Pulp and paper industry is of great importance for economic activity of Finland. Few companies in Pirkanmaa region have expressed their willingness to find beneficial end markets for their side-streams. One possibility for industrial symbioses is to utilize the side streams from pulp and paper industry in the creation of fertilizers. To coop with the problem of “organic” definition for products, this study was made in order to clarify the European and Finnish legislative environment together with legislative and regulation norms.
Definition of “organic fertilizers” in Europe
Defining organic side streams and organic products produced from those side streams, is a complicated legislative procedure. A recently adapted EU Regulation No 2019/1009 lays down the rules, definitions, and legislative procedures of introduction of new fertilizer products on the European market. The document also contains description of testing procedures, outlines the range of possible materials for fertilizer production and talks about the rules of conformity assessment. Rules and guiding definitions from EU Regulation 2019/1009 will be fully introduced from 16th of July 2022, however, articles of 4(3), 14, 42 – 47 have been applied from 15th of July 2019. This regulation works as binding and ruling document for EU members to create their own ruling legislative documents and procedures. This regulation is an example of enhanced legislative documents, since the basis of introduction of this new regulation was the necessary need of amending Regulation No 1069/2009 Animal by-products and derived products for non-human consumption and regulation No 1107/2009 concerning the placement of plant protection products on the market, and last but not least was the necessity of repealing regulation No 2003/2003 about the fertilizers production and placement on the market.
Fertilizers are regulated on both European Union and Finnish level. However, it has been stated by European Commission, that Member States of EU may regulate the use of substances in organic farming as long as the use of the fertilizer is essential to keep the fertility of the soil or meet the nutrition requirements of the specific plants and it is of plant, animal, microbial or mineral origin.
According to regulation 2019/1009 “EU fertilizing products” are referred to an accredited CE organic product. Fertilizing products is a substance, mixture, micro-organism or any other material applied or intended to be applied on plants or their rhizosphere or on mushrooms or their mycosphere, or intended to substitute rhizosphere or rhizosphere, providing plants or mushrooms with nutrients or improving their nutrient efficiency. Organic fertilizers should contain organically derived carbons and nutrients of solely biological origin. Primary and important constituent of organic fertilizers is to include one of primary nutrients, such as nitrogen, phosphorous or potassium.
Proper labelling of organic fertilizers is crucial for the approval of the product. Labelling should state the amount of primary nutrients, declare secondary nutrients, such as calcium, magnesium, sulphur or sodium. The labelling of secondary nutrients should be done with the corresponding chemical symbol. Percentage of total mass should be declared for primary nutrients such as nitrogen, phosphorus and kalium, carbon and dry mass. When along with mass percentage, producers of fertilizers should also indicate the origin of materials.
There is a demand for fertilizers and their raw materials that are made of side streams of forest industry. Fertilizer products can naturally be produced from other materials, but forest industry side streams have certain qualities that generate demand for them. Ash is generally used as inorganic fertilizer, lime mud (in Finnish meesakalkki) as liming material, bark mulch and fibre sludge as soil improvers.
Ash includes phosphorus, potassium and calcium and it is used for fertilization of forests and fields. It improves the quality of leachate water and the soil and the growth of wood 2 – 15 m3 /ha each year. In organic farming the ash must be from wood that hasn’t been treated chemically after cutting and accepted by Evira. Products that utilize side streams from the forest industry as raw material are manufactured and marketed by production sites that are approved by Evira.
Regulations regarding fertilizers on European Union level
European Commission has published a list of materials and products that can be used in organic farming as fertilizers if they meet certain requirements. For example, wood ash or wood chips can be used as long as they have not been chemically treated. If there is a specific material or side stream to be used as organic fertilizer, it must be found in this list and meet the requirements. Also mixtures of the listed products can be considered as organic fertilizers. (European Commission regulation No 889/2008 annex 1)
The European Commission shall authorise for use in organic production and include in a restricted list the products and substances, which may be used in organic farming for the following purposes: (a) as plant protection products; (b) as fertilisers and soil conditioners; (c) as non-organic feed materials from plant origin, feed material from animal and mineral origin and certain substances used in animal nutrition; (d) as feed additives and processing aids; (e) as products for cleaning and disinfection of ponds, cages, buildings and installations for animal production; (f) as products for cleaning and disinfection of buildings and installations used for plant production, including storage on an agricultural holding. (Article 16 Council Regulation (EC) No 834/2007)
Products and substances contained in the restricted list may only be used in so far as the corresponding use is authorised in general agriculture in the Member States concerned in accordance with the relevant Community provisions or national provisions in conformity with Community law. All products and substances shall be of plant, animal, microbial or mineral origin except where products or substances from such sources are not available in sufficient quantities or qualities or if alternatives are not available. (Article 16 Council Regulation (EC) No 834/2007)
The EU organic can only be used on products that have been certified as organic by an authorised control agency or body. The logo can only be used on products when they contain at least 95% organic ingredients and additionally respect further strict conditions for the remaining 5%. However, the logo can´t be used in fertilizers, even though fertilizers might be organic. Fertilizers are not covered by EU organic legislation, which means that there is no legal definition of “organic fertilizer”. Thus, for example, the EU organic logo may not be used in the marketing of organic fertilizers, even when the manure is organic. Organic fertilizer therefore means a fertilising product permitted in organic production.
