Under the Austria Presidency, a political agreement was reached on 20^th November on the EU Fertilisers Regulation (between Council = Member States, European Parliament and the European Commission), after nearly a year of ‘trilogue’. This in particular includes the question of cadmium limits, which has been the principle political blockage: the proposed initial cadmium limit of 60 mgCd/kgP₂O₅ will apply three years after entry into force of the new Regulation, and a review will then consider whether or not lower limits should be applied seven years later. Member States will be able to apply lower cadmium limits if they so wish. Final technical wording issues are expected to now be discussed before the end of the year, and the compromise proposal then will go the Member States Ambassadors and the Parliament IMCO Committee and then the Parliament Plenary and Member States Ministers for final approval. Ahead of the final trilogue meeting on 20^th November, the joint letter coordinated by ESPP supporting the Regulation adoption was signed by over 100 companies and other stakeholders, underlining the importance of the EU Fertilisers Regulation to open the European market, remove obstacles and facilitate investment in circular economy nutrient products and recycling technologies.
Fertilizers Europe welcomed the Regulation progress as “balanced”, considering the short implementation delay for the cadmium limit to be a challenge, welcoming the announced inclusion of industrial by-products and the opening of the CE mark to organic fertilisers and biostimulants, but regretting that the low minimum nutrient levels in the Regulation will not ensure quality products.
Growing Media Europe, despite supporting the objective of opening the European market, regret that the new Regulation as currently proposed will exclude nearly all growing media products because of unrealistic Conformity Assessment requirements, and underline that the new Regulation does not include quality standards on agronomic efficiency.

European Parliament press release 20/11/18 “Fertilisers/cadmium: Parliament and Council negotiators reach provisional deal” www.europarl.europa.eu/news/en/press-room/20181119IPR19407/fertilisers-cadmium-parliament-and-council-negotiators-reach-provisional-deal

Fertilizers Europe 20/11/18 “New Fertilizer Regulation – acceptable compromise but challenges remain”  www.fertilizerseurope.com/media/news/single/article/press-release-new-fertilizer-regulation-acceptable-compromise-but-challenges-remain

Growing Media Europe, 20/11/18 “New EU Fertilisers Regulation - Missed opportunity for the growing media industry?” www.growing-media.eu/single-post/2018/11/21/NEW-FERTILIZERS-REGULATION---Missed-opportunity-for-the-growing-media-industry

The 3rd European Nutrient Event (ENE3), 8 - 9 November 2018, Rimini, was jointly organised by the European Sustainable Phosphorus Platform (ESPP) and EU Horizon2020 funded SMART-Plant project. The presentations, final programme, list of key speakers of the event can be downloaded here. The event  was focussed on the theme “towards the circular economy of phosphorous (P) and other nutrients”, in Italy, the Mediterranean region and the EU, including research, development and innovation. Day 1 focussed on phosphorus and nutrient recycling in Italy and the Mediterranean region and the start up of the Italian Phosphorus Platform. It included presentations by the Italian Ministry of Environment and Protection of Land and Sea, ESPP, European Commission DG RTD, key Italian institutes, EurEau, ISLE Utilities, OSTARA, CNP Cycles, Veolia, Suez, EasyMining, Outotec, Aqualia, Assofertilizzanti, Confagricoltura, ITALPOLLINA, Lombardy Region and CAP Holding. Day 2 was focussed on new nutrient recycling R&D projects, updates on current major projects, nutrient management in Horizon Europe and the potential “Mission on Nutrients”. It included presentations by the European Commission DG RTD and EASME, and R&D project presentations by Horizon2020 funded projects Circular Agronomics, HYDROUSA, INCOVER, PeGaSus, P-Al/Fe-WTR, Run4Life, SABANA, SaltGae, SYSTEMIC, Water2Return; INTERREG funded projects BEST, No_Waste, NuReDrain, SEABASED; LIFE funded projects DOP, MEMORY, Newbies, Trialkyl, Vitisom; amd other funded projects BiofuelcellAPP, HTC, MIND-P, PARFORCE, RAVITA and ViviMag. The full report will be be published soon.

