AEEP Statement on Cadmium

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҉ We strongly oppose any limit that is below 80 mg of cadmium for 1 kg of P2O5.

The limits proposed by the European Commission will eliminate the possibility to use most global sources

of phosphate rock, which in turn will lead to the destruction of EU phosphate fertilizer industry: loses of

production, sales, tax revenues and jobs.

҉ Any limit below 80 mg will lead to increased raw material import dependency of the EU fertilizer

industry on their direct foreign competitors, increase of EU fertilizer prices and increased dependency of

the European Union on fertilizer imports.

҉ The world is aiming for self-sufficiency in raw material and food security, the European Commission –

by imposing such limits – is taking a step towards greater dependency on imports from an increasingly

limited number of countries.

AEEP does not dispute the toxicity of cadmium nor the need to reduce its content in EU soils and food. We share this

objective. But we cannot accept strict limits, leading to job losses, that do not achieve the stated objective. Even the

European Commission admits that it cannot quantify the actual reduction of cadmium in food when even the most

stringent of the proposed limits is adopted. This means the link between the proposed limits and benefit to EU

population is speculative at best.

AEEP strongly believes that the objective to protect health and soil quality can be met by recognizing that:

❶ A limit of maximum of 80 mg/kg P2O5 will result in an average cadmium content well below 80 mg/kg P2O5,

which – in line with studies by Prof. Smolders – will lead to a decrease in accumulation of cadmium in EU soils,

which is the stated purpose of the Regulation.

❷ A limit of maximum of 60 mg/kg P2O5, to be reduced to 40 mg and 20 mg is not scientifically justified by any

available study, and is simply not feasible considering cadmium content in available phosphate rock, state of

decadmiation and phosphorus recycling technologies nor the economic dynamics of the fertilizer market.

Moreover, it will have no direct impact on dietary exposure to cadmium.

❸ A limit below 80 mg/kg P2O5 will result in all major phosphate rock exporting countries to hoard the low –

cadmium rock for domestic fertilizer production, actually decreasing – instead of increasing – low cadmium rock

available to EU producers, eventually leading to foreign phosphate producers taking over the entire EU market,

replacing EU produced fertilizers with their own production, driving EU fertilizer producers out of the EU

market, closing down EU phosphate fertilizer production, and making the European Union dependent on

fertilizer imports from a limited number of phosphate rock-producing countries.

Cadmium in

phosphate

fertilizers

ALLIA NCE EUROPÉEN NE DES EN GRA IS PH OSPH A TÉS

(AEEP) has adopted the following common position on

the limit of cadmium proposed by the European

Commission in the Proposal for a Regulation of the

European Parliament and of the Council laying down rules

on the making available on the market of CE marked

fertilizing products and amending Regulations (EC) No

1069/2009 and (EC) No 1107/2009 [COM (2016) 157)].

AEEP Statement on Cadmium

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❹ Granting oligopolistic market power to a few phosphate rock-producing countries, especially Russia, will

ultimately result in higher phosphate fertilizer prices in Europe for European farmers. AEEP members are

concerned that the cost of low cadmium phosphate rock may increase by as much as 25% based on current

experience of supplying low cadmium fertilizers to restricted markets. Farmers engaged in the production of

phosphate hungry crops such as for example brassicas, potatoes, and other root crops will be significantly

disadvantaged.

❺ There is no parity between the cadmium limits set for organic fertilizers and mineral fertilizers with

a P content below 5% P2O5 (expressed in mg per 1 kg of dry mass) and those for mineral fertilizers that have

a total phosphorus (P) content higher than 5% P2O5 (expressed in mg per 1 kg of P2O5). Given the different

units, and the variable transposition of dry mass to P2O5, which depends on P2O5 concentration in dry mass and

moisture, the limits for organic and mineral fertilizers are different. Moreover, the cadmium limit for organic

fertilizers and mineral fertilizers with a P content below 5% P2O5 does not reduce over time.

❻ Whilst organic materials are an important source of phosphorus for EU agriculture, and in limited number of EU

countries may even dominate, mineral fertilizers will continue to provide the majority of phosphorus for EU

agriculture as a whole and eliminating EU mineral phosphate fertilizers cannot be substituted by EU organic

fertilizers for the foreseeable future.

❼ There are currently no known viable decadmiation technologies available to the EU fertilizer industry on the

required scale. While some technologies exist in theory and others are used in the feed industry, the cost and

scale make those processes unviable to the fertilizer industry.

❽ Moreover, a completely unresolved issue is how to handle the resulting cadmium waste, which – in quantities

expected to be extracted by the fertilizer industry – would create a serious health and environmental hazard.

