Fertilizers and circular economy, the new EU rules


The new ‘fertilizer regulation‘, reg. EU 2019/1009, effective 16.4.22, harmonizes requirements on fertilizers made from mineral phosphates and organic or secondary raw materials. (1) In a logic of circular economy and short supply chain. This opens up new possibilities for the production and sale, including in Europe, of recycled or organic materials for fertilization.

Organic fertilizers and circular economy

The European Commission presented the proposed regulation under consideration in March 2016, as part of the Action Plan on the Circular Economy in the EU. In fact, one of the main objectives is to encourage large-scale production of fertilizers made from local organic or secondary raw materials by converting waste into crop nutrients.

In fact, more widespread use of recycled nutrients in agriculture can help optimize the most resource-efficient nutrient management used. In fact, such products can be used, even in combination with fertilizers, to improve nutritional efficiency. With the benefit of reducing both the environmental impact of agricultural activities and the European Union’s dependence on nutrients from outside the EU.

Regulation (EU) 2019/1009

Reg. EU 2019/1009 supplements the existing EU rules to include recycled and organic materials. Thus, the spectrum of regulated fertilizers is greatly broadened. Opening free movement to many products that until now could not bear the CE mark. Such as organic, organo-mineral, and biostimulant fertilizers, which have become increasingly important to farmers in recent years.

The regulation also defines a set of harmonized limits, in relation to various contaminants in mineral fertilizers. With specific regard to some heavy metals (e.g., cadmium, nickel, hexavalent chromium, mercury, lead, and arsenic). The maximum cadmium content in phosphate fertilizers is set at 60 mg/kg (against a hazard limit defined as 75mg/kg). However, this threshold is intended to be progressively reduced, so as to stimulate industry to optimize the reclamation procedures of source minerals.

Classifications, standards, and entry into force

As for substance classifications , the regulation specifically clarifies that biostimulants have the function of improving one or more plant characteristics including tolerance to abiotic stress and never to protect against biotic stresses.

Finally, the Annexes to the regulation set some standards on composition and labeling of fertilizers. (2) Fertilizer manufacturers that do not bear CE markings will still be allowed to place them on national markets.

The application of the regulation, which has been in effect since 15.7.19, takes effect on 16.7.22. (3)

Dario Dongo


(1) Regulation (EU) 2019/1009, laying down rules concerning the making available on the market of EU fertilizer products, amending Regulations (EC) 1069/09 and 1107/09 and repealing Regulation (EC) 2003/03

(2) Regarding the technical means allowed in organic production, see the previous article

(3) Instead, Articles 4.3, 14, 42, 43, 44, 45, 46 and 47 apply as of 7/15/19. As of 16.4.20, Articles 20 to 36.

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Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.