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1 Poligono Industrial La Paz, 185, Teruel (Spain) Tlfno.: Fax: To European Commission (by Register of Commission Documents website, Teruel (Spain) 9th May 2016 Matter: Feedback Proposal COM(2016)157/F1 for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL laying down rules on the making available on the market of CE marked fertilising products and amending Regulations (EC) nº 1069/2009 and (EC) nº 1107/2009. FERTINAGRO NUTRIENTES S.L. is a Spanish manufacturer of fertilisers with factories in Spain and France that produces solid and liquid inorganic, organic and organomineral fertilisers, organic soil improvers, amino acids, humic acids, biostimulants, etc. that is present into the European market and export to numerous countries around the World. We want to submit some comments about this proposal. - In general it seems very appropriate for us the approach of wanting to harmonize all fertiliser products currently marketed within the European Union, and especially organic fertilisers, organo-mineral fertilisers, organic soil improvers and other special products such as humic soil improvers (humic acids), hydrolysed proteins (amino acids), products of micro-organisms, etc. which will boost the use of organic fertilisers in Circular Economy. - We know well the problems arising from the mutual recognition that is not being applied especially in products such as these indicated, therefore the CE marking might to favour free trade and to facilitate the use by farmers of a wide range of products of big interest for the regeneration of our ecosystems and the harnessing of natural and anthropogenic organic resources. - We understand the concern of the Commission to ensure that the CE products can not endanger animal and human health and the environment by establishing limits for contaminants, although as discuss later, some limits we seem very strict without no technical justification and others instead too permissive. 1

2 - In relation to the economic and social impact of the new regulation, we are concerned that they have not properly evaluated some of the requirements that would be implemented and that this could harm ultimately the economy of the end user, the farmer, that as we will discuss, inevitably the costs of implementation and maintenance of the proposed regulatory system would be affect him. - We are also concerned that want to take advantage of the circular economy policy to make an accelerated political proposal, with many confusing points and with interpretation difficult, with lacking of agronomical requirements of effectiveness and numerous technical deficiencies, as well as paragraphs not yet completed as animal by-products that have reached the end point and products pending of their incorporation as the struvite from sewage sludge, the biochar from vegetable pyrolysis and vegetable ashes of energy crops, household wastes and sewage sludge, or well the list of harmonised standards without publishing in the Official Journal of the European Union for compliance with the requirements of this proposal. - We are aware of the importance of the changes that will be established with regard to the current Regulation (EC) nº 2003/2003 on fertilisers and we also concerned about its implementation that will require undoubtedly a great period of adaptation of enterprises to meet the new requirements, operation and development of notified bodies, development of EU conformity documentations, etc. ensuring an adequate supply to end users during this period of market adjustment. - In short, we properly value the willingness of the European Commission to harmonize and promote the use of organic fertilisers in the market and we will continue to work through the Organic and Organo-Mineral Fertilisers Manufacturers Spanish Association (FOMA) that is participating into Working Group on Fertilisers (FWG) of DG GROW since 2012 as observers, as well as other ways of collaboration. COMMETS - The considering 23 of the proposal states that the manufacturer having detailed knowledge of the design and production process is best suitable to carry out the procedure for conformity assessment. Therefore, the conformity assessment of fertiliser products with CE marking should remain the obligation of the manufacturer. However in Chapter 4 (Articles 19-35) is established the leadership of notified bodies for control and supervision of the EU Declaration of Conformity of the modules specified in Annex IV, depending on the component materials of Annex II and its functional category of Annex I. - Module A which involves an internal certification by the manufacturer may only be used for organic materials that come from the food industry (CMC 6) as molasses and vinasses from sugar beets or sugarcane and energy crop digestates (CMC 4) obtained by anaerobic digestion of vegetable material. The remaining organic products which are the majority, should declare their EU conformity 2

3 through module B (applicability of EU-type examination) combined with module C (internal production control) or the D1 module (quality assurance of the production process) being incomplete the listing of certain animal by-products (CMC 11) and indefinite the module to apply to compost (CMC 3) which apparently would have to adapt to the module D1 for exclusion of others. - Most organic fertilisers, organo-mineral fertilisers and organic soil improvers are made by composting processes, then if the compost as component material CMC 3 must meet the module D1, it would be a high cost for the manufacturing sector, so we request were applicable the module A (internal production control) or ultimately module B (applicability of EU type examination) combined with module C (internal production control) that combined with controls for Member States and Regional Governments (autonomous regions) on animal by-products and wastes, we consider would control perfectly the placing of products on the market and would be at the same level of requirements that bioestimulants for example which should assume a greater level of control by its nature. - In any case, according to the proposal from the Commission, except for CMC 6 and CMC 4, the most fertiliser products of organic nature should comply with the corresponding modules involving the intervention of a notified body to establish the EU Declaration of conformity. - If the responsibility is solely of the manufacturer, then does not make sense the intervention of notified bodies, since necessarily it would involve an unjustified increase in costs and a slowdown the placing on the market. Currently Member States, and in particular Spain, have adequate mechanisms for control of raw materials, production processes and specifications of organic products through registration in the Ministry of Agriculture that has proven to be an effective, rigorous and thorough procedure to ensure the adequacy of such products to safety standards for human health, animal and environment, as well as control of raw materials, production processes, labelling, levels of contaminants, etc. which at the same time are audited by inspections of fraud in the Autonomous Communities (Regional Governments), and in the case of animal by-products, authorizations and inspections of Regional Governments SANDACH (Animal by-products official control), and in the case of materials from wastes, integral environmental authorizations as waste management, officially periodically audited. - Therefore it is considered more efficient and less economically costly the continuity of the exhaustive control mechanisms of the products of organic origin performed in Spain. So if the responsibility is solely of the manufacturer, should remain as internal certification combined with official control bodies of the Member State (Ministry of Agriculture and bodies of the Autonomous Communities or Regional Governments), and not have to use notified bodies. - Even if notified bodies would to document a lot of training (some hundreds in a short time will emerge), they never will have the knowledge of raw materials and production processes that manufacturers nor the experience of these, so it makes no sense to verify the EU Conformity of organic products. Ultimately the responsibility lies with the manufacturer and it would add unnecessary costs that only would make more expensive the placing of products on the market and would 3

4 be the farmer the most affected with a higher cost of fertilisers and less control than at present, since notified bodies would perform a work for economical remuneration, without sufficient technical knowledge to justify it. - Therefore we request that the EU Declaration of conformity of products of organic origin be performed by the manufacturers themselves (module A) being exigible a control audit (registrations) by the Member States and Regional Governments agencies (inspections), such as it is being done today, without assuming an additional cost ultimately to the farmer. - In the event that the European Commission did not agree with this proposal, we request that at least the Member State regulate the costs of services provided by the notified bodies, in order to avoid aggravating the price of the placing of products on the market and do not harm to the farmers. - The article 12 mentions that CE marked fertilising products which are in conformity with harmonised standards or parts thereof the references of which have been published in the Official Journal of the European Union shall be presumed to be in conformity with the requirements set out in Annexes I, II and III covered by these standards or parts thereof, but they are not published as Regulation (EC) nº 2003/2003 will be repealed in which already only some standards appear. We request that before the entry into force of the current proposal of the Commission, these harmonised standards are published, particularly those affecting organic fertilisers, organo-mineral fertilisers and organic soil improvers which there are not harmonised standards currently. So specific harmonised standards should be validated because the standards for inorganic fertilisers are not applicable due to the peculiar characteristics and complexity of the organic matter. - With regard to the product function categories, Annex I, Part II, mention that an organic fertiliser PFC 1(A) and an organo-mineral fertiliser PFC 1(B) shall contain carbon and nutrients of solely biological origin, excluding material which is fossilized or embedded in geological formations, while an organic soil improver PFC 3(A) shall consist exclusively of material of solely biological origin, excluding material which is fossilized or embedded in geological formations. At no time during the preliminary meetings of FWG (DG GROW) in last years, has been mentioned a source definition in these terms, and we doubt whether therefore do not fall within these product function categories the lignites and leonardites, widely recognized in several European countries as raw materials of great agronomic interest for their supplying of humified organic matter and humic substances content. We believe that should be interpreted as the organic products from the petrochemical industry can not be used as raw materials, but yes fossilized or naturally occurring geological materials. We ask for the clarification of the suitability of the use of lignites and leonardites and to consider them as material component CMC 1 virgin material substances. - Besides the leonardites appear under Regulation (EU) nº 354/2014 amending Regulation (EC) nº 889/2008 on organic production, which its considering 3 mention that on the basis of the recommendations of the Expert Group for Technical Advice for Organic Production (EGTOP), with regard to fertilisers and 4

