New Approach Fertiliser Regulation: Remarks VCM, Boerenbond, vzw Mestverwerkers, DLV Belgium, Inagro, University of Ghent, Febiga & Biogas-E

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1 New Approach Fertiliser Regulation: Remarks VCM, Boerenbond, vzw Mestverwerkers, DLV Belgium, Inagro, University of Ghent, Febiga & Biogas-E GENERAL REMARK We find it hard to evaluate the revised Regulation at this point, as there are only powerpoint presentations available, which are often quite vague and do not contain full text. Also background information on the proposed limit values is missing. If several options are given, it is not clear what the reason for this choice is, and what the arguments pro and contra are. Also how and when these choices will be made is not clear. Overall, giving comment on merely a powerpoint presentation, without additional background information, is not an easy task, and a lot of question marks remain. COMMENTS ON Essential quality and labelling requirements, PROPOSED IN THE PPT OF THE EC of 2/6/2014 Quality criteria We would like to highlight that the choice of the quality criteria as such, and the choice of option A or B concerning the quality criteria for organic fertilizers, is very important for the trade of processed manure intra and inter Member States. We have to avoid a deterioration of the trade possibilities. An overview of all traded products, in- and outside of Belgium, which can be considered as processed manure according to the EU 1069/2009 legislation, is given in Table 1. They are the result of an anaerobic digestion, aerobic (composting) thermal treatment of manure or another equivalent pasteurising step according to the EU 1069/2009 legislation. 1

2 Table 1: Quality parameters processed manure (for SF dig, thermally dried dig, composted man/dig, dig and LF dig (A) the 10%- and 90%-quantiles are given; for pelletized pig man, composted liming product and evaporated LF dig (B) the values of 1 specific producer are given): SOLID FERTILIZERS LIQUID FERTILIZERS SF dig Thermally dried dig Composted man/dig Pelletized pig man Composted liming product Struvite Dig (raw) LF dig (A) LF dig (B) Evaporated LF dig Effluent of biological treatment dig MC of dig Dry matter (%) 18-31% 68-95% 41-63% 90% 61,60% 100% 5-13% % 1,90% 11,04% 1.3% 3.5% C org on fresh weight % % 29.2% 12,40% 0.025% % % 0,23% 3,04% 1.5% C org on dry matter % % % 32.4% 20% % % 12,1% 27,50% 42,8% 5.7% N tot (fresh weight) % % % 2.5% 2,20% % ,29% 0,61% 0.01% 0.7% N tot (on dry % %% % 2.8% 3,60% % % 15,3% 5,50% 0,8% 20% N org (fresh weight) % % % 2.2% 1,48% 0% % % 0,40% 0.07% N org (on dry 0.9-5% 1-4.4% % 2.4% 2,40% 0.8-4% 3,60% 2% 2

3 P 2O 5tot (fresh weight) % % % 4.4% 1,80% 28% % % 0,02% 0,57% 0.03% 0.05% P 2O 5 tot (on dry % % % 4.9% 2,90% % 1,1% 5,16% 2,3% 1,4% K 2O tot (fresh weight) % % % 6.8% 8,20% 0% % % 0,0255 0,65 0.9% K 2O tot (on dry ORGANIC FERTILIZER OPTION A ORGANIC FERTILIZER OPTION B % % % 7.5% 13,3% % 1,3% 5,90% 25,7% YES YES YES YES YES NO NO NO NO NO NO NO NO YES NO YES YES/NO NO NO NO NO NO NO NO ORGANOMINERAL FERTILIZER NO YES NO YES YES NO NO NO NO NO NO NO SOIL IMPROVER NO NO NO NO NO NO NO NO NO NO NO NO SF: Solid fraction after mechanical separation LF: Liquid fraction after mechanical separation MC: mineral concentrate, the result of a membrane filtration step on the liquid fraction, which removes the remaining suspended solids Dig: digestate, the end-product of an anaerobic digestion Man: manure 3

