Joint call for nutrients in the EU Circular Economy Act

The signatory organisations below call for an EU Circular Economy Act, ambitious for nutrients, to forward sustainability, EU job creation and competitivity, and food system resilience, including:

• Fix objectives to reduce resource consumption alongside waste prevention and recycling objectives.
• Develop coherent policies to achieve nutrient circularity and reduce nutrient losses (Green Deal / UN Biodiversity Convention -50% target) including regulatory targets, market tools, fiscal and economic, public purchasing, border and trade…
• Improve EU coordination and implementation of Circular Economy policies: e.g. EU Circular Economy Board, information point, FAQ … Ensure coherence of all EU regulations relevant to nutrient circularity, including where possible of authorisations for different applications. Ensure coherence and clarify definitions between regulations and with waste codes.
• Address regulatory obstacles to nutrient recycling whilst maintaining where pertinent for safety and for user confidence, cradle-to-grave producer responsibility and traceability, in particular: Simplify and accelerate EU and National End-of-Waste procedures, communication, implementation,
  • Where EU End-of-Waste criteria are not defined, enable default recognition by other Member States of National and “self-declaration” End-of-Waste status, for which standards, conformity assessment or certification procedures are in place,
• • Create facilitated legal status and procedures for ‘secondary raw materials’ intended for recycling,
• • Address permitting obstacles to intake of secondary raw materials into production sites,
• • Facilitate administration of wastes for R&D and testing of recycling processes and routes.
• Develop general ‘End-Points’ for processes recognised as safe, for which authorisations should be based primarily on quality of the recycled product (product testing, process quality assurance …), not on origin of input materials, but with traceability where pertinent of the input material.
• Approved or certified European authorisations should confer EU End-of-Waste status (Food, Feed authorisations, ABP End-Points), as does the EU Fertilising Products Regulation.
• Develop policies to ensure market demand (‘pull’) for recycled nutrients (see ESPP proposals here) and to support local circular economy businesses and their operating conditions.
• Evaluate the feasibility of a recycled content target or quota and recycled content trading scheme
• for recycled phosphorus in fertilising products (inorganic and organic).
• Modernise the Animal By-Products and Animal Feed regulations to improve coherence and user understanding, facilitate and remove unjustified obstacles to circularity, whilst maintaining guarantees of safety and food-chain confidence.
• Support farmers for nutrient recycling and for use of recycled fertilisers through the CAP (see discussion in SCOPE Newsletter n°154).
• Ø Nutrients as Strategic and Critical Raw Materials (CRM):
• Implement the CRM Act art. 26 for phosphorus,
  • Define ‘Strategic’ inputs for agriculture, critical for food security and food sovereignty, parallel to ‘Strategic Materials’ defined for industry in the CRM Act.
• Implement separate collection of household organic wastes (biowaste) with nutrient recycling.
• Ensure comparable support for materials recycling as for renewable production for materials or carbon valorisation from organics. Integrate where applicable nutrient recycling into waste-to-energy and renewable energy policies: e.g. include manure digestate processing in the Renewable Energy Directive (RED II).
• Establish EU guidance and coordination of waste / ABP / regulatory status of waste-fed algae and biomass
• and extracts therefrom.
• Pollution at source: rapidly phase out or strongly restrict industrial chemicals susceptible to be an obstacle to nutrient and organics recycling, including in imported products. In particular:
  • Rapidly phase out PFAS production and use for consumer applications and for non-essential or dispersive industrial applications, with tolerances for recycling and reuse,
  • Ensure robust verification and enforcement for imports, including chemicals in imported ‘articles’.
• Integrate nutrient circularity, resource consumption reduction and phosphorus as a CRM across EU policies, including: Organic Farming, Taxonomy, Corporate Sustainability Reporting, Public Purchasing, Fiscal policies, Battery Recycling Directive, EU chemicals regulation REACH, Industrial Emissions Directive …
• Improve data to support policies, in particular for organic-based fertilising products.

Detailed proposals prepared by ESPP, after wide stakeholder consultation (including workshops in 2024 and 2025), on policies for market-pull for recycled nutrients, on nutrient recycling in the Circular Economy Act and on implementing the EU Urban Waste Water Directive phosphorus ‘reuse and recycling rates” are here: www.phosphorusplatform.eu/regulatory

Signatories:

CEWEP

AquaMinerals

European Compost Network

Netherlands Nutrient Platform

European Biogas Association

Wiener Stadtwerke GmbH

FEAD

SINFERT

SUEZ Group

Twence

P2Green

UCT – Department of Power Engineering

Institute of Soil Science and Plant Cultivation

VaLoo

Vuna Nexus

Sanitation360

Ragn-Sells

EasyMining

Politecnico di Milano

Eurofema