5 soil conditioners, concluded that leonardite (raw organic sediment rich in humic acids) obtained as a by-product of miming activities, comply with the organic objectives and principles. - With regard to the product function category solid organic fertiliser PFC 1 (A)(I) is indicated in the proposal from the European Commission, that the minimum declarable content of total nitrogen will be 2,5 % by mass. When the manufacturer used as raw materials vegetable matters, it is impossible to meet this requirement, since they naturally contain reduced content of this nutrient. We therefore propose that we can declare a minimum amount of 1,5 %, while for liquid organic fertilisers PIC 1(A) (II) would be 1 %. - With respect to contaminants in the product function category organic fertiliser PFC 1(A), are set strict limits for cadmium and nickel. With the raw materials available in the market both natural (manure, liquid manure and vegetal materials) and anthropogenic origin (household waste, sewage sludge, digestates, meat meal and bone meal, etc.) is impossible to meet such strict limits as nickel cadmium 1,5 ppm and nickel 50 ppm. We request that the limit of cadmium for this PFC is 3 ppm, similar to the proposal from the Commission for organo-mineral fertilisers PFC 1(B), for inorganic fertiliser with macronutrients PFC 1(C)(I) and even growing medium PFC 4 (substrates where root crops are grown directly, potentially more dangerous), because there is no technical justification for doing so restrictive and impossible to comply with the raw materials available, with no possibility of decadmiation. So for nickel, we request a limit of 100 ppm, even somewhat lower than the Commission proposal for inorganic fertilisers (120 ppm). If consistent permissible limits are not set with the raw materials available, many manures and slurry manures will not meet these requirements and they increase their land filling or incineration, increasing environmental problems and submerged uncontrolled market. - With regard to nickel limit on product function category PFC 3(A) organic soil improvers proposed by the Commission nickel 50 ppm, but the limit should be similar to that of the inorganic soil improvers, i.e. 100 ppm. So we request this limit is set, since there is no technical justification for differences between soil improvers. - Following heavy metals, we found that the Commission proposal on cadmium in product function categories organo-mineral fertiliser PFC 1 (B) and inorganic macronutrient fertiliser PFC 1 (C) (I), indicates that if P 2 O 5 5%, the limit will be 60 mgr, Cd/kg.P 2 O 5 when this Regulation enters into force, 3 years later 40 mgr.cd/kg.p 2 O 5, and 12 years later 20 mgr.cd/kg,p 2 O 5. These limits are impossible to meet with the raw materials available in the market. - We understand the Commission's position of wanting to protect human and animal health and the environment by imposing strict limits to reduce dependence on imports of phosphates and promote the recycling of natural resources (manures, slurry manures, vegetable matters, etc.) and anthropogenic resources (sewage sludge, household waste, digestates, meat meal and bone meal, etc.), but we must not forget that these materials also contain cadmium in significant quantities, so phosphorus removal would aggravate the displacement of cadmium to products or 5

6 waste of such extraction, moreover with much higher costs that phosphorus of natural phosphates (more than double), that finally will pay the farmer. - We consider unjustified to impose arbitrary limits on cadmium that are not based on any technical basis but by reference to national laws of 2-3 countries with reduced fertiliser market and guaranteed supply of phosphates from igneous origin by small local deposits or the proximity of the Russian Kola deposits, which in no case can cover the demand for phosphates in the European market. - In 2003 SCTEE (current SCHER) reported that the limits of cadmium in fertilisers should be established on a more solid basis using techniques of risk assessment and not based solely on a possible accumulation in soil that does not take into account the level of risk to human health and the environment. The limits now proposed by the Commission are based on its possible accumulation in the soil according to some algorithms containing wide variation factors and questionable applicability, and not based on a real risk assessment. In some non-eu countries that have developed exhaustive studies based on risk assessment (USA, Canada, Australia, Japan, New Zealand, etc.) from its application in fertilisers until its migration to the food chain to the most sensitive populations, they have set much higher limits, without any harm to health or the environment. In Japan 146 mgr.cd/kg.p 2 O 5, in Australia 131 mgr.cd/kg.p 2 O 5, in New Zealand 122 mgr.cd/kg.p 2 O 5, in United States 4-10 mgr./kg. (by States) per each unit of P 2 O 5, etc. And for organic production in Regulation (EC) nº 889/2008 is set the maximum limit 90 mgrs.cd/kg.p 2 O 5, which therefore meets the criteria and principles of respect to the health and environment. - Decadmiation alternatives are currently not viable and would only be applicable to the phosphoric acid and derivative products, which will displace the problem of cadmium to phosphogypsum, incrementing this well known environmental problem. The calcination of the phosphates will release cadmium to the atmosphere increasing the atmospheric deposition which is also undesirable. - Moreover not make sense to set strict limits for cadmium when according to studies by various authors, inputs of cadmium to the soil of fertilisers are very low compared with other sources of cadmium as atmospheric deposition generated by natural and anthropogenic causes (combustion fossil materials, metallurgical industries, alloys and pigments industries, batteries industries, plastics and polymers, etc.). In fact according to the soil map prepared by Joint Research Centre (JRC) of the European Commission, shows that the highest concentrations of cadmium in soils does not match with the agricultural areas of application of fertilisers, but with the industrial areas of various European countries. - In short, we believe that cadmium limits should be set according to serious studies of actual risk assessment and take into account the application rate or the maximum permissible annual loads. - We attach also the study made by our company, presented in 2014 to DG Enterprise (now DG GROW), a thorough review of all the studies presented in the last fifteen years on cadmium and it performs a similar FOMA proposal but based on real risk assessment, reaching the conclusion that the limit should be around 4 6

7 ppm per unit of P 2 O 5 with what would be 100% protected the most sensitive populations in the worst-case scenarios (similar to California and Minessota States), document Annex I (FERTINAGRO. Presentation and Risk Assessment Study Cadmium.2014). - If the Commission persists in setting arbitrary limits without any technical basis, it will forces to all European manufacturers to seek and to import phosphates of igneous origin with low cadmium in distant and limited availability deposits, creating a dependence on Russia (limited availability for internal consumption) and the Middle East (political instability and uncertainly supply), which substantially increase of the costs of final products to farmers, with the consequent economic and social damage, because moreover with increasing demand of the igneous phosphates, prices would rise dramatically. - A long period of market adjustment for raw materials stored and search for new suppliers of phosphates via import (at least 3-5 years as proposed by the European Commission when he presented the New Approach in 2010) will be needed, so we request this period is established since the publication of future regulation to entry into force, taking into account the difficulty of implementation of the requirements of the proposal, creation, formation and development of notified bodies, preparation and documentation of EU Declarations of conformity, publication of harmonised standards, etc. - However we found very permissive the hexavalent chromium admitted to all functional product categories, 2 mgr/kg. while the current Spanish national legislation requires not be detected (typically < 0.2 ppm) by the analytical method standard EN in organic fertilisers, organo-mineral, organic soil improvers and special products such as humic acids and amino acids (Spanish RD 506/2013). It is known the great oxidizing and carcinogenic power (Group I of the International Agency for Research on Cancer, displayed as a human carcinogen agent) of this compound that also causes kidney and liver damage as well as allergies and skin lesions, with an LD50 (man) < 50 mgr / kg. generating acute renal failure at doses 1-2 mgr/kg. So we do not understand that in the soil improvers which are used 5-10 Tons/ha. they can be admitted so high contents, nor in fertilisers in which lower doses are used. In some non-eu countries, controls on its presence in fertilisers are very exhaustive. Its danger is much higher to cadmium by ingestion, while inhalation cadmium is no danger and instead hexavalent chromium can be lethal. We request that in benefit of health and the environment its content is restricted to maximum, that is, not detectable by the method EN There are dechromation viable industrial processes that should be implemented in case of presence of carcinogenic chromium. - In addition hexavalent chromium is restricted to not detectable on Regulation (EU) nº 354/2014 amending Regulation (EC) nº 889/2008 on organic production according to the Expert Group for Technical Advice for Organic Production (EGTOP) in animal by-products, mixed household waste composted or fermented and organic sediments freshwater, which shows its ecological danger. - With regard to the content of biuret, it is set in the Commission proposal for organic fertilisers PFC 1(A) a maximum of 12 g/kg. Currently there is no 7

8 standardized method of analysis for organic fertilisers, so we do not know if this criterion can be met. There is only EN applicable to synthetic urea by spectrometry and standard ISO / FDIS applicable to urea-based solid and liquid products by HPLC, but no standardized method for organic fertilisers. - In the functional category PFC 1(A)(I) solid organic fertiliser is established as a requirement that contains at least 40 % dry matter and PFC 1(A)(II) liquid organic fertiliser containing less than 40 % dry mass. We request to change both values to 60 % as set out in the functional classes of organo-mineral solids and liquids; it is absurd the placing on the market of solid organic fertilisers with up to 60 % moisture. However we consider acceptable in organic soil improvers (solid) PFC 3(A) is maintained 40 % or more of dry matter by the nature of the raw materials used in these products. Although it should include other relevant functional category as liquid organic soil improvers PFC 3 (A)(II) with less than 40% dry matter, given their considerable presence on the European market and the necessity of regulation. - Another important subject for our company are humic acids and amino acids that are being used in Spain for more than twenty years with a consolidated experience and an important market both in Spain and in other European countries, which are not clearly defined in the Commission proposal. - With respect to humic acids, they are considered organic soil improvers by several European countries as they are products that supply humified organic matter to the soil as humic substances, improving the agronomic characteristics of soils and increasing the formation of clay-humic complex and its cationic exchange capacity in the rhizosphere and nutrient retention and assimilation. They also improve the physical and biological soil properties with extensive scientific literature. Therefore they can meet the criteria of product function category PFC 3(A) organic soil improver, in order to be incorporated into the soil to maintain, improve or protect the physical or chemical properties, structure or biological activity of the soil, and being of organic origin, they fall under the description of organic soil improver PIC 3(A) and they accomplish the requirements set out in Annex I part II of this functional category. - However it could be understood that humic acids also fall under the functional product category PFC 6 as plant bioestimulants depending on what they bring to the soil, as they have a stimulating effect of plant development, but it is precisely the incorporation of humified organic matter what is resulting in the plant such stimulation. Not forget that mineral nutrients occurs something similar: to provide nitrogen that is incorporated into metabolic cycles, stimulates the vegetative development, in the same way that phosphorus stimulates root development, pollination and fruit set and the potassium input stimulates tissue consistency, quality, soluble solids, sugars and fruit coloring. Mineral fertilisers supply nutrients and then stimulate plant physiology, but nonetheless are considered bioestimulants. We therefore propose that humic acids can enter into product function category PFC 3(A) organic soil improvers or to clarify their cataloguing as organic non-microbial plant biostimulant PFC 6(B)(I). 8