4 CONCLUSIONS DERIVED FROM TABLE 1 Several products, currently being traded at large-scale, or with very promising future opportunities towards nutrient recovery cannot be categorised at this point, with the current proposed quality criteria. These products are: 1. Currently frequently traded inter and intra Member States in high quantities as qualitative liquid and solid fertilizers: The solid fraction of digestate, a solid fertilizer. If the European Commission will opt for option B, this product cannot be categorized as a solid organic fertilizer, as its average dry matter content (25%), average Corg content (8,5%) and average N-content (0,6%), P2O5-content (1,0%) and K20-content (0,4%) is too low to meet these criteria. However, given the current proposed quality criteria for organic soil improvers, this product can t be named a soil improver either, because its average dry matter content (25%) is too low. Composted manure/digestate, a solid fertilizer. If the European Commission will opt for option B, this product cannot be categorized as a solid organic fertilizer, as its average N- content (1,4%) and K2O-content (1,2%) are too low. However, given the current proposed quality criteria for organic soil improvers, this product can t be named a soil improver either, because the P2O5-content of composted manures contain elevated P2O5-contents (>2%). Digestate, a liquid fertilizer. Neither options A or B could categorize this fertiliser as a liquid organic fertilizer, as its average Corg content (2,5%), average N-content (0,4%), average P2O5- content (0,4%) and average K2O-content (0,3%) are too low. However, given the current proposed quality criteria for organo-mineral fertilisers, this product can t be named an OM fertiliser either, because the Corg content and nutrient contents are too low. The liquid fraction of digestate, a liquid fertilizer. Neither options A or B could categorize this fertilizer as a liquid organic fertilizer, because its Corg and nutrient contents are too low (please see Table 1 for the 10% and 90% quantiles (A) and the single analysis of a representative type of liquid digestate (B)). For the same reasons as raw digestate, it cannot be named an organo-mineral fertilizer either, given the current quality criteria. For the evaporated liquid fraction of digestate and effluent of the aerobic treatment of digestate, the same findings apply (please see Table 1 for the nutrient contents of representative samples in Flanders). 2. Products with a very high potential towards nutrient recovery from manure and digestate, currently already being produced: Mineral concentrate from digestate, with too low Corg and nutrient content to be either a liquid organic fertilizer or an organomineral fertilizer, assuming the currently proposed quality criteria. However, also a too high Corg content (average 1%) to be categorized as an 4

5 inorganic fertilizer, assuming that there will be zero tolerance for organic matter from biobased sources for inorganic fertilizers Struvite from digestate, same applies as for mineral concentrate. Further, the quality requirements for organic fertilisers and organic soil improvers require a minimum granulometry for powder form. Also for compost is granulometry mentioned as optional identification, while compost isn t a granular product. Labelling requirements What is meant by batch identification code (ppt Essential quality and labelling requirements, slide n 13, 19, 23 and 32)? Not all products are made in batch. Many of these products are made in a continuous flow because the production is based on a biological process, that needs a continuous feeding, or because of the fact that solid products such as composts are continuously being stored during winter, so that individual batches cannot be identified when fertilisation season starts. GENERAL CONCLUSIONS We regret that the current proposal does not take into consideration the trade of digestate, solid fractions and liquid derivatives from digestate and composted manures. We regret that from the current proposal there is no incentive for recycling biowaste/manure into valuable liquid inorganic fertilizers. We ask the Commission to take into consideration that these products could in the near future represent a very good alternative for mineral fertilizers. We would like additional clarification on the granulometry requirement for compost and on the definition of a batch, when these are continuous processes. SUGGESTIONS FOR CHANGE We suggest that the Commission finds a solution for the current gap between inorganic fertilizers (0% Corg) and organic fertilizers (5% Corg for liquid and 15% Corg for solid). A lot of products have a Corg content in between these values. A good option could be to have a maximum Corg content for inorganic fertilizers of 2% and all products with Corg > 2% can then be categorized as organic fertilizers. Today, national lists and existing systems (f.e. derogation procedure) can allow agricultural use of manure derived products on national level. The possible substitution of existing national legislation by the new Fertilizer Regulation should therefore be clearified. We suggest, as a secondary consideration, a derogation procedure for national agricultural use for endproducts from manure/digestate derived products, that don t meet the European criteria. 5

