mineral fertilisers from dried sewage sludge
UpLift marine nutrient recycling project wins innovation award
Phosphorus sorption by clay constituents of soils
Call for papers: phosphorus circular economy
ESPP Members

ESPP is developing an online listing of R&D projects addressing nutrient recycling, in order to facilitate exchange and knowledge transfer between projects and with potential user companies for recycling technologies and recycled nutrient products. Please consult the list currently online and send us information concerning any projects not yet included, or corrections to information included:

ESPP is also developing a listing of research and PhD students working on phosphorus sustainability, in order to facilitate networking and contacts. If you wish to be included, or have research students we should include, in this list, please send us summary details: name, email, title of phosphorus related research underway:

In order to bring together nutrient recycling R&D and user industries:

European nutrient recycling event, Basel, 18th and 19th October: programme and registration (now open)
- Wednesday 18th October: workshop on implementation of the new German and Swiss legislations requiring phosphorus recovery from sewage (in German and English)
- Thursday 19th October: meeting of nutrient recycling R&D projects (presentations, posters), technology supplier stands, R&D project consortium brokerage
+ Recycled nutrient product qualities and standards
+ Nutrient recovery in the sewage works of the future
+ Life Cycle – Analysis (LCA) and – Costing (LCC)
+ Technology transfer from municipal sewage to / from manures and other streams
+ How to move from R&D to implementation
Speakers, panellists and workshop leaders include: European Commission, EIP AGRI, Newtrient USA, Gruppo CAP Milan, Veolia, Finland Ministry of Agriculture & Fisheries, Scotland Highlands & Islands, SYSTEMIC, INCOVER, SMART-Plant, Run4Life, VCM …

Upcoming events for your agenda:

5th September, Brussels, ESPP stakeholders meeting on EU Fertilisers Regulation revision and STRUBIAS proposals (struvite, biochar, ash). Contact if not already registered.

27-28 November, Eindhoven (NL), ManuREsource 2017 - International conference on manure management and valorisation. Stakeholder discussion on processed manure in the EU Nitrates Directive. 29th November: site visits to manure processing installations

Tuesday 12 December, Brussels, ESPP General Assembly 2017, on the use of recycled nutrient products in organic farming: implementation of EU Fertilisers Regulation, assessment of recycled products under EU Organic Farming Regulation, issues with contaminants, quality, safety, image and confidence

See more events at

Newsletter about nutrient stewardship - European Sustainable Phosphorus Platform (ESPP).

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ESPP meetings
Stakeholder meeting to discuss EU Fertilisers Regulation
European Nutrient event – phosphorus recovery workshop and EU R&D meeting
New ESPP members
Vienna City
EU fertiliser criteria proposals for struvite, biochars, ashes (STRUBIAS)
EU Fertiliser Regulation proposal progressing through Parliament
Germany passes law making phosphorus recycling obligatory
Finland nutrient recycling policy and projects
EU court action against UK for sewage treatment resolved
Networks for transition to a bio-based and circular economy
North Sea Resources Roundabout
Netherlands Policy Brief: circular economy food system
Do you have a technology to remove excess phosphorus from freshwater bodies?
Phos4Life demonstrates 95% phosphorus recovery to phosphoric acid
Scenarios for sewage works energy and resource recovery
Overview of feasible technologies for phosphorus recovery in Switzerland
Nitrogen mineralisation from digestate
Yara position on the circular economy and examples of actions
Phytase safe and performance-effective in fish feed
Review of biochars as fertilisers
DVO “Phosphorus Removal” system makes fertiliser from digestate
Newtrient manure nutrient processing catalogue
IFA Nutrient Management Handbook
Cow urine finds a market
High quality fertilisation
From urine to ‘Pisner’ beer
Why organic farmers need recycled phosphorus fertilisers
GWI sludge treatment technology perspective
Correction Kjerstadius et al. LCA in ESPP eNews n°11
ESPP Members