9 - With respect to amino acids, we understand that are nitrogenous organic fertilisers of animal or vegetable origin such as configured in legislations of several European countries, as they always contain organic nitrogen and its contribution promotes the synthesis of proteins in the plant and other metabolic precursors necessary for the development. Besides they supplying organic nitrogen with similar function to processed manures, vinasses, etc. as well as organic carbon which improves nutrition and plant metabolism. Therefore they could enter into PFC 1(A) as organic fertiliser to provide nutrients carbon and accomplish the contaminants requirements of that category. - We are also aware that amino acids, depending on what they supply to the plant, have a stimulating effect of plant development, with the incorporation of organic nitrogen integrated into amino acids, resulting in the plant such stimulation, as we have discussed with mineral nutrients that stimulate various stages of plant development. We therefore propose that amino acids can enter into product function category PFC 1(A) as organic fertilisers or to clarify their cataloguing as organic non-microbial biostimulant PFC 6 (B)(I). - Another observation we make, is about the amino acids of animal origin. In the proposal the Commission stated in the considering 9 that fertiliser products with CE marking that fall within the scope of Regulation (EC) nº 1069/2009, but reaches a point in the manufacturing chain beyond which it no longer offer poses any significant risk to public or animal health ("the end point in the manufacturing chain"), it would represent an unnecessary administrative burden to continue subjecting the product to the provisions of this Regulation. It is therefore appropriate to exclude such fertiliser products from the scope of that regulation. It is therefore appropriate to amend Regulation (EC) nº 1069/2009 accordingly. And in the considering 10 it is mentioned to be necessary to determine the end point in the manufacturing chain of each material relevant component containing animal by-products in accordance with the procedures laid down in Regulation (EC) nº 1069/2009. Thus, in Article 45 of the Commission proposal is indicated that Article 5 of this Regulation, that for derived products referred to in Articles 32, 35 and 36 which no longer pose any significant risk to amending public or animal health, an end point in the manufacturing chain may be determined, beyond which they are no longer subject to the requirements of the Regulation. - In particular Article 32 of Regulation (EC) nº 1069/2009 refers to organic fertilisers and organic soil improvers, and in the Regulation (EU) nº 2015/9 is modified the article 20 of the Regulation (EU) nº 142/2011, and is added that the exempt from the registration requirement to operators who use small amounts of materials from categories 2 and 3 or products derived to supply them directly to end users within the same region, in the local market or local establishments of retail, if the competent authority considers that such activity do not poses a risk of spreading any serious transmissible to humans or animals disease. - In addition, the exemption of registration of the users of organic fertilisers or organic soil improvers in premises where there is no farm animals and operators who handle and distribute organic fertilisers or organic soil improvers exclusively in ready packages for sale to retail weighing 50 kg maximum for external uses to the chain of feed and food. 9

10 - In short, as long as fertilisers in packages of up to 50 kgs. the registration is not necessary, while for larger packages or bulk will depend on the competent authority. These measures therefore facilitate the marketing of these products and unsubscribe the register of warehouse operators and carriers that handle packaged goods, reducing the requirements of Regulation because their dangerousness is understood. - Moreover the Regulation (EU) nº 354/2014 amending Regulation (EC) nº 889/2008 on organic production, in the considering 3 is indicated that on the basis of the recommendations of the Expert Group for Technical Advice for Organic Production (EGTOP), with respect to fertilisers and soil conditioners they concluded that the amino acids (hydrolysed proteins) from animal by-products, accomplish the objectives and ecological principles (involving their safety), which are included as fertilisers used in organic production with that only requirement that they should not apply to the edible parts of the crop. - Therefore we request that in accordance with Article 45 of the Commission proposal, as amino acids are no longer pose any significant risk to public or animal health and also their use in organic production is contemplated, the end point in the manufacturing chain must be determined, ceasing to be subject to the requirements of Regulation (EC) nº 1069/2009 and appearing as CMC 11 material component in Annex II as hydrolysed proteins (amino acids) with safety requirements (maximum molecular weight, degree of hydrolysis, microbiology, etc.) to be determined. - Both the conformity assessment module B and module D1 of Annex IV, states that must be submitted to the notified bodies, evidences that the animal by-products have reached the end point in the manufacturing chain within the meaning of that Regulation. Since Article 5 of Regulation (EC) nº 1069/2009 is amended, and in particular may be determined an end point in the manufacturing chain regarding organic fertilisers and organic soil improvers as referred to in Article 32 of this Regulation, we request is sufficient evidence that the final product which is prepared by ABP accomplish the requirements of this proposal from the Commission and enter into the product function categories of organic fertilisers, organo-mineral fertilisers, organic soil improvers and plant biostimulants. - With respect to algae (seaweed) extracts sold in the European market, according to the Commission proposal, they would be classified in accordance with Annex II as component materials, plants, parts of plants or plant extracts unprocessed or processed mechanically (CMC 2), but only with cutting, grinding, centrifugation, pressing, drying, lyophilization or extraction with water. However, most of the algae extracts on the market are obtained by alkaline treatment. The Regulation (EC) nº 889/2008 on organic production mentions them as directly obtained by physical processes including dehydration, freezing and grinding or extraction with water or aqueous acid and/or alkaline solution or fermentation. So that apparently according to the Commission proposal could not be marketed with the CE mark. Please clarify us if algae extracts obtained by alkaline treatment can be marketed with the CE mark. We request to include into CMC 2 the alkaline treatment of the seaweed extracts. 10

11 - Also in Annex II, in the component material category CMC 7 micro-organisms, they have listed only mycorrhizal fungi, and three nitrogen-fixing bacteria (Azotobacter, Rhizobium and Azospirillum). Despite the insistence of the Commission proposal of the importance of the use of phosphorus in the Circular Economy, it is surprising that phosphorus solubilising bacterias such as Pseudomonas fluorescens, Ps. ferruginous, Bradyrhizobium sp, Bacillus polymyxa, Bacillus megaterium, etc. are not included-we request that phosphorus solubilizing micro-organisms are included. Similarly it would be interesting to include potassium solubilizing micro-organisms (Bacillus mucilagenosus, Paenibacillus sp., Aspergillus awamori, etc.). - Annex II within the component material category CMC 6 by-products from the food industry, we request that in addition to the products of the sugar industry, are included these of the wine industry (vinasse, grape marc and other vegetable materials), beer (pomace, yeast and vegetable materials), oil from olive trees and oilseeds (marc, alpechin, alperujo, cake meal, etc.) and starch (corn extracts, tubers, etc.), since the big interest of all these products in the manufacture of organic products. also used for Organic Production on Regulation EC nº 889/2008). - Annex III on labelling requirements in product function category PFC 1(C)(I)(a) solid inorganic macronutrient fertiliser, is indicated that the particle form of the product shall be granule, pellet or powder (when at least 90% of the product can pass through a sieve of 10 mm). These indications should also appear in product function product categories PFC 1(A)(I) solid organic fertiliser, in PFC 1(B)(I) solid organo-mineral fertiliser and PFC 3(A) organic soil improver. With regard to the latter product function category, it should also be separated if it is a solid or a liquid organic soil improver, as already indicated above, since the liquid forms are very frequent in the European market and they must regulated. - Continuing with the labelling requirements of Annex III, we believe that in product function categories CFC 1(A) organic fertiliser, CFP 1(B) organo-mineral fertiliser and CFC 3(A) organic soil improver, in addition to declaring the contents in nutrients and organic carbon, also we think it should be indicated the total humic extract (humic substances) and the content of humic acid and fulvic acids. Humic substances are the sum of humic and fulvic acids and they are the fraction of the organic matter that is transformed into humus. Humus is the main indicator of agronomic quality of organic matter and is responsible for the formation of the clay-humic complex and nutrient retention capacity and is directly correlated with soil fertility. If we produce organic fertilisers, organo-mineral fertilisers and organic soil improvers with good humus content, their agricultural activity will be higher. We can quantify humic substances as total humic extract by standard methods. We request to be declared on the label the total humic extract and content of humic/ fulvic acids in organic fertilisers, organo-mineral fertilisers and organic soil improvers because it is an essential quality requirement in these CFP. - In the same way, we request able to declare the (free) amino acids when present in product function categories PFC 1(A) organic fertiliser, CFP 1(B) organo-mineral 11

12 fertiliser and PFC 3(A) organic soil improver, because of their agronomic value and quality parameter. - We also consider of interest in labelling requirements (Annex III), the C/N ratio (organic carbon/organic nitrogen) in organic fertilisers PFC 1(A) because is a parameter indicative of the degree transformation of organic matter and its rate of mineralization, being traditionally used in many European countries. This parameter is already mentioned in organic soil improvers PFC 3(A). - Generally we consider that organic fertilisers PFC 1(A), organo-mineral fertilisers PFC 1(B) and organic soil improvers PFC 3(A), in addition to carbon and nutrients should be declared requirements of agronomic quality, indicating their higher assimilation by crops and improve of the soil fertility. - With respect to tolerances (part 3 of Annex III) on the organic carbon in the product function category PFC 1(A) organic fertiliser and PFC 1(B) organomineral fertiliser is contemplated a 20 % of relative deviation of the declared value with a maximum of 2 percentage points in absolute terms. And with regard to product function category PFC 3(A) organic soil improver, organic carbon 10 % of relative deviation of the declared content with a maximum of 1 percentage point in absolute terms. Due to the high variability that present the organic carbon in the ring tests that take place in Spain annually between laboratories from the manufacturer sector and the Member State and Regional Governments, we consider that in both cases should be allowed a tolerance of 20 % of relative deviation of the value declared with a maximum of 4 percentage points in absolute terms. SUMMARY OBSERVATIOS - Request for application of module A (EU Declaration internal production control) for products of organic origin combined with monitoring by the Member State and Regional Governments, and otherwise official regulation of the costs of the notified bodies by the Member State to not harm the prices to the farmer for placing the products on the market. - Request for confirmation of the suitability of use of lignites and leonardites as raw materials for organic fertilisers, organo-mineral fertilisers and organic soil improvers and their inclusion as virgin materials substances. - Adjustment of the cadmium and nickel limits in organic fertilisers (thus equating them to inorganic fertilisers), due the impossibility to accomplish them for the raw materials available, because otherwise they will end up in landfills or incinerators, since they could not be used;. And in the case of organic soil improvers to set a nickel limit similar to inorganic soil improvers. 12

