The 23rd of May, 2014
POSITION ON THE FUTURE EUROPEAN REGULATION
FOR FERTILIZING MATERIALS AND GROWING MEDIA
PRESENTED BY DG ENTERPRISE 17 MARCH 2014
UNIFA considers that Regulation (EC) n° 2003/2003 is an important piece of European legislation in
the field of the fertilizing materials that enables the free trade of mineral fertilizers and liming
materials in all member states of the European Union.
UNIFA supports the harmonization of the placing on the market of all fertilizers and growing media
(see UNIFA contribution of June 2011).
In addition and based on the latest information provided by the EC Working Group Fertilizers 17
March 2014, Unifa proposes to:
1. Maintain types designations in order to comply with all other regulations (Seveso directive
2012/18/EU, transport of dangerous goods... ) and to fulfill analyzes adapted to the composition of
the product. In this way, users and control services will have all the necessary information.
2 .Check that the harmonized and standardized methods of analysis cover the essential
requirements in terms of elements and concentration ranges (in particular related to the lowering of
thresholds proposed).
3. Take care of the possible overlapping of EU regulations in order not to impose
requirements already described in an existing regulation.
Ex : The chemicals substances that go into mineral fertilizers are subjected to REACH.
Ex : The dangerous substances or mixtures are labeled according to CLP
Ex : The fertilizers based on animals by-products or containing animals by-products are subjected to
Regulation ( EC) n°1069/2009 and Regulation (EU) n°142/2011 .
4. Clarify the concept of end of waste for the by-products or co- products exempt from
REACH.
For Unifa, any waste entering into the composition of a product of the future Regulation shall be
registered in REACH. However, some natural substances or substances not subjected to a chemical
reaction are exempted from REACH. It is necessary for these by-products or co-products to define
evaluation criteria and establish an entry in the settlement process.
5. Set thresholds for contaminants based on maximum application or if not possible by kg of
nutrients.
Indeed, lowering quality thresholds can allow to market diluted products complying with the
Regulation but the risk of soil contamination can still exist if large quantities are spreaded.
6. Clarify the evaluation process for the introduction of new products under the future
regulation (see guide for the evaluation of fertilizing material Unifa 2012/09).
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I. CATEGORIES OF FERTILIZING MATERIALS
UNIFA is in favor of a new regulation which integrates:
- Mineral fertilizers, organic fertilizers and organo-mineral fertilizers.
Indeed, it should differentiate an organo-mineral fertilizer from a simple blend of organic fertilizers
from animal and / or plants (without nitrogen provided from organic synthesis) and mineral fertilizers
The organo-mineral fertilizer is manufactured in the form of granulates , pellets in which we can find
each nutrient or liquid. The addition of a mineral fertilizer to an organic fertilizer is used to improve
its immediate efficacy and use by plants. This action is optimal only if the product is homogeneous.
- Liming materials
- Soil improvers with organic soil improvers and inorganic soil improvers
- Growing media
- Plant biostimulants
- Agronomic fertilizer additives ( nitrification inhibitors , urease inhibitors , chelating agents
and complexing agents, coating agents ... )
- Mixed products of the above categories as well as those prepared with the agronomic
fertilizer additives.
Compared to the presentation given at the meeting of Working Group Fertilizers on March 17th, and
in the absence of written draft and information on labeling, UNIFA wishes:
II. THE QUALITY REQUIREMENTS
(See detailed Unifa proposal in the attached table)
1. To adapt the quality thresholds categories of mineral fertilizers, organic fertilizers, organomineral fertilizers and liming materials
 For primary nutrients : minimum levels
Mineral fertilizers: N total: 3% on dry matter (DM) for solids and 2% on commercialized product for
fluids, P2O5total 3% on DM for solids and 2% on commercialized product for fluids , K2O total 3% on
DM for solids and 2% on commercialized product for fluids
Organic fertilizer (% by weight ) : N total: 3% for solids and 1 % for liquids , or P 2O5 total: 3% , or K2O
total: 3%
Organo-mineral fertilizers (% by weight) : N total 2% , of which 1 % N organic ( N without N from
organic synthesis), P2O5 total: 2% , K2O total: 2%
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Organic soil improver (% by weight) : N total < 3.0%, and P2O5total < 3.0% and K2O total <3.0%
 For secondary nutrients : minimum levels
For reasons of simplification, determine the minimum thresholds of secondary nutrient elements in
their elemental form rather than oxide.