All information and outcomes of the event can be found at www.smart-plant.eu/ENE3

An overview of R&D activities by ESPP including a full description of the research projects and more information about the potential Mission on Nutrients can be found at www.phosphorusplatform.eu/R&D

The Mission on Nutrients will be further discussed during the European Sustainable Nutrient Initiative (ESNI) event, 22 January 2019, Brussels, www.biorefine.eu/european-sustainable-nutrient-initiative-esni-2019-0

The Chartered Institution of Water and Environment Management (CIWEM, United Kingdom) organised a workshop of industry, experts and regulators to input to the Institute’s Policy Position Statement on valorisation of sewage biosolids (currently being redefined), London, 3rd March 2018. ESPP was invited to give a presentation to summarise developments in Europe, and outlined the Germany and Switzerland regulations and Baltic HELCOM policies requiring phosphorus recycling from sewage, pressures on agricultural use of sewage biosolids (e.g. announced public enquiry in Sweden – ESPP eNews n°24, Global GAP food industry criteria excluding use of sewage biosolids on cropland …) and current proposals regarding sewage biosolids in the EU Fertilisers Regulation proposal (expected to be excluded from composts, digestates, biochars, but authorised for precipitated phosphate salts and ash-based recycling). Discussion in the group noted that concerns about non-biodegradable polymers used in sludge dewatering could prevent sewage biosolids application to land (e.g. new German regulations). The discussion noted that nearly half of sewage sludge biosolids in Europe are today recycled via use on lands, and similarly in the USA (60%), Australia (nearly 60%) and China (nearly 50%). The UK has one of the highest rates of use on farmland (80% of sewage biosolids), which poses operational risks (for the water industry) and cost risks (for the consumer) if this route were to be stopped. Sludge biosolids are estimated by David Tomkins (AquaEnviro) to represent around 17% of total phosphorus input to UK agriculture. Sludge biosolids recycling to land has changed considerably over recent decades, and today is mostly as stable, solid, storable composts or digestates. Participants considered that biosolids use on cropland is recognised as safe for the food chain, but that there are questions about possible impacts of organic contaminants (such as pharmaceuticals) or micro-plastics on soils and the environment, and these need to be addressed. The energy value of sewage sludge was emphasised, and the options today available for energy valorisation (high energy-efficiency incineration, hydrothermal gasification). Questions were asked about the return of carbon to agricultural soils in sludge biosolids: is this significant given the application rates (limited by crop nutrient requirements). Participants suggested that the positive values of sewage sludge as an energy, carbon and nutrient resource should be emphasised, underlining the need for appropriate valorisation routes and technologies, for different local contexts.

CIWEM Wastewater and Biosolids Panel www.ciwem.org/technical-panels/wastewater-management
ESPP presentation at CIWEM workshop www.slideshare.net/NutrientPlatform/biosolids-and-nutrient-recycling-in-europe-ciwem-biosolids-workshop-london-3-october-2018

ESPP input to the European Commission public consultation on the evaluation of the Urban Waste Water Treatment Directive (UWWT) 1991/271/EEC suggesting that the explicit, command-and-control, treatment requirements and discharge limits fixed by this Directive (and by the Nitrates Directive) should be maintained as key “backstops”  within the more holistic and ambitious Water Framework Directive. ESPP noted that the UWWT Directive has led to large improvements in sewage collection and treatment in many Member States, often following EU verification and infringement procedures. Nonetheless, phosphorus losses to waters remain a major environmental challenge across Europe, and this will be accentuated with climate change. Further action will be needed, including in some cases lower phosphorus discharge consents for sewage works. ESPP underlined the potential for flexible permitting, e.g. catchment nutrient discharge trading systems, to achieve phosphorus loss reductions cost-effectively. ESPP noted the need to clarify the UWWT Directive definitions of “agglomeration”, of “appropriate treatment” (smaller sewage works) and of “sensitive areas” (take into account climate change). ESPP also emphasised that the UWWT Directive’s scope should be widened to ensure appropriate management of sewage sludge and valorisation, including nutrient recovery or recycling and valorisation of organic carbon.