13 - With respect to cadmium in organo-mineral fertilisers and inorganic fertilisers, with phosphorus content higher than 5%, we request to establish limits based on real risk assessment and not exclusively based on a hypothetical accumulation in the soil, due to the impossibility to meet such strict limits with the raw materials available in the market, which will not reduce the contents in soils and will harm the costs of the sector to farmers, with negative economic and social impact and generating dependence on Russia and the Middle East, which also logically will increase their prices drastically per their demand into the European market. - Clarifying of the classification of products with large experience in Spain as humic substances (humic acids) and hydrolysed proteins (amino acids) as organic fertilisers or organic soil improvers respectively, or their suitability as plant bioestimulants. - Request for hydrolysed proteins (amino acids) of animal origin as the end point determined in the manufacturing chain, because they pose no danger to health or the environment, ceasing to be subject to the requirements of Regulation (EC) nº 1069/2009, and to be included as component materials. - Request for the declaration of humic substances (total humic extract) and the content of humic/fulvic acids, as well as free amino acids if are presents, in organic and organo-mineral fertilisers and organic soil improvers because they are essential requirements of agronomical quality. - Adaptation of the tolerances of organic carbon in organic and organo-mineral fertilisers and organic soil improvers, due to the variability generated by current analytical methods. - Finally, we request for a reasonable period of market adjustment (transitional period allowing companies and public authorities to prepare for the new rules according to the press release of the European Commission on March 17, 2016), of 3-5 years as proposed by the European Commission when presented the New Approach in 2010, because the adequacy of raw materials and production processes to the new requirements of cadmium, since the publication of future regulation to entry into force, taking into account besides the difficulty of implementation of the proposal, operation and development of notified bodies, preparation of documentation modules conformity assessment, publishing of the harmonised standards, etc. 13

14 We hope you are taken into consideration all our observations in relation to the manufacturers of organic products sector and ultimately in interest of the farmer and we are at the disposal of the Commission, Council and Parliament for any clarification or additional information required. Yours faithfully, Rafael Gómez Gamero Technical Manager Fertinagro Nutrientes S.L. Spanish Fertilisers Industry - Document enclosed: Annexe I Presentation and Risk Assessment Study Cadmium 14

15 ANNEX I PRESETATIO STUDY OF CADMIUM I FERTILISERS AD EW PROPOSAL, FOR MEMBER STATES AD OBSERVERS OF THE FWG 22nd August, 2014 Fertinagro Nutrientes S.L. is a Spanish manufacturer of solid and liquid inorganic, organic and organo-mineral fertilisers, organic soil improvers, amino acids, humic acids, biostimulants, etc. that is present into the European market and export to numerous countries around the World. This company is associated in FOMA the Organic and Organo-mineral Fertiliser Manufacturers Spanish Association, and it has participated actively on the FOMA proposals to the European Commission during last years. Now, we present here a complete study about the cadmium on fertilisers studying all works published in the last fifteen years on Europe and other countries in order to establish conclusions for the preparation of the future European Regulation, and moreover we make a proposal based on real risk assessment and compatible with FOMA proposals. Into the point 6 of the minutes of the FWG on 19 November 2012, information about the technical working groups established to prepare the revision of the Fertilisers Regulation, it was indicated that as regards the proposed maximum limit values for heavy metals in primary and secondary nutrient fertilisers, it was agreed that the limit for cadmium should be expressed in mg/kg P 2 O 5. Several Member States (PL, FR, PT, ES) said that the limit of 60 mg Cd/kg P 2 O 5 proposed by several countries during the discussions on the FWG 28 th October 2009, was too stringent and should be raised up to 90 mg Cd/kg P 2 O 5. During this meeting of 2009, there was not agreement because these limits were not based on risk assessment (SCHER Scientific Committee on Health and Environmental Risks, 2003, before SCTEE). The WG3 during 2012 established, but not consensus, that if the fertilising material content bellow 5 % of P 2 O 5, the maximum content of cadmium should be 1,5-3 ppm similar to EoW JRC As is known, the concentration of cadmium is correlated with the percentage of phosphorus and the application rate. Then, we would agree to express the limit for cadmium in mg/kg P 2 O 5, but it is necessary to divide the quantity of the cadmium into the final product by the concentration of the P 2 O 5 in the product to get the cadmium concentration in mg/kg P 2 O 5. We think this mathematic operation could be not intuitive for the users, the farmers, and it not feasible into the standard fertilisers market. The Commission was studying during 2013 to establish classes of maximum heavy metals contents in function of the application rates. Other possibility is to set a maximum yearly load and to fix a maximum application rate for not reaching this limit, as is proposed by FOMA. In some States of USA, the rules set limits for cadmium in mgrs/kg. per each one percent of P 2 O 5 (and also in Europe for feeding stuffs). This operation is easier and intuitive and it is directly correlated with the application rates, then we think could be interesting to express the cadmium content in mgrs/kg. of cadmium per each one percent of P 2 O 5. In this way, the richness of the fertiliser is correlated with the application rate and then the quantity provided to the soil. In relation with the limit for the cadmium in phosphates, a lot of studies have been submitted into the last fifteen years. The studies submitted by some European countries could justify the possible cadmium accumulation into the soil, but it is not correlated with the ingestion of cadmium by the population 1

16 or the possible damage to the environment, as the Scientific Committee SCHER confirmed in This Committee also established that a limit for Cd in phosphate fertilisers should be derived based on a risk assessment approach and not only based on the soil accumulation of arbitrary proposals. In our opinion, it has not been made an adequate valuation of the risk action-consequence, getting arbitraries limits based into the proposals of Finland, Sweden and Austria, with limited agricultural surface and local supplying of sources of igneous phosphates with low cadmium (Siilinjarvi-Finland, Kiiruna-Sweeden, Grangessburg-Sweeden) of scarce production and impossible coverage for the European Union. Only it is concluded that based in algorithms of wide variation of results and doubtful scientific validation, could have accumulation into the soil if the limit of 60 mgr.cd/kg.p 2 O 5 was exceeded, witch is a limit based into the national rules of the mentioned countries. But the manufacturers of the rest of Europe (more than 90 %) haven`t option rather than the sedimentary deposits of the North of Africa and scarce resources in Middle East, being absurd the supply of Kola or South Africa. To pretend to justify unattainable limits of cadmium with the available raw materials in Europe, arguing the endangerment for the human health and its possible migration to the food chain, have not sense if we checking all the studies about this matter. In USA, Canada, Australia, New Zealand, etc. where have made exhaustive studies about the presence of cadmium on the phosphated fertilisers and its possible impact on the chain food through the exposition pathways to the populations more sensible, are fixed limit much more high around 4-10 ppm per each 1 % de P 2 O 5 (4 ppm in California with ph 4-8 and intensive application rates of fertilisers) or 131 mgr/kg P 2 O 5 (Australia) or 146 mgr/kg. P 2 O 5 (Japan) or 122 mgr/kg. P 2 O 5 in New Zealand with very acid soils. It is inadmissible that three-four countries want to impose limits that are not based in the risk assessment but to reach no accumulation in the soil, without take into account other more important inputs (air deposition, sludges, industrial wastes, etc.), neither really rating the health risk of the possible exposition pathways of the supplied cadmium with the fertilisers, taking into account only the intrinsic risk of cadmium. SCHER agreed in 2012 that the low ph of some soils, could increase the uptake by the crops, however, as cadmium removal from the soil by leaching is also high, the net cadmium soil accumulation is lower. The future trends in crop cadmium concentrations are smaller (lower increase) in countries like Sweden compared to most other trends in Europe because soil cadmium increases at a lower rate at equal input. In the rest of the World, the limits of cadmium on fertilisers, with very wide range of ph and application rates, are much less strict, being even paradoxically much more permissive for the feed animal inside Europe. If we check the Commission Directive 2005/87/EC about undesirable substances in animal feed as regards lead, fluorine and cadmium, the Scientific Panel on contaminants in the Food Chain of the EFSA, adopted an opinion on a request from the Commission related to cadmium as undesirable substance in animal feed on Then, this European Directive rules the maximum content in feeding stuffs much less stricts that the European proposals on fertilisers. The limits fixed in this Directive are for straight ingestion of feedings stuffs that go into the food chain through the animals (meat, milk, etc.). Therefore for fertilisers to set limits like 1,5-3 mgr/kg. as is discussed into WG3 during 2012, is not logic and totally absurd because the animals or the humans do not eat fertilisers. As we know, the cadmium of the fertilisers up taken from the soil depends on the bioavailability and numerous factors, and then the limits must be well higher than feeding stuffs. The studies that have been done in other countries outside the EU, in special in USA, result exhaustive, and they constituent a valuation of the real risk from the beginning of the application 2