AEEP is concerned that third countries undertaking this work would not consider this aspect fully leading to

atmospheric pollution and deposition in the closed Mediterranean ecosystem. Any requirement on EU

producers to remove cadmium internally will generate cadmium waste within the territory of the EU, leading to

ecological, environmental, health and social difficulties in the EU. Therefore, apart from technological

challenges, the logistics, costs and full environmental consequences of decadmiation need to be fully analyzed.

❾ AEEP is concerned that phosphate rock producing countries will reserve the low cadmium rock for their internal

production; increasing the export of even higher cadmium rock, which will leave EU producers with no access

to the resource.

❿ AEEP is concerned that the EFSA studies used by the European Commission have not considered the role of

imported food in generating cadmium exposure to EU population. Without analysis of cadmium provided to

EU population by imported foods, imposing stringent limits on cadmium in EU fertilizers is simply unnecessary

and counterproductive.

⓫ AEEP is concerned the European Commission did not properly assess the variability of cadmium in phosphate

deposits. A maximum limit for cadmium in fertilizers will apply to every single bag produced and sold in the EU

and the industry will need to ensure every kg of phosphate used meets the requirements of the regulation.

Actually, a large number of deposits that appear to be compatible with the limits proposed by the Commission

will not be sourceable by the industry due to natural variability of cadmium in the rock.

AEEP Statement on Cadmium

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AEEP as Europe’s preeminent phosphate fertilizer alliance requests a limit of not lower than 80 mg Cd / kg P2O5 in inorganic macronutrient fertilisers until a proper risk and impact assessment is generated and technologies allowing EU fertilizer producers to achieve limits proposed by the Commission are clearly attainable.

Undersigned ………………………………………………………………………..

Paloma Pérez Sánchez General Secretary Asociación Nacional de Fabricantes de Fertilizantes (ANFFE) Spain

………………………………………………………………………

David Hopkins Managing Director CF Fertilisers UK Ltd. United Kingdom

……………………………………………………………………….

Grzegorz Zagozda CEO Luvena S.A Poland

……………………………………………………………………….

Jo Gilbertson Sector Head – Fertilisers Agricultural Industries Confederation United Kingdom

……………………………………………………………………….

Jacek Ciubak CEO FOSFAN Poland

……………………………………………………………………….

Henri Boyer Vice President - Supervisory Board Groupe ROULLIER France

………………………………………………………………………..

Mihai Anitei CEO Azomures SA Romania

……………………………………………………………………….

Mariusz Bober CEO Grupa Azoty S.A.

……………………………………………………………………….

Florence NYS General Delegate UNIFA – Union des Industries de la Fertilisation France

………………………………………………………………………………

Dr. Jörg-Ulrich Drews Managing Director Bundesverband der Düngermischer e.V. Germany

……………………………………………………………………..

Mihai Anitei President Employers’ Federation of Producers in the Chemical Industry Romania (METACHIM) Romania

………………………………………………………………………

Sławomir Litwin CEO – General Director Zakłady Chemiczne "Siarkopol" Poland

AEEP Statement on Cadmium

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Philippe Rombaut CEO AGROPOLYCHIM JSC Bulgaria

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Max Winkler Business Development Manager OMEX Agriculture Ltd United Kingdom

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Elvira Becker-Keller Managing Director Rupp Landhandel GmbH Germany

…………………………………………………………………………...

Helmut Lehner Managing Director LEHNER Agrar GmbH Germany

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Robert J. K. Ingham Fertiliser Director Glasson Grain Limited United Kingdom

………………………………………………………………………..

Dr. Pier Luigi Graziano President Associazione Italiana Fertilizzanti Italy

………………………………………………………………………………

Gustaaf Zeeman Managing Director EMT Netherland

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Michael Pater Managing Director Origin UK Operations Limited United Kingdom

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Andreas Hochgerner Managing Director

RWA Raiffeisen Ware Austria AG Austria

…………………………………………………………………………….

Jan Bröring Managing Director H. Bröring GmbH & Co. KG Germany

……………………………………………………………………………

Theo Averbeck Managing Director BBAG Vechta-Langförden eG Germany

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Cord Wierper Managing Director Friedrich Diekgerdes Landhandels GmbH Germany

AEEP Statement on Cadmium

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Holger Knief Managing Director Vechteland Agrarhandel GmbH Germany

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Hubert Ecketsberger Head of Agricultural-Department Lagerhausegenossenschaft Eferding-Grieskirchen eGen Austria

………………………………………………………………………

José Vieira President Associação Nacional de Produtores e Importadores de Fertilizantes Portugal

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