Eunomia study, for ESPP, proposes 40+ questions which policymakers should take into account if considering possible ‘quotas’ for recycled phosphorus in fertilisers (minimum recycled content). The 10-page study, intended as a briefing tool for policy makers, has been developed through research and an engagement process undertaken by Eunomia on behalf of ESPP; it is not an ESPP position. The document summarises Eunomia’s review of literature and stakeholder consultation with experts and practitioners, including fertiliser producers, the water and waste industries, recycling technology companies, research. The questions are intended to provide practical perspectives on the potential effectiveness, fairness, feasibility and possible co-benefits or unintended consequences of a possible a quota system for recycled phosphorus in fertilisers. The identified questions show the complexity of defining a workable system: which types of fertiliser? Phosphorus from sewage only or also from e.g. manure ? How to ensure quality of recycled phosphorus materials if their uptake is ‘obligatory’ ? At what point in the fertiliser production – distribution – use chain could quotas be applied ? Geographical scope (how to take into account regional phosphorus surpluses, how to deal with imports and exports …) ? Would quotas be tradeable ? What would be the administrative and cost burdens ? Eunomia conclude that “Some of these questions could be difficult, if not impossible, to answer. Nonetheless, mapping out the key uncertainties and trade-offs is important for identifying practical pathways and avoiding unintended consequences.”
“Questions on Possible Phosphorus Quotas for Fertilisers”, Eunomia, January 2026, commissioned by ESPP: read the study