For fertilizer without primary element:
Ca: 1.5% Mg : 1.5% S: 1 , 5 % Na: 1.5 %
 For micro-nutrients: minimum levels
Solids (% on DM) : 5 %
Fluids (% by weight) : 2 %
 For liming materials:
Minimum Neutralizing Value (as EN 12945): 25 % NV (equivalent to lime CaO) or 15 as HO - on dry
matter
Minimum reactivity for crude products (as EN 13971 or as EN 16357): 10
2. To define forms for Nitrogen and Phosphorus authorized and the solubility of Phosphorus :
• Nnitric, Nammoniacal ,Nureic , Ncyanamide ,
+ Norganic(only for organic fertilizers , organo-mineral fertilizers and organic soil improvers).
Forms of N must be declared on the label.
• Phosphorus only as single and double phosphate
• P2O5 soluble in mineral acids, in neutral ammonium citrate, in water and only for fertilizer
containing phosphate rock in formic acid.
These solubilities must be declared on the label.
3 .To define essential requirements for mixtures within a category (thresholds for micro –nutrients
can’t be the same as those for NPK fertilizer with micro-nutrients, too high) and labeling
requirements for mixtures of categories .
It is proposed to set a minimum amount for (N + P2O5 + K2O)
- 18 % on DM for solid mineral fertilizers and 12% by weight for fluid mineral fertilizers
- 7% by weight for organic fertilizers and organo-mineral fertilizers
For the fertilizer NPK with micro-nutrient : 0,001% minimum of micro-nutrient.
4. To avoid any overlapping of categories (or a product under another regulation) together so that
the same product can be placed on the market under only one category.
Indeed, to avoid a costly registration, a company could add some nutrients to a plant protection
product or to a biostimulant and sell it as an inorganic fertilizer or an organic fertilizer .
5. To maintain type designations..
Unifa believes that labeling products only with their nutrient content is insufficient, especially in
terms of security, storage and efficacy.
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Some components in the blends are incompatible and can lead to impair the efficacy of the product
due to chemical interactions (for example, alteration of the solubility) or physical interaction (eg
segregation of particles). The only technical feasibility of a physical mixture is not in itself a guarantee
of efficiency.
The lack of type designation may also make it difficult or impossible to implement or control the
application of other regulations such as the Regulation on explosives precursors or that relating to
the transport of dangerous goods.
That is why Unifa proposes that a list of type designations in the Annex or in harmonized European
standards.
6 .To have by means of labeling a difference between the products obtained by blending (bulkblends) and formulated products (complex).
To be able to distinguish granular fertilizers that combine all the nutrients in the same granule from
those which are the result of a mixture of several granular fertilizers (bulk-blends) and allow the enduser to identify the quality in order to avoid heterogeneity when spreading to the field.
8. Choose organic C and not organic matter as quality requirements, because it does not apply to
all categories of products.
Organic C is determined by chemical oxidation or specific dosage of organic C while the organic
matter is determined by gravimetry and simple combustion which leads to overestimate the rate of
organic matter for some families such as organo-mineral fertilizers OM.
III. SAFETY REQUIREMENTS :
(See detailed Unifa proposal in the attached table)
1. Unifa proposes a threshold of 75 mg / kg P2O5 for fertilizers above 5 % P2O5. A limit of 60mg/kg
P2O5 would exclude 25% of phosphate fertilizers placed on the market in France.
2. Unifa proposes to establish a maximum total Cr content in the case of organic raw materials.
Indeed, under certain conditions, the total Cr may change to Cr ( VI ) into the soil and organic
fertilizing materials are spreaded at high level of application rate.
3. In the new approach as presented, the safety criteria defined in the types designations of the
regulation (UE) n°2003/2003 will not be included in the future regulation.
Maximal Cu content for ammonium nitrate with N>28%.
Maximal Cl content for fertilizer.