17 of phosphates at high application rates and with high contents of cadmium, until the ingestion of agricultural products and even ingestion of fertilised soil with phosphates by the more sensible populations (children of farmer families, pregnant women with low reserves of zinc, vegetarians, etc.) with the scenarios more unfavourable, as well as the study of possible damages to the aquatic organisms and environment in general, taking into account multiples factors, that conclude with the calculation of maximum admissible concentrations based into the real risk (Risk-Based Concentrations RBC) and that through statistic treatment (probabilistic and deterministic) for covering all the possible scenarios with the % percentile, result in limits much higher than those some countries into the EU want to set. The beginning studies about risk-based concentrations for cadmium and other metals were developed in 1998 by California Department of Food and Agriculture CDFA through the consulting Foster Wheeler, Lee R. Shull, and in 1999 the risks were assessed using the principles developed by USEPA (Environment Protection Agency USA), with acceptable level of risk. In 2000 The Fertilizer Institute (TFI) contracted with the consulting Weinberg Group for developing the RBC (threshold of cadmium concentration based into risk assessment), with a similar equation to that used by CDFA with Foster Wheeler. At the end of 2000, The Weinberg Group, worked in collaboration with a consulting of CDFA (New Fields), and recalculated the limits RBC basing in the distribution coefficient of the soil obtained by USEPA. They did not introduce changes in the RBC, confirming their validity. After to make this study, and taking into account that the main way of input of cadmium to soil is the atmospheric deposition (metallurgic industries, miner extractions, manufacture of batteries industries, incinerations of plastics, pneumatics and urban wastes, pigments, colorants, etc.) and other important sources like sewage sludge, compost, biodigestates, manures, etc., although the limit of 60 mgr. was set in fertilisers, or even was reduced to 40 or 20, the problem would being the same, and into the soil, we would find an average content at European level of 0,2 mgrs.cd/kg. The map elaborated by Joint Research Centre (JRC) of the European Commission, show that the European areas with high content in cadmium, are not the agricultural areas, but the industrial areas. Moreover the Communitarian foods or the importation of countries where is not regulated the cadmium in fertilisers or the limits are more high, accomplish with the European rule of foods (Regulation EC nº 1881/2006 and EU nº 488/2014). Then is evident that the bioavailability of the cadmium coming from fertilisers and its small application rates, may not produce any problem at medium or large term. Concerning to the decadmiation process of phosphoric acid, is not still acceptable or practice (it only would affect to TSP), and only would permit to displace the cadmium to phosphogymsum, then it would increase the environmental problem, already important in numerous countries. The study conclude with a proposal based into the analysed documentations for covering all the unfavourable scenarios and for the more sensible populations, and with the reflexion about if the cadmium is more dangerous in Europe than the rest of the World, since the limit outside EU are less strict (USA, Canada, Japan, Australia, New Zealand, etc.). Also are proposed the measures that would be adopted to reduce the cadmium in the environment. Rafael Gomez Spanish Fertilisers Industry 3

18 GLOBAL OVERVIEW ABOUT THE STUDIES O CADMIUM RISK ASSESSMET I FERTILISERS EUROPEA PROPOSAL CADMIUM COTET I FERTILISERS A reflexion: Is the cadmium more dangerous in Europe than in the rest of the World? Technical Management. August 2014.rev3 Spain Contact: direcciontecnica@agrimartin.com

19 COTETS 1. INTRODUCTION ATMOSPHERIC RELEASES (EMISSIONS) CADMIUM IN SOIL 7 4. HUMAN EXPOSURE PATHWAYS AND EFFECTS IMPACTS ON THE ECOSYSTEM CADMIUM IN FERTILISERS EUROPEAN STUDIES FOR THE REGULATION OF THE CADMIUM IN FERTILISERS STUDIES SUBMITTED BY SEVERAL EUROPEAN COUNTRIES Finland Norway Austria Denmark Sweden Other informations (Germany, France, United Kingdom) REGULATIONS AND STUDIES IN OTHER COUNTRIES OUTSIDE EUROPEAN UNION Washington State Department of Agriculture (USA) State of Oregon (USA) California Department of Food and Agriculture (USA) Environment Protection Agency EPA (USA) The Fertilizer Institute (TFI) (USA) The Association of American Plant Food Control Officials AAPFCO (USA-Canada-Puerto Rico) Canada Australia Japan New Zealand Summary limits cadmium LAST PROPOSAL EUROPEAN COMMISSION DISCUSSIONS Risk assessment differences Inform of the Scientific Committee on Toxicity, Ecotoxicity and the Environment SCTEE (2003) Inputs of cadmium from fertilisers and other sources Algorithms accumulations in soil (ERM, EU) Plant uptake of soil cadmium and algorithms (ERM, EU) Cadmium bioavailability from soil Cadmium release to environment Cadmium assessment impact on human health Cadmium assessment impact on environment European cadmium limits in fertilisers American cadmium risk assessment in fertilisers OUR PROPOSAL, RISK-BASED CONCENTRATION OF CADMIUM IN FERTILISERS COMPARISON OF OUR RBC PROPOSAL WITH FOMA ASSOCIATION PROPOSAL CONCLUSIONS REFERENCES

20 RISK ASSESSMET CADMIUM I FERTILISERS 1. ITRODUCTIO Cadmium is a soft, silvery white metal that occurs naturally in the Earth s crust. Cadmium usually combines with other elements such as oxygen, chlorine or sulphur to form cadmium oxide, cadmium chloride or cadmium sulphate. Cadmium oxide is most commonly found in the air, because it may be oxidised in moist air at ambient temperatures, whereas cadmium chloride and cadmium sulphate dissolve in water. The average natural abundance of cadmium in the earth's crust has most often been reported from 0.1 to 0.5 mgrs./kg. Trace elements such as cadmium (Cd) are ubiquitous in the natural environment. It is indigenous in soils and is derived from the weathering of minerals in parent material. Factors such as climate, vegetation, topography, organic matter, micro organisms, and ph may affect their presence, chemical forms, and transformations in the soils. Mineral extractions and manufacturing processes often concentrate the broadly dispersed cadmium, which end up in industrial products and consumer goods. Thus, anthropogenic activities often redistribute the extracted cadmium near and around human habitats when the wastes from mining, manufacturing and consuming are disposed. Cadmium is potentially harmful to humans and other biota that are exposed to them, even in rather small quantities. In crop production, cadmium may be introduced into soils through a variety of environmental exposure pathways that include applications of fertilisers and micronutrients, irrigation, pesticide uses, land application of organic wastes, re-incorporation of crop residues, and atmospheric fallouts (Chang and Page, 2000). Depending on their chemical nature and concentration, cadmium in the soil may be transformed to other chemical forms, accumulated in soils, leached into deeper soil strata, be carried away by surface runoffs, become airborne, and/or be absorbed by growing plants. One source is the geologic Cd coming from parent rock (< mg/kg), atmospheric deposition arising from industry, and sewage sludge and industrial waste application to agricultural lands. These three anthropogenic sources are major contributors to the Cd burden in agricultural soils in Europe and North America. 2

21 According the study of World Health Organization (WHO), cadmium exerts toxic effects on the kidney, the skeletal system and the respiratory system and is classified as a human carcinogen. It is generally present in the environment at low levels; however, human activity has greatly increased those levels.cadmium can travel long distances from the source of emission by atmospheric transport.it is readily accumulated in many organisms, notably molluscs and crustaceans. Lower concentrations are found in vegetables, cereals and starchy roots. Human exposure occurs mainly from consumption of contaminated food, active and passive inhalation of tobacco smoke and inhalation by workers in the nonferrous metal industry.national, regional and global actions are needed to decrease global environmental cadmium releases and reduce occupational and environmental exposure. The majority of cadmium present in the atmosphere is the result of human activities, especially smelting of non-ferrous metal ores, fossil fuel combustion and municipal waste incineration. Atmospheric deposition of cadmium on arable soils exceeds its elimination in many countries, resulting in a gradual increase in cadmium levels in soils and crops.application of municipal sewage sludge to agricultural soil can also be a significant source of cadmium. The main part of the cadmium metal is converted into cadmium oxide for production of batteries. Cadmium metal is converted into cadmium oxide mainly in China, Belgium and Japan. Belgium and China are major importers of cadmium metal and Belgium further export the cadmium oxide to producers of NiCd batteries in other countries. NiCd batteries are manufactured in a global manner in that raw materials originate in one country, the batteries are produced in another, incorporated into a product in yet another, and sold into a final market and used by the consumer in yet another. The main producers of portable batteries are China and Japan, whereas Sweden and France are the major producers of industrial NiCd batteries (ICdA, 2006). The worldwide market of NiCd batteries continues to grow, cadmium concentrations in the urban environment are commonly considerably higher (an order of magnitude or more) than those in rural areas. Elevated concentrations of cadmium in mosses can be associated either with local contamination from various industrial and mining activities, or with atmospheric long-range transport from large-scale point sources, or from widespread area sources. 3

22 2. ATMOSPHERIC RELEASES (EMISSIOS) According to the information submitted by United Nations Environment Programme (UNEP) in 2008 and 2010, the major natural sources for emission to air are volcanoes, airborne soil particles, sea spray, biogenic material and forest fires. The main anthropogenic sources of emissions are non-ferrous metal production and fossil fuel combustion. Other sources include iron and steel production, waste incineration and cement production. In some developing countries, open burning of cadmiumcontaining products and indiscriminate dumping contribute to local and regional exposure. The more recent study suggests that natural emissions might be between 5 and 30 times higher than anthropogenic emissions (UNEP ) Various human activities (such as mining, metal production, combustion of fossil fuels and other industrial processes) have resulted, therefore, in elevated cadmium concentrations in the environment. For example, cadmium deposition in the 1960 s and 1970 s in the Greenland ice core was eight times higher than in pre-industrial times. These data suggest that industrial emissions have been more important as a source of deposition in Greenland and perhaps other Arctic areas than natural emissions. Direct deposition of Cd from air is a potential direct route by which Cd may enter the human food chain. The experimental evidence reviewed indicates that this pathway can be neglected in areas with low Cd deposition rates (<2 g Cd ha-1 y-1, typical of most rural areas in Europe). However, airborne Cd can be a dominant source of Cd in crops if Cd deposition is clearly elevated (>10 g Cd ha-1 y-1), a situation that may occur around pyrometallurgic smelters. Dalenberg and Van Driel, 1990, measured the relative contribution of air Cd to the Cd concentration in different field crops grown in a rural area of the northern Netherlands. The airborne fraction of Cd varied from insignificant (grass, spinach, carrot roots and shoots) to maximum 21% in wheat flour and 48% in wheat straw. The higher contribution in wheat was ascribed to the longer growing period of that crop. These plants were grown in field conditions where the Cd deposition rate was g Cd ha-1 y-1, a value typical of rural areas in central Europe. Atmospheric deposition was Austria 2,6 gr.cd/ha/y (BFl 1997), France 2 gr.cd/ha/y (Jensen and Bro-Rasmussen 1992), Belgium 3,6 gr.cd/ha/y (rural areas, VMM 1997). Nriagu and Pacyna, 1988, subtmitted that the release to land coming from coal fly ash and bottom fly ash was the 26 % of the total discharge of cadmium, and the atmospheric fall-out was the 19 %. Fertilisers, only was the 0,5 % (To see the table below) 4

