The European Commission has replied to ESPP that post-processing of digestates and composts (e.g. solid-liquid separation, stabilisation …) is not at present covered by the EU Fertilising Products Regulation (FPR) CMC criteria.
ESPP raised this question to DG GROW some time ago, because such post-processing will often be implemented to condition and prepare products to place on the European market, especially digestates. The Commission’s reply also confirms that processing additives used downstream of the anaerobic digester / composter are not considered as “composting /digestion additives” (as cited in CMCs3 and 5), e.g. polymers for solid-liquid separation, pH adjusters, granulation aids …
It is in ESPP’s view preferable to resolve such questions now, rather than have them being brought up during a control of a product already on the market after implementation of the FPR from June 2022.
The Commission has indicated to ESPP that amendment of CMCs 3-5 (Annex II of the FPR) could be considered to include (certain) post-processing routes, and that this will be discussed in the next EU Fertilisers Expert Group (of which ESPP is a member) in November 2021.
ESPP proposes to work with relevant federations and operators, to prepare a list of process routes and of additives used for post-processing of composts and digestates, and collate information for each one on how widespread is application and market relevance, product benefits, additives used, extent to which compost/digestate is or is not chemically modified by the process, …
EU Fertilising Products Regulation (FPR) 2019/2009