ESPP input to the EU public consultation on the “Evaluation of the Urban Waste Water Treatment Directive”, 19^th October 2018 www.phosphorusplatform.eu/regulatory
Note that a further EU consultation “Fitness Check of the Water Framework Directive and the Floods Directive” is open to 4^th March 2019 at https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2017-5128184/public-consultation_en

Some fifty companies (fertiliser industry, compost producers, water industry, recycling sector) and other stakeholders have sent a joint letter to EU decision makers underlining the importance of the proposed new EU Fertilisers Regulation for the Circular Economy and to open the European market for nutrient recycling technologies. They ask Council, Parliament and the Commission to resolve the current blockage in ‘trilogue’ and to finalise and adopt the proposed Regulation. This letter is open for further signatures, with the objective of 100 signatory companies and stakeholders. Companies and organisations wishing to join the signatories on this Joint Letter should send by 16th November company name, name and email of signatory contact and logo (all as to be included on the letter) to .

Joint letter dated 15th October 2018, with signatories to date can be found at www.phosphorusplatform.eu/regulatory  

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

Please subscribe www.phosphorusplatform.eu/Subscribe 
Link to www.phosphorusplatform.eu/eNews027
Download as PDF

Read more ...

Fertieuropa (part of the SADER Group), based in Ribadeo (Spain) and manufacturing in Bilbao, is specialised in complex fertilisers (NPK) producing different formulas to satisfy a wide variety of crops based and depending on different regional crop needs. Phosphorus is an essential part of fertiliser production, with a very important role in the future of agriculture. Consumption of phosphorus fertilisers will increase in the future to ensure food production, but mined phosphate rock resources are limited. New methods and technologies for recovery and recycling phosphorus must be developed in order to satisfy the needs of the market without damaging the environment. For Fertieuropa, participation in the European Sustainable Phosphorus Platform will provide the chance to learn about this theme, develop new ideas and participate in projects that promote the circular economy and ensure at the same time high-quality products.

Fertieuropa website www.en.fertieuropa.com/lang

One of the European Sustainable Phosphorus Platform (ESPP)’s objectives is to be a hub for networking, for exchange of information and for interaction between research and industry. This SCOPE special edition aims to identify and summarise some of the most significant, recent, scientific publications into phosphorus stewardship. The following list of papers are summarised.

Download SCOPE Newsletter # 128

Read more ...

The summary of the 3rd  European Sustainable Phosphorus Conference (ESPC3), Helsinki, 11 - 13 June 2018 is now published in ESPP SCOPE Newsletter no 127:
www.phosphorusplatform.eu/SCOPE127

The ESPC3 was co-organised by Baltic Sea Action Group (BSAG) and ESPP, bringing together nearly 300 participants from 30 countries, significantly increased from ESPC1 (Brussels 2013) and ESPC2 (Berlin 2015).

You will find the all outcomes here including summary, presentations, conclusions and posters.

The 3rd European Nutrient Event (ENE3) will take place at the ECOMONDO 2018 green technology expo, 8 - 9 November 2018, Rimini, Italy www.smart-plant.eu/ENE3 
Rimini, on the Adriatic coast, is only 1h45 train from Bologna airport and 2h10 train from Milan central.

ENE3 is Jointly organised by the European Sustainable Phosphorus Platform (ESPP) and SMART-Plant (Horizon 2020 research project).

Day 1: phosphorus and nutrient recycling in Italy and the Mediterranean region, the new Italian Phosphorus Project. Presentations by: Italian Ministry of Environment and Protection of Land and Sea, ESPP, European Commission DG Research, key Italian institutes, EurEau, ISLE Utilities, OSTARA, CNP Cycles, Veolia, Suez, EasyMining, Outotec, Aqualia, Assofertilizzanti, Confagricoltura, ITALPOLLINA, Lombardy Region, CAP Holding.