23 It was also reported that total inputs of cadmium from both dry deposition and precipitation range from 2.6 to 19 g ha-1 year-1 in rural areas (ERM 2000). About the release to land and aquatic systems, following the information of the UNEP (2008 and 2010), some cadmium-containing products are disposed of in various waste deposits, released to soil or the aquatic environment. Major categories of these releases include residues from coal combustion, mine tailings, and smelter slag and waste. In recent years, nickel-cadmium (NiCd) batteries and primary batteries with cadmium content have constituted a major source of cadmium disposed of in landfills with municipal waste. About three-fourths of cadmium is used in Ni-Cd batteries, most of the remaining one-fourth is used mainly for pigments, coatings and plating, and as stabilizers for plastics. The long-term fate of the cadmium accumulating in the landfills is uncertain and may represent a future source of releases. The handling of wastes may lead to elevated local and regional release levels for developing countries. The open burning in some developing countries of waste products containing cadmium could be an important source of local and regional cadmium releases to land and aquatic systems. Cadmium is produced mainly as a by-product of mining, smelting and refining of zinc and, to a lesser degree, as a by-product of lead and copper production. A growing proportion of refined cadmium consumption is accounted for by NiCd batteries, which in 2004 represented 81 per cent of the total. Other major uses of refined 5

24 cadmium are: pigments for plastics, ceramics and enamels; stabilizers for plastics; plating on iron and steel; and as an alloying element of some lead, copper and tin alloys. Products containing cadmium are not typically collected separately from the general waste stream. Therefore cadmium discards will end up in municipal waste and disposed of in landfills, incineration, open burning or indiscriminate dumping. Some of the cadmium in these products will be released to the environment, the extent of which depends on disposal method, control technologies applied and other factors. In remote areas of the United States of America, atmospheric cadmium concentrations are generally below 1 ng/m 3. Levels in urban air are significantly higher (3 40 ng/m 3 ). Over the Great Lakes, atmospheric cadmium concentrations ranged from 0.2 to 0.6 ng/m 3. These data indicate that atmospheric cadmium concentrations are much higher close to sources of emissions and that long range transport results in much lower levels in the atmosphere. Total emission to the atmosphere from natural sources Nriagu (1989) estimated the total emission in 1983 at 150-2,600 tonnes/year. These estimates are still frequently cited. In a new study by Richardson et al. (2001), total emissions from natural sources are estimated at 15,000-88,000 tonnes/year. The large difference is mainly due to very different estimates of the significance of the releases of soil particles to the atmosphere and cadmium releases from natural fires, and confirm the complexity about the calculations of the emissions to the atmosphere. The releases of cadmium by natural processes, as estimated by Richardson et al. (2001), seem to exceed anthropogenic releases. The major component of cadmium anthropogenic emission to air is due to pyrogenic emission which involves burning of fossil solid and liquid fuels in boilers, internal combustion engines, turbines, non-ferrous metal production, etc. In some densely populated countries, e.g. Denmark and the Netherlands, waste incineration residues, and in particular clinker, are frequently used for road construction purposes and other civil works, thereby increasing the possibility that cadmium may be spread into the environment through construction and later reconstruction activities. The air Cd concentrations in Denmark (Hovmand et al. (1.3 ng m-3) and atmospheric Cd deposition during plant growth ( g ha-1 y-1) are representative for a rural area. In rural areas, Cd deposition rates typically are below 2 g Cd ha-1 y-1. Around old metal smelters, the air-crop foodchain pathway may therefore dominate Cd exposure in the general population at high atmospheric Cd deposition (e.g. >10 g Cd ha- 1 y-1). Cadmium pollutants present in the air may be transported from a hundred to a few thousand kilometres and have a typical atmospheric residence time of about l-10 days before deposition occurs by wet or dry processes (Elinder, 1985; ATSDR, 1999). 6

25 3. CADMIUM I SOIL Cadmium in soils mainly comes from atmospheric deposition, manure and sewage sludge, wastewater irrigation, phosphate fertilisers, etc. The U.S. EPA (1999) reports that under acidic conditions, cadmium solubility increases and very little adsorption of cadmium by soil colloids, hydrous oxides, and organic matter takes place. At ph values greater than 6 units, cadmium is adsorbed by the soil solid phase or is precipitated, and the concentrations of dissolved cadmium are greatly reduced. Cadmium forms soluble complexes with inorganic and organic ligands, in particular with chloride ions. The formation of these complexes will increase cadmium mobility in soils (McLean and Bledsoe, 1992, as cited by U.S. EPA, 1999). Adriano et al., (2005) argue that in general, chloride can be expected to form a soluble complex with Cd 2+ as CdCl +, thereby decreasing the adsorption of Cd 2+ to soil particles. In contrast to inorganic ligand ions, Cd 2+ adsorption by kaolinite, a variable-charge mineral, could be enhanced by the presence of organic matter via the formation of an adsorbed organic layer on the clay surface (Adriano et al.,2005). Cadmium may be adsorbed by clay minerals, carbonates or hydrous oxides of iron and manganese or may be precipitated as cadmium carbonate, hydroxide, and phosphate (U.S. EPA, 1999). Evidence suggests that adsorption mechanisms may be the primary source of cadmium removal from soils. In soils and sediments polluted with metal wastes, the greatest percentage of total cadmium was associated with the exchangeable fraction. Cadmium concentrations have been shown to be limited by cadmium carbonate in neutral and alkaline soils (U.S. EPA, 1999). In Europe and USA, the amount of Cd added to soils from the atmosphere in rural areas varied from 1 to 25 g/ha.year (Jackson and Alloway 1992). In agricultural soils, is submitted by several countries, that the higher input of cadmium is the atmospheric deposition. According to JRC EU (Cd Summary Risk Assessment Report 2008), current diffuse emissions of Cd to agricultural soil through atmospheric deposition and the use of P fertilisers are predicted to have a small effect on future soil Cd concentrations (EU mean: 6% increase in 60 years) with modelled regional soil that include natural soil, industrial soil and 8 different agricultural scenarios (all below the PNECsoil). All these modelled values are total concentrations that are expected after 60 years (agricultural soils) or far beyond that (natural and industrial soils) with current regional emissions to soil. The starting concentrations are EU average values for the ambient concentrations. (To see the table below) 7

26 Mining, smelting, and sintering of non-ferrous metals have resulted in cadmium contamination of nearby soils. In regions near these types of industrial operations, surface soils with concentrations in excess of 24 mg Cd/kg have been frequently reported. (Page, A.L. et all. 1998). Plant bioavailability of soil Cd Soil factors that increase the uptake of Cd by plants are low ph, high salinity, high Cd concentration, low organic matter content, low cation exchange capacity, low clay, Fe and Mn oxides concentration, Zn deficiency, presence of NH 4+, high temperature. Cd decreases in various plant species and plant parts in the following order: leafy vegetables > root vegetables > cereals > fruits. Older plants or plant parts contain more Cd than younger ones. In Sweden was reported (Statens livsmedelsverk 1989; Eriksson et al. 1990) that the Cd content of oat grains has a clear connection with the soil ph. When the ph of the soil was increased by one ph unit in the ph range of , the Cd content of grains was decreased to about a half. Leafy vegetables and potato tubers naturally accumulate higher levels of cadmium than do fruits and cereals (Mench et al. 1998). Long term experiments carried out in the United States, where the recommended levels of phosphorous were used, showed that while cadmium in soil had increased over time, the wheat, corn and soybeans grown on these soils showed no increase in cadmium (Mortvedt, 1987). 8

