Pollutants in fertilizers – report commissioned by EC

Fertilizers may contain contaminants that can affect human health or the environment, including by contaminating groundwater, surface water and drinking water, accumulating in crops or livestock.

Since the Fertilizer Products Regulation (EU) 2019/1009 does not resolve all issues in this area, the European Commission has commissioned an assessment of the problem. Published in 2024 on the website of the Publications Office of the European Union, the report Contaminants in Fertilizers: Assessment of the risks from their presence and socio-economic impacts of a possible restriction under REACH , describes three separate but related objectives:

• Assessing the presence of contaminants in fertilizers;
• Identification of fertilizers of concern due to the impact of fertilizer ingredients or products on environmental degradation, including pollution of natural resources or on human health through the environment;
• Assesses the challenges of analyzing fertilizer alternatives.

The report can be downloaded from the website of the Publications Office of the European Union.

General context

Fertilizers may contain contaminants that affect human health and the environment. Such contaminants or intentionally added substances are partially addressed in the Fertilizer Products Regulation (EU) 2019/1009. This regulation sets out requirements for various categories of fertilizer products, but not all potential contaminants or intentionally added substances of concern are included. In addition, Regulation (EU) 2019/1009 does not apply to fertilizer products marketed under national regulations.

Therefore, if there is a need to eliminate certain identified risks to human health and/or the environment, it is proposed to assess whether it is possible to apply REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) in these specific cases.

In addition, activities by the European Chemicals Agency (ECHA) in the field of fertilizers (e.g., the preparation of the Annex XV dossier on calcium cyanamide restriction) have raised some questions about how best to conduct regulatory management analysis (RMOA) and analysis of alternatives (AOA).

In this context, the European Commission-Directorate General for the Environment commissioned the assessment, which has three separate but related objectives:

1. Assessment of the presence of contaminants in fertilizers and documentation of fertilizers that pose potential risks to human health and the environment;
2. Identification of potential fertilizers of concern due to the impact of fertilizer ingredients or products on environmental degradation, including pollution of natural resources or on human health through environmental pollution;
3. Assessing the challenges of analyzing fertilizer alternatives.

Report Pollutants in Fertilizers

The scope of the assessment in the report, published in 2024, includes organic, organo-mineral and inorganic fertilizers defined in accordance with Annex I of Regulation (EU) 2019/1009. At the request of the European Commission (EC), an additional risk assessment was conducted for pyrazoles, which are used as nitrification inhibitors.

The following categories of fertilizer products were not included in the survey:

• liming agents;
• soil improvers;
• growing media;
• inhibitors;
• plant biostimulators;
• Some mixtures of fertilizer products.

Conclusions of the report Pollutants in Fertilizers

The market analysis was based on a review of relevant literature and statistical sources at the international, European and national levels. The report indicates that during the period under review, France, Germany, Poland and Spain were the four main countries using mineral fertilizers, accounting for more than half of the EU’s total mineral fertilizer consumption (55.4 percent).

The results of the survey include statistics describing the EU fertilizer market and a compilation of information on the hazards and risks associated with the presence of contaminants in fertilizers.

The applications point to numerous and significant data gaps and missing statistics for market analysis. In addition, for reasons of confidentiality, data held by fertilizer manufacturers and required for the analysis of alternatives to fertilizers or substances that may have negative effects on the environment, human or animal health are not publicly available. In the absence of data, an expert opinion was used. Nevertheless, it may be challenged and considered biased.

As the report points out, there is currently insufficient data on the use of specific fertilizers for microanalysis to be possible, so in most cases the assessment has been based on macroanalysis. An example of insufficiently detailed figures is the use of calcium cyanamide, and in the case of technological additives, the information is proprietary and therefore confidential and unavailable.

Given the paucity of data, the evaluation of economic feasibility relied on a combination of qualitative and quantitative factors, varying according to the type of pollutant/fertilizer of concern.

Fertilizers of concern due to (intentionally added) ingredients

One of the objectives of the study was to identify substances that, when used in fertilizers, may pose (directly or indirectly through products) a risk to the environment or humans.

The consultation and analysis of the REACH registration dossier, indicated that the REACH list of substances used in fertilizers (PC 12 – Fertilizers) contains 1183 substances. The report indicated a list of 154 substances classified as CMR (sensitizing or carcinogenic, mutagenic or reproductive toxicity), STOT RE (repeated exposure target organ toxicity) or chronic aquatic toxicity, or as having endocrine disrupting potential and used in the agricultural sector in fertilizers in quantities exceeding 100 tons per year.

The report identifies substances of potential concern which include:

• 53 inorganic, representing the metals Ti, Mn, Fe, Co, Ni, Cu, Zn and Al and their compounds (in addition to non-metals such as ammonium compounds);
• 9 boron;
• 36 organic.

Most of the identified substances of potential concern are non-fertilizer chemicals used to improve the quality and stability of fertilizers:

• Additives to improve fertilizer performance — use of additives to control nitrification, leaching or volatilization processes;
• Additives for the preservation and stabilization of fertilizers – for example, as corrosion inhibitors and anti-caking, anti-dust and hydrophobic agents.