Day 2: new nutrient recycling R&D projects, updates on current major projects, nutrient management in Horizon Europe, potential “Mission on Nutrients”. Presentations by: European Commission DG RTD and EASME. Project presentations by:
H2020 funding: AgroCycle, Circular Agronomics, HYDROUSA, INCOVER, Pegasus, PFeWTR, Run4Life, SABANA, SYSTEMIC, Water2Return
INTERREG funding: BEST, No_Waste, NuReDrain, Phos4You, SEABASED
LIFE funding: DOP, Newbies, Trialkyl, Vitisom
Other: BiofuelcellAPP, HTC, MIND-P, PARFORCE, RAVITA, StraPhos, ViviMag

Register here: www.eventbrite.it/e/3rd-european-nutrient-event-registration-49310903239 (free ECOMONODO ticket included)
See updated programme here: www.smart-plant.eu/ENE3 

Nearby the interest to exchange between different R&D projects addressing nutrient recycling (H2020, BBI, LIFE+, INTERREG, national, industry funded projects), technology providers and users, the objective of the meeting is to define together the need for action to foster nutrient recycling in Europe. This will be concretised in the publication of the proceedings and conclusions of the event, including a short presentation of all participating R&D projects. With the support of DG RTD, and P-REX (FP7 project), a similar event related to phosphorus recycling was organised in March 2015 leading to publication of the proceedings and conclusions by the European Commission: http://bookshop.europa.eu/en/circular-approaches-to-phosphorus-pbKI0115204.
Outcomes the 2nd European Nutrient R&D event (Basel, Switzerland) last year can be found at: www.phosphorusplatform.eu/R&D

The launch of the Czech Republic Phosphorus Platform (CPP) was announced at the 3rd European Sustainable Phosphorus Conference (ESPC3, 11-13 June 2018, Helsinki) by Jindra Duras (Vltava River Authority) who presented a poster (online here). CPP is as an initiative five first members: Two represent River Authorities (two of the five Authorities in Czech Republic) and advocate vision to control eutrophication of freshwaters. One member is interested in progress of new technologies for waste water treatment plants (ASIO) and two are from research, relating to the circular economy. CPP is open to new members and to new ideas and topics. The Platform project aims to engage government, other river basin authorities, universities, sewage treatment operators, industry, research and NGOs to develop actions to raise awareness about phosphorus losses, mitigation and recycling.

Website of Czech Republic Phosphorus Platform www.fosforovaplatforma.cz and email address of Jindra Dura  

Poster presentation of CPP at ESPC3 www.phosphorusplatform.eu/images/Conference/ESPC3/Outcomes/ESPC3-poster-Czech-Repulic-Phosphorus-Platform.pdf

The 12^th European Waste Water Management Conference (EWWM), Manchester (AquaEnviro), addressed a range of questions about water treatment, including tomorrow’s challenges of phosphorus removal to stringent discharge consents and of emerging contaminants (pharmaceuticals, antimicrobial resistance, organic chemicals, microplastics). The conference brought together around 230 participants, mainly from water companies and technology suppliers.

Chris Thornton, European Sustainable Phosphorus Platform (ESPP), opened the conference session on phosphorus (P), by summarising the pressures to remove phosphorus from wastewater and the developments towards phosphorus recovery and recycling. He underlined opportunities including the proposed new EU Fertilisers Regulation, EU R&D funding and projects, the draft EU Water Reuse Regulation, the Water Framework Directive review, the pending EU pharmaceuticals strategy, technology transfer and flexible consent permitting. A key and pressing challenge however is the questioning of use of sewage biosolids in agriculture, both from regulators and from supermarket or food industry purchasing criteria, driven by negative perceptions around contaminants

Complete reporting of the phosphorus session can be found in ESPP eNews 26: www.phosphorusplatform.eu/eNews026

The 3rd European Nutrient Event (ENE3) will take place at the ECOMONDO 2018 green technology expo, 8 - 9 November 2018, Rimini, Italy
www.smart-plant.eu/ENE3 Rimini, on the Adriatic coast, is 1h45 train from Bologna airport and 2h10 train from Milan central.