27 Liming generally decreases extractable Cd. By increasing soil ph generally decreased Cd concentration in plant, but another factors like grain yield can affect the Cd concentration. Furthermore the great factor influencing Cd uptake by oat was the soil ph and the crop yield. Consequently the final conclusion is that even though the Cd in soil can increase with addition of Cd through phosphate fertilisers in the ranges of application giving, the availability of this metal mainly depends of the soil ph. Furthermore the application of fertiliser, during a long period of time did not necessarily increase the plant Cd and Cd uptake. Moreover it is often observed that Cd concentration in soil solution or Cd concentrations in neutral salt extracts of soil (NH 4 NO 3, NaNO 3 or CaCl 2 extracts) are better predictors for crop Cd than total soil Cd. This indicates that Cd availability is linked with Cd mobility. The discussion on soil ph affecting crop Cd has, however, shown that mobility and plant availability do not always go hand in hand. The dynamic equilibrium between cadmium in the soil solution and that absorbed on the solid phase of the soil depends on the ph, the chemical nature of the metal species, the stability of cadmium complexes and the binding power of functional groups and competing ions (Hellstrand and Landner, 1998). Both toxicity and bioavailability of cadmium are influenced by soil characteristics (ECB, 2005). Soil characteristics influence cadmium sorption and therefore its bioavailability and toxicity (ECB, 2005). Cadmium mobility and bioavailability are higher in non calcareous than in calcareous soils (Thornton 1992, as cited by ATSDR, 1999). Liming of soil raises the ph, increasing cadmium adsorption to the soil and reducing bioavailability (He and Singh 1994; Thornton 1992, as cited by ATSDR, 1999). A general trend emerges that toxicity increases in soil when mobility of cadmium is higher, i.e. soil toxicity increases as soil ph, or soil organic matter decrease. Exceptions to this rule have also been found (ECB, 2005). Plants grown in a greenhouse or a container take up more cadmium than the same plants grown in soil with the same cadmium levels in the field. This is due to greater root development in a confined volume in containers and to the fact that all the roots are in contact with cadmium-contaminated soil. In the field, roots may grow down below the cadmium-contaminated level (Page and Chang, 1978; De Vries and Tiller, 1978, as cited by IPCS, 1992b). Increasing soil zinc is known to reduce cadmium availability to plants (ECB, 2005) because Zn inhibits cadmium uptake and cadmium translocation from roots to shoots of plants (Chaney and Ryan, 1994). Once the heavy metals are placed in the soil, they can be stored in it, move to plant roots, lost to water ways. Metal mobility is affected by soil processes and soil factors, such as ph, inorganic and organic ligands, ionic strength and cation concentration, time of contact and redox reactions (McLaughlin et al., 1998). From the total amount of heavy metals in soils, a particular fraction is absorbed by plants. That fraction is influenced by plant processes in the rhizosphere, such as solution ph at soil-root interface, and root exudates as the main ones. One of those is the chloride, which can be considered as the best example, because is often founded in high concentration in the soil solution and is known it forms complexes with contaminants metal ions. When the Cd makes complexes together 9

28 with chlorine, the mobility of Cd through the soil increase as well as increase through desorption of Cd from the solid phase and maintenance of a higher equilibrium solution Cd concentration. Positive relationships had been found between Cd 2+ and Cl - concentrations in saline soils within crops growth on them. In spite of this positive tendency there was also shown a limit of Cd amount on soil surfaces capable of being desorbed by Cl -, which means that at this point Cl - does not increase total Cd 2+ concentrations in solution, but simply reduces Cd 2+ activity (McLaughlin et al., 1997). In a study between Norwegian University of Life Science Department of Plant and Environmental Sciences and the Universidad Politécnica de Madrid, Escuela Técnica Superior de Ingenieros Agrónomos, the Cd concentration in plant was not affected by different levels of Cd applied to the soil in any of the years under study ( ). Hence the results suggest that the plant Cd does not depend of the amount of Cd added. Generally the same trend was observed in soil Cd, because any change was detected in total soil Cd increasing Cd additions through fertilizer. Plant availability of soil Cd depends on several soil and crop factors. In general, plant uptake of Cd increases with: (1) decrease in soil ph; (2) decrease in Cd sorption capacity of soil, i.e. decrease in soil contents of organic matter, clay, Fe, Al, and Mn oxides; (3) decrease in soil moisture content; (4) increase in soil salinity leading to the formation of soluble CdCl complexes; (5) increase in deficiency of micronutrients, such as Zn. 4. HUMA EXPOSURE PATHWAYS AD EFFECTS With the discovery in the 1970 s that Itai Itai disease in some prefectures of Japan that was caused by chronic Cd poisoning of the local population due to irrigation of rice with polluted waters from mining areas, provisional limits on tolerable human intakes of Cd were set by the World Health Organisation. Despite several reviews, these provisional limits remain unchanged to this day (WHO, ) and EFSA took them into account for the Commission Recommendation (2014/193/EU) about the reduction of the presence of cadmium on foodsstuffs. Other controls on Cd were introduced in many countries by limiting this metal s use in industrial products, setting strict limits for industrial waste discharges to the environment, and imposing limits in foods, drinking waters and agricultural inputs. Cadmium (Cd) is a heavy metal found as an environmental contaminant, both through natural occurrence and from industrial and agricultural sources. Foodstuffs are the main source of cadmium exposure for the non-smoking general population. Cadmium absorption after dietary exposure in humans is relatively low (3 5 %) but cadmium is efficiently retained in the kidney and liver in the human body, with a very long biological half-life ranging from 10 to 30 years. Cadmium is primarily toxic to the kidney, especially to the proximal tubular cells where it accumulates over time and may cause renal dysfunction. Cadmium can also cause bone demineralisation, either through direct bone damage or indirectly as a result of renal dysfunction. After prolonged and/or high exposure the tubular damage may progress to decreased glomerular filtration rate, and eventually to renal failure. The International Agency for Research on Cancer has classified cadmium as a 10

29 human carcinogen (Group 1) on the basis of occupational studies. Newer data on human exposure to cadmium in the general population have been statistically associated with increased risk of cancer such as in the lung, endometrium, bladder, and breast. Cadmium is recognized by the World Health Organization (WHO) as a carcinogen by inhalation, which can cause lung cancer, bone disease and kidney dysfunction, but still no evidence exist to link cadmium to cancer by oral ingestion. Cadmium accumulates in the kidneys with a half life of years (Van Kaunwenberg, 2002; Syers, 2001). Cadmium tends to build up in human body with continued exposure. Cadmium concentrations can build up in the soils, which can lead to higher uptake by food plants. However still there is lacking information doesn t exist enough data to ensure the positive relation between cadmium in soils and food chain, bioavailability of Cd and its transfer to food chain is getting big concern in the European Union. According to World Health Organization (WHO), the provisional tolerable weekly intake (PTWI) has been set at 7 µg Cd Kg-1 of body weight (Van Kaunwenberg, 2002; Syers, 2001). This amount is basically based on risk assessment from studies of the Japanese Itai-itai disease. In 1988 and subsequently in 2003, the Joint FAO/WHO Expert Committee on Food Additives (JECFA) set and confirmed a Provisional Tolerable Weekly Intake (PTWI) of 7 µg/kg body weight (b.w.) for cadmium (FAO/WHO, 1988; 2004). In 2010, the JECFA reviewed its previous evaluation on cadmium and established a provisional tolerable monthly intake (PTMI) of 25 µg/kg b.w. which corresponds to 5.8 µg/kg b.w. as weekly intake. In 2004, the European Commission carried out an exposure assessment with the data collected in SCCOP task (EC, 2004). The SCOOP report served as a basis for setting and updating maximum levels for cadmium in foodstuffs. In 2009 and subsequently confirmed in 2011, the Panel on Contaminants in the Food Chain issued an opinion in which they recommended that the PTWI should be reduced to a tolerable weekly intake (TWI) of 2.5 µg/kg b.w. in order to ensure a high level of protection of consumers, including subgroups of the population such as children, vegetarians or people living in highly contaminated areas (EFSA, 2009; 2012). The mean dietary exposure across European countries was estimated to be 2.3 µg/kg b.w. per week (range from 1.9 to 3.0 µg/kg b.w. per week) and the high exposure was estimated to be 3.0 µg/kg b.w. per week (range from 2.5 to 3.9 µg/kg b.w. per week). Due to their high consumption of cereals, nuts, oilseeds and pulses, vegetarians have a higher dietary exposure of up to 5.4 µg/kg b.w. per week. Regular consumers of bivalve molluscs and wild mushrooms were also found to have higher dietary exposures of 4.6 and 4.3 µg/kg b.w. per week, respectively. Tobacco smoking can contribute to a similar internal exposure as that from the diet. House dust can be an important source of exposure for children. The EFSA Panel (2012) concluded that although adverse effects are unlikely to occur in an individual with current dietary exposure, there is a need to reduce exposure to cadmium at the population level because of the limited safety margin. The current review confirmed that children on average and adults at the 95th percentile dietary exposure could exceed health-based guidance values. 11

30 The kidney is considered the critical target organ for toxicity of cadmium in humans. The main critical effects include an increased excretion of proteins in urine as a result of proximal tubular cell damage. The severity of the effect depends on duration and magnitude of exposure. Cadmium is a human carcinogen by the inhalation route. Epidemiological data from occupational settings confirm lungs being the primary target organ. Cadmium is not considered a carcinogen by ingestion. Cadmium is mainly stored in the liver and kidneys. Excretion is slow, with a very long half-life (decades) in the human body. Cadmium concentrations in most tissues increase with age. Cadmium occurs in all food, but agricultural crops (particularly irrigated rice) generally account for most of the intake. Vegetarians and high cereal-consuming and pulse-consuming groups are likely to have higher exposures compared to the general population. People with a high intake of shellfish and organ meat from marine animals may have a particularly high intake of cadmium. People with low body iron stores, especially pregnant women, or low zinc intake will exhibit higher rates of cadmium uptake. People with other nutritional deficiencies may also be at risk. Tobacco is an important source of cadmium uptake in smokers and may also affect non-smokers through passive exposure to secondary smoke. People living in the vicinity of industrial sources and other point sources of cadmium release can be exposed to an increased level of cadmium. According to available data, the average weekly intake of cadmium from food in most countries is within the range of µg/kg body weight. Although available data indicate that most people have intake levels below the provisional tolerable weekly intake (PTWI) (7 µg/kg body weight per week), WHO recognizes that the margin between the PTWI and the actual weekly intake of cadmium by the general population is small, less than 10-fold, and that this margin may be even smaller in smokers. In some populations at high risk, the margin may be non-existent. In Japan the daily intake of cadmium per person is estimated at 3.59 µg/person/day or 3.75 µg/kg body weight/week, which is lower than the provisional tolerable weekly intake (7.0 µg/kg bw/w) (Japan s submission, 2007). Most cadmium in the human diet comes from agricultural products, as plants take up the metal from soil; cadmium reaches soil through deposition from the atmosphere and other sources, mainly mining areas. In heavily contaminated areas, re-suspension of dust can cause a substantial proportion of crop contamination and human exposure via inhalation and ingestion (WHO/UNECE, 2006). Workers may be exposed to cadmium in the zinc, copper and steel industries, in the manufacture of nickel-cadmium batteries, solar cells, and jewellery, in metal plating, production of plastics and many other industrial activities. Acute cadmium poisoning is characterized by irritation of the respiratory tract, while in chronic poisoning the main target organ is the renal tubule (Nogue et al., 2004). The main route of cadmium exposure in the occupational setting is via the respiratory tract. Air concentrations of cadmium fumes or dust vary considerably between different industries, such as smelters, pigment plants and battery factories (Järup et al., 1998a). Workers exposed to high levels of cadmium may develop renal proximal tubular dysfunction, glomerular damage with progressive renal disease, and respiratory symptoms, including pneumonitis and emphysema, and acute respiratory distress syndromes (Barbee and Prince, 1999). 12

