ECN recommendations ahead of the trilogue negotiations

Fertilising Product Regulation

Following the European Parliament’s 24/10 vote on the CE marked fertilising products proposal and with regard to the starting interinstitutional negotiations on this file, the European Compost Network (ECN) has published an updated position paper with specific recommendations on several elements of the proposal which are still incompatible with the overall objective to increase the use of recycled nutrients.

While ECN appreciates the extensive discussions that have already taken place on this file in the EP and the Council, the following elements are of grave conflict with the objective to promote safe and innovative organic fertilisers produced form recycled bio-waste and other secondary raw materials:

  • The unjustified widening of most CMCs (Component Material Categories) CMC 2, 4, 6 for bio-waste input materials to CMCs without guaranteeing sufficient treatment, process control and conformity assessment compared to requirements set for compost (CMC 3) and digestate (CMC 5) with bio-waste input materials as defined in Directive 2008/98.
  • The missing adaption of  more flexible proposed temperature/time profiles for hygienisation for bio-waste within composting (CMC 3) and fermentation (CMC 5) other than those proposed by EU COM.
  • The pathogen control with limit values for “Escherichia coli/ and Enterococcaceae” for organic fertilizer, organic soil improver and growing media.

If these will be adopted as such, the proposal would significantly obstruct the use of bio-waste materials including garden and park waste for CE marked fertilising products, and thus would go against the overall Circular Economy goals.

ECN therefore calls upon the negotiation partners to consider making the necessary changes to these and other aspects in the proposal, following the suggestions as included in our recommendations, in order to fulfil the shared objective of ensuring recycled bio-waste and other secondary raw materials will be part of CE fertilising products.

Please find the updated position paper (date 31/10) indicating several specific elements which are of our gravest concern here.