Day1: phosphorus and nutrient recycling in Italy and the Mediterranean region, the new Italian Phosphorus Project.
Day 2: new nutrient recycling R&D projects, updates on current major projects, nutrient management in Horizon Europe, potential “Mission on Nutrients”.

Register here: www.eventbrite.it/e/3rd-european-nutrient-event-registration-49310903239 (free ECOMONODO ticket included)

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

Please subscribe www.phosphorusplatform.eu/Subscribe 
Link to www.phosphorusplatform.eu/eNews026
Download as PDF

Read more ...

The PeGaSus research project (Phosphorus efficiency in the chicken Gallus gallus and pig Sus scrofa), 2017-2020, will look at the fate of phosphorus in livestock production (in fodder, animals, microbiota, manure slurry, soil and water), model phosphorus management strategies and policy measures, carry out livestock trials of different feed strategies and alternative phosphorus feed sources and laboratory studies to characterise biological factors impacting phosphorus utilisation, assess phosphorus recycling potential (manure, bone meal), model phosphorus deficient/surplus areas within selected eutrophication Sensitive Areas, and propose policy measures to reduce phosphorus losses and increase recycling. PEGaSus is a project within the European Research Area NETwork on Sustainable Animal Production (ERA-NET SusAn), a network of 36 national research councils, national food and food safety agencies or similar, agricultural ministries and other organisations, which pool funds for transnational calls for research into sustainable animal production.

PEGaSus www.pegasus.fbn-dummerstorf.de and www.sei.org/projects-and-tools/projects/pegasus-phosphorus-management-eu SusAn (European Research Area on Sustainable Animal Production) www.era-susan.eu

The ESPP catalogue of nutrient recycling and stewardship research, development and innovation projects has been updated and can be downloaded here.

Please put your R&D project to the list, complete gaps and send corrections if necessary and send you input to

You can find complete information about the ESPP R&D activities at our R&D website section: www.phosphorusplatform.eu/R&D

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

Comments on STRUBIAS Pre-Final Report to:

The European Commission has opened a public consultation, to 19th October 2018, on how the Urban Waste Water Treatment Directive (UWWT 91/271/EEC) has affected sewage collection and treatment and contributed to the quality of water bodies and the environment. The objectives are to gather general public views and also expert opinion and detailed information, in addition to the first consultation which took place already in 2017. ESPP will respond to the consultation, based on our input to this first consultation (9/11/2017). We invite you to both respond directly online to the EU consultation and send any comments to ESPP to include in our input (comments on our 2017 input)

EU “Public consultation on the Evaluation of the Urban Waste Water Treatment Directive” open to 19th October 2018 https://ec.europa.eu/info/consultations/public-consultation-evaluation-urban-waste-water-treatment-directive_en

ESPP input to 2017 consultation on the UWWT Directive www.phosphorusplatform.eu/images/download/ESPP-input-UWWTD-consultation-SUBMITTED-TEXT%209_11_17.pdf

ESPP has commissioned an independent journalist to prepare an outline “Mission” on nutrients, to input to the EU FP9 (Horizon Europe) R&D programme preparation process. This document is based on input received from stakeholders consulted by SYSTEMIC, Biorefine, ESPP, ESPC3 and INMS (international nitrogen management system). The two page synthesis was submitted to the European Commission on 20th July 2018 in order to start discussion, and aims to provide an accessible overview, for strategic consideration in the EU programme content definition process. You are invited to already contact your National R&D Contact Points (list here: https://erc.europa.eu/national-contact-points) to ask them to support towards the EU the inclusion of nutrients in FP9 Horizon Europe. Input and comment is welcome to adjust and develop this nutrients Mission proposal.

