Public consultation to 17th May on amendment of Annex III of the Nitrates Directive to allow certain recovered nutrient products to be exempted from the 170 kgN/ha spreading limit. This limit is applicable for “manure … even in a processed form” in Nitrate Vulnerable Zones, whereas synthetic fertilisers generally have a higher spreading limit. The Commission’s proposed amendment partly takes the JRC “Renure” proposals, but allows only three eligible recovered products: ammonium salts from gas scrubbing, “mineral concentrates” from reverse osmosis, precipitated struvite. The proposed criteria also specify that the manure processing must have increased the mineral-N and that the resulting products must be of “consistent quality”.
This is presented as an “interim solution”. By limiting to these three specific recycled nutrient products, the proposal avoids the fact that the JRC Renure criteria (total N must be ≥ 90% mineral, or ratio organic carbon / total N < 3), without other criteria, would be difficult for Member States regulatory authorities to verify (would be passed by raw manure spiked with urea) and would allow scarcely processed manure and some raw manure fractions.
The proposal includes additional requirements: copper and zinc limits, pathogen limits, quality control, labelling requirements, and also requirements which would appear to require specific modifications of NVZ Action Plans wherever these recovered products are to be authorised > 170 kgN/ha: tightening land application limits for all fertilisers, prevention of air emissions, specific consideration of the authorised products in Action Plans, especially as regards Natura 2000 and drinking water abstraction. Also, authorisation of the recovered products requires that “Member States ensure that livestock numbers and manure production do not increase as a result”.
Commission Directive amending Annex III of the Nitrates Directive consultation to 17th May. Input: 4000 characters plus optional document.