The EU is at an important point in its move toward more resilient, competitive and sustainable agricultural systems. Organic-based fertilisers (OBFs) derived from organic materials offer a critical pathway forward to supporting farmers into the future.
Although the EU’s Fertilising Products Regulation (FPR) aims to ensure harmonised access to the EU single market, regulatory complexity and delays continue to prevent innovation and market access.
This paper calls for three practical, low-cost regulatory adjustments by the EU that can deliver quick, high-impact benefits without compromising safety. Opening the EU single market to more OBF products will help boost competitiveness, reduce the EU’s dependency on external inputs and improve food security.
These three highlights are:
1. Animal By-Products (ABPs): Unlocking a Critical Resource for Circular Agriculture and Healthy Soils
The current rules for ABP-derived materials under the FPR, are narrow and not tailored to fertilising products. As a result, safe, nutrient-rich materials like bone meal and blood meal are often excluded from CE-marked products, discarded, or underused due to outdated or unclear regulatory processes and missing assessments.
ECOFI recommends:
- Revising ABPR references to allow safer, treated ABPs
- Allowing the ABP end point to be reached at any production stage
- Basing eligibility on the safety and quality of the final product rather than raw material origin
- Applying the “one substance, one assessment” principle to remove redundant procedures and improve predictability.
2. REACH Requirements: Disproportionate Burdens That Undermine Circular Solutions
REACH requirements continue to block market access for organic-based fertilisers made from low-risk, recycled, or biologically sourced materials, even when these materials are already covered by other EU regulations. These substances are not unsafe, they are simply subject to disproportionate regulation compared to their actual risk, particularly when used exclusively in fertilising products and already assessed under existing frameworks.
ECOFI proposes:
- Developing streamlined REACH pathways for fertiliser-use-only substances derived from organic materials
- Coordinating more closely between ECHA and the European Commission on REACH FPR interactions
- Extending the “one substance, one assessment” principle to avoid duplication for materials already evaluated under ABPR, national fertiliser rules, or FPR authorisations.
You can find out more about ECOFI’s position on the need to restore normal REACH requirements for EU fertilising products in our joint position paper with EBIC and other stakeholders.
3. Missing Materials, Missing Processes, Missing Innovation in the Circular Economy: Fixing the Gaps in a Static System
Many safe and commonly used materials are excluded from the FPR simply because they do not fit within the current Component Material Categories (CMCs). Circular economy innovations often involve new processes that change material characteristics. However, there is no ongoing mechanism to add new materials or methods, the interface between FPR, ABPR, and WFD does not support circularity, and fragmented rules lead to inconsistent interpretations across Member States. Without updates, the FPR cannot fulfil its goal of enabling cross-border trade in circular fertilising products.
ECOFI proposes:
- An open system for submitting new materials to the FPR, based on clearly defined, transparent criteria
- This system should be efficient, ensuring that new materials can be added promptly when they meet established criteria, supporting flexibility and innovation in the circular economy
- Improving regulatory coherence across FPR, REACH, ABPR, and WFD, including better coordination across Commission services (GROW, SANTE, ENVI, AGRI).
This approach will foster innovation in the bioeconomy, strengthen Europe’s position in sustainable and circular agriculture, and support food security and strategic autonomy.
If all the above measures are implemented, the European Commission can help the Fertilising Products Regulation deliver on its original promise: to increase cross-border trade in sustainable fertilising products as well as support the circular economy.
Read more from ECOFI’s position below. If you’re interested in learning more about ECOFI and how we are working to support the OBF sector, you can email jessica@prospero.ag