Maximal content of biuret in urea.
It is necessary to integrate them in the essential requirements.
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Quality criteria
Inorganic (mineral)
solid fertilizer with
primary and secondary
nutrients and
micronutrients
Inorganic (mineral)
fluid fertilizer with
primary and secondary
ans micronutrients
Unifa proposal
Unifa proposal
Organic fertilizer
Unifa proposal
for straight solid
fertilizer 3% b W (1% by
W for fluid fertililizer)
N organic /for
compound fertilizer 3%
by W in which 1% N
organic or
Organo-mineral
fertilizer
Soil improver
liming material
Unifa proposal
Unifa proposal
Unifa proposal
N total (straight and
compound)
3% on DM
2% by W
P2O5 total (straight and
compound)
3% on DM
2% by W
3% by W or
2% by W in which 1% Norg
(0,5% by W for fluid
fertilizer) and without N
from organic synthesis
2% by W in which 1% Norg
(0,5% by W for fluid
fertilizer) and without N
from organic synthesis
K2O total (straight and
compound)
3% on DM
2% by W
3% by W or
2% by W
<3,0% by W
18% on DM
12% by W
7% by W
7% by W
<7,0% by W
fertilizer without primary
nutrient 1, 5% Ca on DM
fertilizer without primary
nutrient 1, 5% Ca by W
fertilizer without primary
nutrient 1, 5% Mg on DM
fertilizer without primary
nutrient 1, 5% S on DM
fertilizer without primary
nutrient 1, 5% Na on DM
fertilizer without primary
nutrient 1, 5% Mg by W
fertilizer without primary
nutrient 1, 5% S by W
fertilizer without primary
nutrient 1, 5% Na by W
5% on DM
2% by W
0,001% on DM
0,001% by W
15% by W (fluid
fertilizer 5% by W)
7,5% by W (fluid fertilizer
3% by W)
10% by W
N+P2O5+K2O (for
compound fertilizer)
Calcium
Magnesium
Sulfur
Sodium
micro - nutrient (simple or
mixture of micronutrients)
micro-nutrient (for
mixture with primary or
secondary muntrients)
Corganic
<3,0% by W
<3,0% by W
C/N
C/N> 8
MS
30%
25 equivalent CaO on
DM or 15 equivalent
-
NV
reactivity for crude
products
HO on DM
10
DM : Dry Matter
by W : by weight (on the commercialised product)
Thresholds depend on the limit of quantification of the method by elemnt and in the mixture
Proposal of Unifa without information on labelling from the European Commission
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Safety criteria
As
Cd pour des produits contenant
moins de 5% de P2O5
Cd pour des produits contenant plus
de 5% de P2O5
Solid or fluid
Inorganic (mineral)
fertilizer
Organic fertilizer
organo-mineral
fertilizer
Soil improver
Liming material
Unifa proposal mg/kg DM
Unifa proposal mg/kg DM
Unifa proposal mg/kg DM
Unifa proposal mg/kg DM
Unifa proposal mg/kg
DM
60
60
3
60
18
120
5
3
3
3
75 mg/kg P2O5
Cr total
75 mg/kg P2O5
120
120
120
CrVI
2
2
2
2
Standard in
development
Hg
2
2
2
2
2
Ni
120
120
120
60
90
Pb
150
150
150
180
200
Cu
300
300
300
Zn
600
600
600
Absence in 25g of product Absence in 25g of product for
for vegetable farming vegetable farming Absence in
Absence in 1g of product
1g of product for the other
for the other farming
farming
Absence in 25g of product for
vegetable farming Absence in 1g of
product for the other farming
Se
PHAs
Salmonella spp
Escherichia Coli
viable weed seeds
1000 UFC/g of product
1000 UFC/g of product
1000 UFC/g of product
Macroscopic impurities < 2mm
(glass, plastic, metal)
Macroscopic impurities > 5mm
- films and PSE > 5mm:<0,3% on DM
-other plastics > 5mm : <0,8% on DM
- glass and metal> 2mm : <2% on DM
DM : Dry Matter
Thresholds depend on the limit of quantification of the method by element and in the mixture
Proposal of Unifa without information on labelling from the European Commission
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