ECOFI, supported by APEP – the European Potash Producers Association and the European Biostimulants Industry Council
(EBIC), has released a position paper proposing a criteria-based approach to facilitate the inclusion of new materials in EU fertilising products under the Fertilising Products Regulation (FPR) without needing to update the existing lists in each Component Material Category (CMC). The current system requires regulatory updates for even minor additions, which delays the uptake of innovative, circular, safe, and effective materials.
What ECOFI aims to achieve:
ECOFI seeks to introduce a more dynamic and science-based approach to evaluating new materials, aligning with New Legislative Framework (NLF) principles and reducing delays. The proposal complements ongoing EU work on introducing new materials to the FPR, particularly the study led by the Nutrient Management Institute (NMI) and offers a practical solution that can be implemented via a delegated act under Article 42(1) of the FPR.
ECOFI’s proposal – two main options:
1.Introduce a horizontal section in Annex II with science-based inclusion criteria
ECOFI proposes introducing a horizontal section at the beginning of Annex II of the FPR, just before the specifications for CMC 1, defining general inclusion criteria for new materials across most Component Material Categories (excluding CMC 7 for micro-organisms). This approach would enable the use of innovative materials not explicitly listed, provided they meet defined safety, environmental, and agronomic thresholds such as limits for contaminants (e.g. heavy metals, pathogens), no adverse impact on human health or the environment under intended use and demonstrated agronomic effect or value (e.g. nutrient content, biostimulant function etc.). This structured framework, supported by stakeholders in the May 2025 Commission Expert Group meeting on Fertilising Products (CEG-FP) and potentially developed with the NMI, could be legally introduced via a delegated act under Article 42(1), avoiding the need to amend the Regulation itself.
2. Enable Conformity Assessment based on these criteria
ECOFI proposes allowing manufacturers to demonstrate compliance with new inclusion criteria through established conformity assessment procedures, eliminating the need to update annexes each time a new material is added. This approach restores the FPR’s original aim: facilitating market access based on safety and performance. Inspired by successful models in other EU regulations (like for construction products and medical devices), this criteria-based pathway would simplify the system, advance circularity, boost competitiveness and safeguard the environment and public health. It also aligns with broader EU strategies and strengthens the flexibility of the CE marking system under the FPR.
Together, these options provide a practical and science-based route for integrating new materials into the EU market, supporting innovation, circularity, and the bioeconomy.
ECOFI’s proposal lays the groundwork for a more flexible system to assess new materials for CE-marked EU fertilising products by introducing general eligibility criteria in Annex II. As next steps, the European Commission could: (1) develop these criteria through the ongoing NMI technical study, (2) test the approach on selected materials to test its feasibility and regulatory impact and (3) consult stakeholders to ensure the system is proportionate, workable and aligned with practical realities.
ECOFI stands ready to contribute technical insight, industry perspective, and constructive collaboration to support the successful development and implementation of this pathway together with the Commission and other stakeholders.
For more information, or to lend your support to this position, contact Jessica Fitch, Secretary General of ECOFI: jessica@prospero.ag