Regulations regarding organic fertilizers on Finnish level
Evira’s organic control maintains an advisory list of fertilizer products suitable for organic production. Evira’s organic control department also evaluates the suitability of a fertilizer product for organic production. Anyone can submit an apply if the requirements are met.
The product information sheet for an organic fertilizer shall provide written information on the type and trade name, properties, composition, use of the fertilizer and contact details of the manufacturer and / or importer. The type names of the organic fertilizers can be found in groups 1B1 to 1B4 of the national list of type names. It is required to have a certain type name in order to get an organic status for a fertilizer. However, it is possible to apply for a new type name on Evira’s website. The list of type names also contains the minimum amounts of nutrients and other properties for each type of fertilizer preparation. Otherwise, the minimum amounts are regulated in law regulation (MMM asetus lannoitevalmisteista 24/11). Minimum declared content of secondary nutrients in weight percentages are calcium (Ca) 1.4% magnesium (Mg) 0.5% sodium (Na) 2.2% and sulphur (S) 1.0%.
The product information for organic fertilizers shall indicate all the raw materials used in the manufacture, including the type of manure and any substances added to the product. Organic fertilizers may contain organic substances or preparations of animal, plant and microbial origin. Organic fertilizer must not contain municipal or industrial sewage sludge. Substances required for granulation and stabilization, coloring matters permitted for food use and organic and inorganic substances approved as plant protection products in Finland may be added to organic fertilizers. The composition of the raw material of an organic fertilizer may differ from the permitted raw materials by one percentage point without changing the type designation of the fertilizer preparation. (MMM asetus lannoitevalmisteista 24/11)
General quality requirements are for all fertilizers as well as maximum levels for harmful substances and hygiene requirements. The general quality requirements mean that the fertilizers must be of uniform quality and suitable for their intended use and that their use must not present a risk of spreading plant and animal diseases or alien species.
Raw materials of animal origin must be processed in a processing plant approved in accordance with the requirements of By-product Regulation (EC) No 1069/2009. The approval number of the processing plant must be marked on the packaging. In the case of organic fertilizers obtained from side streams of the pharmaceutical industry, the level of antibiotic residues shall not exceed 0,1 mg / kg of dry matter as measured by HPLC.
European Commission is the governing body of EU that is responsible for setting of guidelines regarding organic products. Each member of EU has its own organic certifications bodies and branches of government that are responsible for setting of local specifications. In Finland, such governing body is Evira. Each member of EU also has its own organic audit companies that are responsible for providing guidance in regards to certification and regular check of organic labelled products. Anyone can submit an application to Evira’s list of accepted fertilizers for organic farming.
Writers: Evgenii Shornikov, Bertta Hannuksela, Eemeli Tanninen, Venla Linebaugh
Editing: Noora Markkanen
Finnish summary: Noora Markkanen
Accreditation of Fertilizer products, and general principles of CE accreditation: Regulation 765/2008
Application and accreditation of standards within the premises of EU: 1025/2012
Council Regulation (EC) No 834/2007 of 28 June 2007 on organic production and labelling of organic products and repealing Regulation (EEC) No 2092/91
Directive 2008/98/EC Waste Framework Directive
EU Ecolabel: Regulation (EC) No 66/2010
(EC) No 834/2007
Ecodesign Act (Laki tuotteiden ekologiselle suunnittelulle ja energiamerkinnälle asetettavista vaatimuksista 1005/2008, amended in 1009/2010, in Finnish)
Fertilizer regulation: 2019/1009
MMM asetus lannoitevalmisteista 24/2011
Organic food and agricultural products regulation: 2018/848