31 The risk assessment of food chain contamination is complicated by the lack of a consistent relationship between soil Cd and crop Cd. The population studies in contaminated areas do show that the correlation between soil Cd and indicators of Cd exposure (U-Cd or B-Cd) is weak or insignificant. Soil or crop specific Cd transfer data should, therefore, be included in the risk assessment of Cd. Human uptake of cadmium takes place mainly through food. Foodstuffs that are rich in cadmium can greatly increase the cadmium concentration in human bodies. Examples are liver, mushrooms, shellfish, mussels, cocoa powder and dried seaweed. An exposure to significantly higher cadmium levels occurs when people smoke. Tobacco smoke transports cadmium into the lungs. Blood will transport it through the rest of the body where it can increase effects by potentiating cadmium that is already present from cadmium-rich food. Other high exposures can occur with people who live near hazardous waste sites or factories that release cadmium into the air and people that work in the metal refinery industry. When people breathe in cadmium it can severely damage the lungs. This may even cause death. Cadmium is first transported to the liver through the blood. There, it is bond to proteins to form complexes that are transported to the kidneys. Cadmium accumulates in kidneys, where it damages filtering mechanisms. This causes the excretion of essential proteins and sugars from the body and further kidney damage. It takes a very long time before cadmium that has accumulated in kidneys is excreted from a human body. In terms of foodstuff contamination by cadmium, the Codex Alimentarius Comission, assert the Cd limits in dry weight for plants, as cereal grain in 0,1 mg Cd Kg plant-1, rice polished (0,4 mg Cd Kg plant-1), brassica vegetables (0,05 mg Cd Kg plant-1), leafy vegetables (0,2 mg Cd Kg plant-1), legume vegetables ( 0,1 mg Cd Kg plant-1), potato (0,1 mg Cd Kg plant-1), and wheat (0,2 mg Cd Kg plant-1). Moreover in the European Union, the Regulation (EC) nº 1881/2006, set vegetables and fruits 0,05 mgr/kg., leafy vegetables y fresh herbs 0,2 mgr/kg, root vegetables and potatoes 0,1 mgr/kg. And the Commission Regulation (EU) nº 488/2014 confirmed these limits and added limits for chocolate and cocoa powder, processed cereal based foods for babies, parsnips, salsify, celery and horseradish, certain fish species, etc. A big quantity of studies has been reported to analyse the cadmium content in foods, in Europe and in the rest of the world. Fortunately, the found levels are usually below the thresholds of Codex Alimentarius and EC Regulations. For the human, it has been estimated that an 8-hour exposure to 5 mg/m 3 may be lethal and an 8- hour exposure to 1 mg/m 3 is considered as immediately dangerous for life. 13

32 5. IMPACTS O THE ECOSYSTEM Cd tends to bioaccumulate in organs such as the kidney and liver of vertebrates, but aquatic invertebrates and algae can also build up relatively high concentrations. Effects on birds and mammals are mainly due to kidney damage. In sea birds and marine mammals in particular, cadmium accumulates to relatively high levels. In terrestrial ecosystems, soil micro-organisms and plants are more sensitive to cadmium than soil invertebrates. Both invertebrates and plants can accumulate cadmium. Predators feeding on such soil invertebrates can introduce cadmium into the food chain, which suggests a risk of secondary poisoning through the food chain from worms to higher trophic levels (birds or mammals). The accumulation of cadmium by plants results in this contaminant entering the human food chain. Atmospheric deposition has been decreasing as a result of decreased emissions, but atmospheric deposition was in the late 1990 s (and at present) still the major source of cadmium input to agricultural soils in many of the European countries for which cadmium balances for agricultural soils have been reported. This air deposition coming from metallurgic industries, miner extractions, manufacture of batteries industries, incinerations of plastics, pneumatics and urban wastes, pigments, colorants, etc. As cadmium is taken up by plants, increased soil concentration can result in an increased cadmium concentration in food products. The re-use and/or landfilling of incineration residues may result in a longterm diffuse emission potentially contaminating groundwater, surface water and soil (Summary risk assessment JRC 2008) An increasing part of the global cadmium consumption is used for nickel-cadmium (NiCd) batteries, which in 2005 accounted for 82 percent of the total cadmium consumption, however, under certain conditions, cadmium can be transported by airflows over hundreds or even thousands of kilometres and contribute to the impact on human health and ecosystems far away from the emission source adhered to aerosol particles. A total predicted non effects concentration PNEC soil of mg/kg soil has been proposed for ecosystem, based on ecotoxicity. The average content in arable European soils is 0,2 mgr/kg while in industrial areas reach up 1,6 mgr/kg. A total PNEC water of 0.19 µg/l has been proposed in several risk assessment. The Cd concentrations in large European rivers vary between < µg/l., with most values found < 0.1 µg/l. The Cd concentrations in sediments range 1-10 mg/kg dw with most values around 1 mg Cd/kg dw. The PNEC sediment =2.3 mg Cd/kg dw and is derived from a chronic study and an assessment factor. No risks to the aquatic environment is observed for landfills emitting a leachate with a total cadmium content of 5-50 µg/l unless the leachate contains >50 µg Cd L-1 and is discharged immediately to the surface water. No risk for soil organisms is predicted for the hypothetical local incineration plant when considering the atmospheric Cd emissions. Concentrations in air of 0,1-0,5 ng/m 3, with Predicted Environmental Concentrations (PEC) of 0,6. The PNEC oral for birds and mammals is mg/kgfood respectively based on chronic feeding studies. No risk is predicted for aquatic organisms in the soft waters (hardness below 40 mg CaCO 3 /L) of the Swedish region for which a characterization could be made with the hardness corrected PNEC very soft water of 0.08 µg/l which is proposed for water with hardness mg CaCO 3 /L and DOC concentrations above 2 mg C/L with the additional warning 14

33 that for the most sensitive species there is no information that there would be no adverse effects below that PNEC below hardness 5 mg CaCO 3 /L and DOC 4 mg/l. 6. CADMIUM I FERTILISERS Fertilising materials are manufactured containing certified amounts of plant nutrients to facilitate crop growth when applied on cultivated lands. In addition to the active ingredients, however, fertilisers may contain trace elements such as cadmium that is potentially harmful to consumers of the harvested products if the substances of concern are absorbed by plants during the course of growth. Cadmium may enter commercial fertilisers by being present in the raw materials used for manufacturing and blending. If is added as apart of the nutrients and micronutrients, this element may accumulate over time in the receiving soils, as they are relatively immobile in comparison to the plant nutrients. In this manner, its concentrations in the soil will rise, resulting in greater plant uptake. The question is, could applications of phosphorus fertilisers cause an increase in the concentrations of potentially hazardous trace elements such as cadmium in cropland soils? In each cropping or growing season, however, the quantities required per unit of cultivated area to support a successful harvest are moderate. Judging from the concentrations and distributions of cadmium in the fertilisers, the trace element inputs to cropland soils, although frequent and long-term in nature, are inherently low in intensity. Even though their concentrations in the fertilisers supplements may be significantly elevated, the amounts of cadmium added to soils through each application are small in comparison to the mass of the receiving soils. According to the information of Smolders, Belgium 2008, in terms of cadmium input, the Mediterranean countries as Portugal (3,1 gr Cd ha-1 year-1), France (2,5 gr Cd ha-1 year-1), Italy (2 gr Cd ha-1 year-1), and Spain (1,9 gr Cd ha-1 year-1) have the highest levels. Whereas the Scandinavian countries have the lowest cadmium input, Sweden and Finland (0,1 gr Cd ha-1 year-1), and Denmark (0,5 gr Cd ha-1 year-1) (Nziguheba and Smolders, 2007, Van Kaunwenberg, 2002). (To see table below) 15

34 16

35 Cd input to agricultural soil via the application of sewage sludge (gr/ha/year) up to 100 Belgium (MFG-1996), 22,3 UK (Allowey et al. 1998), up to 50 Germany (provided by Germany 2002). Manure, UK 6,5 (Allowey et al.1998), Germany 4,1 (Severin,1999), Netherland 2,1 (MFG 1996) The trace element content of the soils may also be changed through natural weathering processes, by atmospheric fallout, and due to plant absorption. In addition, there are other sources of inputs such as pesticides and irrigation water. Thus, it is essential to separate the contributions of the other causes and the fertiliser applications on the changes in trace element concentrations in the cropland soils. Accumulations of cadmium, if they indeed occur, would more likely be detected in the surface layers of cropland soils receiving long-term and high-intensity fertiliser applications. Vegetable productions require considerably higher levels of fertiliser inputs than other crops. The soils receiving frequent and heavy fertiliser applications would represent the worst-case scenario, and any accumulations of cadmium that occurred would be susceptible to detection in the field survey. In order to establish trends, however, large numbers of specimens were needed. It was also imperative that additional samples be obtained to establish the baseline levels from which comparisons could be made. A study submitted by the California Department of Food and Agriculture of the University of California in 2004, collected and analyzed a large number of soil samples 17