6 We suggest that the Commission choses option A for the organic fertilizers, otherwise a lot of products will not be able to meet the nutrient content criteria for organic fertilizers, whilst having a too high nutrient content to be a soil improver. If there is no consensus on option A, another option should be worked out with lower minimal nutrient contents for organic fertilizers or higher maximal nutrient contents for soil improvers. FOOD FOR THOUGHT Several processed manure products, currently being traded intra and inter Member States, cannot be categorised with the current proposed quality criteria The Nitrates Directive aims to protect European water bodies from pollution by nitrates from agriculture. It defines maximum limits on manure application in designated vulnerable zones. This results in the fact that a large number of EU regions are confronted with manure surpluses. These surpluses are processed into stabilized, processed manure products that are sought after by farmers in areas where there is little livestock production, but large areas of arable land. An exchange of nutrients over borders (according to the EU 1069/2009 regulation, this is only possible with processed products) is a win-win situation for both farmers. Moreover, it reduces the pressure of animal nutrients in certain hotspots in Europe with intensive animal farming, thereby protecting local vulnerable water bodies. However, current proposed quality criteria limits impede further use of certain processed manure products as a fertilizer in Europe, which can only lead to high local manure surpluses leading to environmental risks and enormous financial consequences for highly efficient intensive livestock farms in regions such as Flanders (BE), Brittany (FR), Catalunya (ES), Po valley (IT), Denmark, Quality criteria don t reflect the content of digestate, a valuable end-product of renewable energy production, currently being traded intra and inter Member States Europe aims to get 20% of its energy from renewable sources by Renewables include wind, solar, hydro-electric and tidal power as well as geothermal energy and biomass. More renewable energy will enable the EU to cut greenhouse emissions and make it less dependent on imported energy. Biomass is the most important feedstock for renewables. Biogas production plays an important role in the achievement of the EU 2020 goals. A valuable end-product of biogas production is digestate. Currently there are more than biogas plants operated in Europe, over alone in Germany. The application of digestate on arable land closes the nutrient cycles in regional ecosystems. VCM regrets that digestate and its derivatives (liquid fractions) don t fit under the current quality criteria (please see Table 1). Sustainable production and use of digestate contributes to Europe s GHG emissions saving target, creates green jobs in the countryside and reduces odour/ pathogens. Biogas is a versatile source of energy that can be produced anywhere in Europe from organic materials, municipal wastes, creating security of supply and locally produced energy for heat electricity and transport purposes. Without smooth disposal of the end-products, all other social, economic, and ecological benefits of the biogas plants will lapse. 6

7 No incentives for nutrient recovery End-products from manure and digestate processing plants, with similar properties as mineral fertilizers (high nitrogen availability coefficient and barely organic are already available, but cannot be categorised within the current quality criteria limits set out in the proposal for the revised Fertilisers Regulation. From a cradle-to-cradle perspective Europe has an important responsibility in supporting the nutrient recovery technology development and upscaling of current plants. This can only be done if the endproducts, substitutes for current mineral fertilizers, fit in the revised legislative framework. This is a first requirement before investments can be made. In Table 1 VCM, Boerenbond, vzw Mestverwerkers, DLV, Inagro, University of Ghent, Febiga and Biogas-E compared the proposed requirements with the nutrient content of the Flemish processed products based on official analyses (legal documents). It is of utmost importance that the currently proposed quality criteria are revised, so that all products mentioned here (and currently being traded without any problems, posing a win-win situation for farmers at the supply and demand side!) can be categorised in the new Fertiliser Regulation. VCM, Boerenbond, vzw Mestverwerkers, DLV, Inagro, University of Ghent, Febiga and Biogas-E aim for a level playing field in the European Fertilizer market between fertilizers from non-animal origin, and fertilizers derived from processed animal manure. MORE INFORMATION Contact person: - Viooltje Lebuf, VCM, viooltje.lebuf@vcm-mestverwerking.be, Céline Schollier, VCM, celine.schollier@vcm-mestverwerking.be, SIGNED BY Bart Naeyaert, President of VCM (Flemish Coordination Centre for Manure Processing) Eddy Vandycke, staff member manure processing, Boerenbond Luc Vansteelant, President of vzw Mestverwerkers Kristof Bol, DLV Belgium Bart Ryckaert, Head of the department of energy, biomass & innovation, Inagro vzw Erik Meers, Prof. dr. ir. at the University of Ghent Tore Content, President of Febiga vzw Luc Van Holm, President of Biogas-E 7