Fertilisers

The Fertiliser Products Regulation (EU Reg. 2019/1009 - FPR) provides for even stricter compliance circles than REACH itself.

In fact, the FPR regulation states that:

"All substances incorporated in the EU fertiliser product, on their own or in a mixture, with the exception of polymers, must have been registered in accordance with Regulation (EC) No 1907/2006 ( 2 ), in a dossier containing:

the information specified in Annexes VI, VII and VIII of Regulation (EC) No 1907/2006, and a chemical safety report in accordance with Article 14 of Regulation (EC) No 1907/2006 covering the use of the substance as a fertiliser product, unless that substance is expressly covered by one of the exemptions from the obligation to register set out in Annex IV to Regulation (EC) No 1907/2006 or in section 6, 7, 8, 9 or 10 (for magnesia only) of Annex V of the same regulation ."

This means that for almost all Categories of Constituent Materials (CMCs) the FPR provides for:

• REACH registration also for imported / manufactured substances < 1 ton/year (subject to specific exemptions, not always comparable to those provided by REACh itself)
• the use as a fertiliser product is always included in the FPR.

OUR SERVICES

• COMPLIANCE CHECK OF SUBSTANCES USED (both with reference to REACH and to the additional requirements of the FPR)
• APPLICABILITY CHECK OF EXEMPTIONS
• STRATEGY TO BE COMPLINT WITH REACH REQUIREMENTS REQUIRED BY THE FPR REGULATION, including
  • REACH REGISTRATIONS
  • CSA / CSR