Multiple use

Multiple-Use Components

The concept of multiple-use components is well-established across various industries, including food, feed, medicine, and cosmetics. EBIC has written a position paper showing its support for multiple-use formulations (2021) complemented by another paper sent to DG GROW in September 2024 and a contribution sent to DG GROW on 31 January 2025 (which rejects the current version of the FPR FAQ).

In agriculture, this concept is crucial for innovation, allowing the combination of existing and new components to explore diverse product functions. Examples of components with multiple agricultural functions illustrate the benefits of this approach:

1. Urea: Commonly used as a nitrogen fertiliser, urea is also approved as an insecticide active substance under the Plant Protection Products (PPP) Regulation [Regulation (EC) 1107/2009].
2. Copper: Recognised as an essential plant nutrient and included in various formulations under previous fertiliser regulations (EC 2003/2003) and the FPR. Copper is also known for its fungicidal properties and is approved as an active substance under the PPP regulation.
3. Iron Sulphate: Used as both a herbicide and a fertiliser, demonstrating its multiple functionalities under both the fertiliser and plant protection regulations.
4. Mono-potassium Phosphate (MKP): As a fertiliser providing water-soluble phosphorus (P) and potassium (K), MKP is classified under Product Function Category (PFC) 1 in the FPR. It also has fungicidal effects against various diseases, occasionally being used in combination with fungicides.
5. Maltodextrin: Approved as an insecticide under the PPP regulation and used as an inert carrier substance for plant biostimulants and other products.
6. Hydrolysed Proteins: Known for their biostimulant effects, hydrolysed proteins are also approved as insecticides under the PPP regulation.
7. Phosphites (or Phosphonates): While approved as a fungicide active substance, phosphites are also used in plant biostimulants to enhance root growth and development. Despite their biostimulant effects, phosphites are explicitly banned in fertilising products under Annex I, Part II, Point 6 of the FPR.
8. Microorganisms: Mycorrhizal fungi, Rhizobium spp., and Azospirillum spp. are used as plant biostimulants and also have multiple functions, such as inducing plant defense responses. Other microorganisms, like Bacillus spp., Pseudomonas spp., and Trichoderma spp., have shown biostimulant effects and have been commercialised as plant biostimulants under national regulations, despite being approved as active substances under the PPP regulation.

What are the challenges to multiple-use concept in regulation?

The concept of multiple-use components is recognised in the FPR and related regulations. According to the Commission Delegated Regulation (EU) 2021/1768, an EU fertilising product may contain an active substance within the meaning of Article 2(2) of Regulation (EC) No 1107/2009 only if the product does not have a plant protection function within the meaning of Article 2(1) of that Regulation.

The intended use and function of the product determine its classification under the FPR. A component’s presence in a product does not automatically define the product’s function or legal framework. For instance, a component in both a plant biostimulant and a fertiliser might serve different functions depending on its formulation, application, and target crop.

EBIC supports the use of multiple-use components in various formulations to achieve different plant biostimulant, fertiliser, or plant protection functions. Innovation in the plant biostimulants industry relies on combining components in diverse ways to fulfil multiple product functions. Scientific evidence and practical experience demonstrate that components can have multiple effects and contribute to various product functions when used under specific conditions.

To ensure market predictability and foster innovation, it is essential that conformity assessment bodies, Member States, and other stakeholders respect the multiple-use concept. This includes allowing components approved as active substances under the PPP regulation to be used in plant biostimulant products, provided they comply with the FPR and national regulations.

For more information, please refer to the European Commission’s FAQ document and the relevant technical amendments to the FPR.