subject to respecting EU Fertilising Products criteria. This positive Opinion comes just 18 months after submission of this dossier. It is now up to the European Commission to prepare an amending regulation to include such recovered calcium phosphate into the list of authorised fertilisers in Annex II of the EU Organic Farming Regulatiion. The Opinion refers to the EGTOP positive Opinion on “calcined phosphates” from municipal sewage, 2016, stating that these are a “similar material” (this is questionable), but that this Opinion was subject to their inclusion into the EU fertilisers regulation (which is now done). “Struvite and other precipitated phosphates”, as defined in the EU Fertilising Products Regulation (FPR) CMC12, were authorised in EU Organic Farming in January 2023 (see ESPP eNews n°73), but this does not cover phosphates from ashes (CMC13). This new Opinion is based on the EasyMining Ash2Phos process and mentions other processes, focussing only on calcium phosphate from sewage sludge incineration ash, noting its low water solubility as important. The Opinion indicates that recovery from other ashes (meat and bone meal, manure, plant residues, agricultural digestates) is considered not appropriate, because it is preferrable for Organic Farming to use these directly as fertilisers. The recommendation is to authorise, for Organic Farming: “Calcium phosphate recovered from ash – Only from sewage sludge ash origin – The relevant limits for contamination and organic pollutants set [in the EU FPR] apply”. This is different from the requirements for struvite and precipitated phosphates (as inscribed in the Organic Farming Regulation) which require to “meet the requirements laid down” in the EU FPR (interpreted by the European Commission to mean: must be CE-Mark Certified under the FPR). It remains to be seen which wording the Commission will use if and when they amend the Organic Farming Regulation.
ESPP regrets that this Opinion leaves “calcined phosphates” with a positive EGTOP Opinion from 2016 but not yet implemented into the Organic Farming Regulation. ESPP welcomes this new EGTOP positive Opinion but we regret that this is limited to “calcium phosphates”. If EGTOP considers each recycled material one-by-one, they will consume much energy and progress very slowly. ESPP suggests that EGTOP consider all ash-based phosphate and potassium fertilisers recovered from ash which meet the requirements of the EU Fertilising Products Regulation (PFC1 = Fertilisers and CMC13 = Thermal Oxidation Materials and Derivates), subject to defining a limitation on solubility, as discussed in this Opinion. ESPP also regrets the limitation to sewage sludge ash. Some animal by-products cannot be spread directly on fields and must be incinerated, so that recycling of nutrients from ash is the best option, and incinerators may intake several different materials in order to optimise nutrient recycling and minimise environmental footprint.
EGTOP (EU Expert Group for Technical Advice on Organic Production), Final report on Plant Protection (X) and Fertilisers (VII), adopted 6 - 8 March 2024 here.