The European Commission has published for consultation to 21/11/2022 proposed authorisation of recovered struvite and precipitated phosphates in certified Organic production. The proposed wording is as per the EGTOP Opinion of June 2022, see ESPP eNews n°69, and would modify the annexes of the EU Organic Farming Regulation (2021/1165) to include: Recovered struvite and precipitated phosphate salts: products must meet the requirements laid down in Regulation (EU) 2019/1009, animal manure as source material cannot have factory farming origin. Also as indicated in the eNews, wording concerning compost and digestate of bio-waste is modified.
Questions posed by this wording include: does “meet the requirements” of the EU Fertilising Products Regulation 2019/2009 mean that the FPR Conformity Assessment is necessary as per FPR Annex IV? Does this refer only to the specifications of Annex II CMC12, or also of Annex I PFCs and Annex III labelling ? What is the definition of “factory farming” – does this include livestock in stables for part of the year? Does this also cover “derivates” of precipitated phosphates as defined in the FPR CMC 12?
ESPP will also request that further recycled materials currently not authorised in Organic production: Renewable calcined phosphates (cf. positive EGTOP Opinion 2016 (“Final Report on Fertilisers II”) and waste ash derived nutrients (phosphorus from sewage sludge incineration ashes, potassium from municipal solid waste ashes …), Recovered elemental sulphur, Bio-sourced adsorbents used to treat wastewaters, Phosphorus-rich pyrolysis and gasification materials (inc. biochars), Algae and algae products grown to treat wastewater. Vivianite, Recovered nitrogen from off-gases..
Any individual or organisation can contribute to this public consultation.
Public consultation on amendment to the EU Organic Farming Regulation. Open to 21st November 2022