The European Commission (JRC) has circulated first draft “nutrient recovery rules” (outline for possible CMC – Component Material Category – criteria under the revised EU Fertilisers Regulation) for struvite (widened to recovered phosphate salts), biochars and pyrolysis products and ashes - STRUBIAS. The report and annexes include a detailed assessment explaining these proposed requirements. It is open to comment and can be consulted on the ESPP website . Please note that the Commission will only accept comments submitted by members of the STRUBIAS Expert Group, which includes ESPP, DPP (German Phosphorus Platform), ECN, EBA, EFPRA, Suez, Vienna City, Italpollina and Fertilisers Europe, as well as Member State representatives. If you have comments, please therefore send to ESPP by end July (), because ESPP must submit consolidated comments in August. This will be discussed at ESPP’s stakeholder meeting with the European Commission on 5th September.

ESPP has submitted comments to the EU public consultation on pharmaceuticals in the environment. ESPP underlines the importance of developing better knowledge concerning presence of pharmaceuticals in sewage biosolids and manures, fate and impact on soils and for agriculture, and removal of pharmaceuticals in sewage and manure treatments (e.g. sewage works, anaerobic digestion, composting). Among these topics there are important questions to maintaining recycling of sewage biosolids and manures to agriculture (safety, farmer and public confidence).

The European Commission has published a proposed ‘roadmap’ for a ‘Strategic approach to pharmaceuticals in the environment’, open for public comment to 26th May 2017. The three page document specifies the relevant EU regulatory framework, in particular pharmacovigilance, and proposes to address particularly pharmaceuticals in water but also pharmaceuticals in soil as specified by pharmacovigilance. The Commission estimates that EU pharmaceutical consumption doubled from 1990 to 2000 and doubled again from 2000 to 2012. The ‘roadmap’ proposes as main objectives to identify knowledge gaps and solution to fill these, and to protect the environment whilst safeguarding access to effective and appropriate pharmaceutical treatments for humans and animals. Uncertainty about levels of pharmaceuticals in the environment and need for risk assessment are underlined. 

ESPP has submitted comments to the EU public consultation on the CAP (Common Agricultural Policy). ESPP underlines the importance of phosphorus because of global food security and the environmental challenge of eutrophication, and underlines the importance of supporting phosphorus use efficiency and recycling in agriculture, in synergy with nitrogen management and return of organic carbon to soil.  ESPP suggests to include in the CAP criteria and funding for closing nutrient cycles and for nutrient recycling, taking into account quality and safety, and including integration of nutrient management into farm, crop and food product sustainability criteria. Reference is made to the work of ENRD (European Network for Rural Development) working group on Resource Efficiency (underway) and the conclusions of the EIP-AGRI Focus Group 19 on “Recycled Nutrients” (See SCOPE Newsletter n°124).

EU public consultation on the Common Agricultural Policy, to 2nd May 2017

The European Commission has published a proposed ‘roadmap’ for a ‘Strategic approach to pharmaceuticals in the environment’, open for public comment to 26th May 2017. The three page document specifies the relevant EU regulatory framework, in particular pharmacovigilance, and proposes to address particularly pharmaceuticals in water but also pharmaceuticals in soil as specified by pharmacovigilance. The Commission estimates that EU pharmaceutical consumption doubled from 1990 to 2000 and doubled again from 2000 to 2012. The ‘roadmap’ proposes as main objectives to identify knowledge gaps and solution to fill these, and to protect the environment whilst safeguarding access to effective and appropriate pharmaceutical treatments for humans and animals. Uncertainty about levels of pharmaceuticals in the environment and need for risk assessment are underlined. ESPP is submitting comment to the EU to underline the importance of developing better knowledge concerning presence of pharmaceuticals in sewage biosolids and manures, fate and impact on soils and for agriculture, and removal of pharmaceuticals in sewage and manure treatments (e.g. sewage works, anaerobic digestion, composting), because of the importance of this question to maintaining recycling of sewage biosolids and manures to agriculture (safety, farmer and public confidence).

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