“Proposal for a Horizon Europe mission on nutrients. Grand challenge: Healthy people and planet. Mission: To halve the nutrient footprint of food by 2030, for more resilient farms, healthier diets and a better environment” www.phosphorusplatform.eu/R&D Comments and input welcome to

European Commission proposed legislative text for FP9 Horizon Europe, 7th June 2018
https://ec.europa.eu/info/designing-next-research-and-innovation-framework-programme/what-shapes-next-framework-programme_en

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

Please subscribe www.phosphorusplatform.eu/Subscribe 
Link to www.phosphorusplatform.eu/eNews025
Download as PDF

Read more ...

On 1st June 2018, the European Commission published the legislative proposal for the Common Agricultural Policy (CAP) after 2020. Objectives are announced as fairer funding targeting (including limiting payments to 100 000 € per farm), higher environment and climate action objectives (in particular: preserving carbon rich soils such as wetlands, obligatory farm nutrient management tool, crop rotation) and tighter food safety (reducing pesticides, antibiotics). Art. 3 fixes that Member States shall establish a system of “Farm Sustainability Tool for Nutrients” and this is specified in Annex III “Rules of conditionality” (GAEC 5) – see detail below. The payment conditionality requirements (Annex III) also include (SMR 1) respect of the EU Water Framework Directive (and specifically “Article 11(3)(e) and Article 11(3)(h) as regards mandatory requirements to control diffuse sources of pollution by phosphates”) and (SMR 2) respect of the EU Nitrates Directive, as well as (GAEC 4) buffer strips (both within and outside Nitrate Directive Vulnerable Zones), tillage management (GAEC 6) and no bare soil in most sensitive periods (GAEC 7). Nutrients are also included in the CAP indicators (Annex I): “I.15 Improving water quality: Gross nutrient balance on agricultural land” and “1.16 Reducing nutrient leakage: Nitrate in ground water - Percentage of ground water stations with N concentration over 50 mg/l as per the Nitrate directive”.

In Annex III, footnote 2, it is specified that the Farm Sustainability Tool for Nutrients “shall provide at least for the following elements and functionalities”:

a) Elements

• Relevant farm information based on LPIS and IACS (Integrated Administration and Control System and Land Parcel Identification System);
• Information from the soil sampling, on an appropriate spatial and temporal scale;
• Information on relevant management practices, crop history, and yield goals;
• Indications regarding legal limits and requirements relevant to farm nutrients management;
• A complete nutrient budget.

b) Functionalities

• Automatic integration of data from various sources (LPIS and IACS, farmer-generated data, soil analyses etc.) as far as possible, to avoid data input duplication for farmers;
• Two-way communication between PA/MAs and farmers allowed;
• Modularity and possibility to support further sustainability objectives (e.g. emissions management, water management)
• Respect of EU data inter-operability, openness and re-use principles;
• Guarantees for data security and privacy in line with best current standards.

The CAP legislative proposal will now go to discussion by European Parliament and Council, a process in which stakeholders (including ESPP) will make input and representations.

* Annex III conditionality definitions: SMR = Statutory Management Requirement and GAEC = Standards for good agricultural and environmental condition of land
Legislative text proposal for a Regulation “establishing rules on support for strategic plans to be drawn up by Member States under the Common agricultural policy (CAP Strategic Plans) and financed by the European Agricultural Guarantee Fund (EAGF) and by the European Agricultural Fund for Rural Development (EAFRD) …” COM(2018) 392 final and 2018/0216 (COD), 1st June 2018 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2018%3A392%3AFIN and presentation page https://ec.europa.eu/info/food-farming-fisheries/key-policies/common-agricultural-policy/future-cap_en

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 5^th 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 3^rd 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 13^th 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/C_org 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 13^th August 2018, download online at www.phosphorusplatform.eu/regulatory comments to ESPP by 3rd September 2018 and discussion at stakeholders meeting Brussels and webinar 5^th September www.eventbrite.ca/e/eu-fertilisers-regulation-and-strubias-tickets-47156434164