EBIC Calls for Return to Proportional REACH Rules
May 2025
REACH rules must be restored
EBIC has released a joint position paper urging the European Commission to restore normal REACH (Regulation (EC) 1907/2006) requirements for substances used in EU fertilising products. The call comes amid growing concerns that the current “REACH+” approach imposes disproportionate burdens on innovation and supply chains without delivering measurable safety benefits.
This joint paper has been released alongside 11 co-signatories: The Association des Producteurs Européens de Potasse (APEP); European Consortium of the Organic-Based Fertiliser (ECOFI), ESPP; – the European Sustainable Phosphorus Platform; Fertilizers Europe; Growing Media Europe, AEFA; Spanish Agricultural Nutrients Manufacturers Association; The Union of Fertilisation Industries (UNIFA); Artemis, Federchimica Assofertilizzanti – National Association of Fertilizer Manufacturers; Hellenic Fertilizers’ Association; and Afaïa.
REACH+, is the term given to the stricter application of the REACH Regulation within the Fertilising Products Regulation (FPR, EU 2019/1009), which requires substances produced in volumes under 10 tonnes per year to meet the same data and registration demands as those produced at industrial scale. These heightened requirements have been applied without a prior impact assessment or evidence of increased safety, the paper argues.
“Instead of encouraging innovation, these disproportionate requirements are deterring it—especially for substances used in very small quantities,” said Hélène Collignon, EBIC Consultant. “Many of these inputs are already approved for use in food or feed. Requiring additional chemical safety reporting for fertilising products only increases costs and complexity without any corresponding benefit.”
Major challenges for industry
The paper outlines three central concerns:
- Feasibility: Small manufacturers struggle to comply with enhanced data demands, particularly when upstream suppliers are unwilling to disclose proprietary ingredient information or upgrade REACH dossiers.
- Economic distortion: Costs to upgrade registration can increase the price of key additives by up to 540%, forcing producers to revert to less effective or less sustainable alternatives.
- Regulatory confusion: Current wording in the FPR does not clearly distinguish between component materials and unintended substances like impurities, leaving room for inconsistent enforcement.
These issues disproportionately affect small and medium-sized enterprises (SMEs) and slow the adoption of innovative products like biostimulants which can help support farmers remain competitive and sustainable.
Proposals for restoring balance
EBIC’s paper proposes several practical revisions:
- Reinstate the original REACH tonnage bands and data requirements.
- Apply stricter obligations only to substances classified as hazardous.
- Introduce a legal clarification exempting trace impurities from REACH+ obligations.
- Set a threshold of 0.1% w/w below which REACH+ requirements would not apply.
These measures, EBIC says, would uphold high safety and environmental standards while restoring legal certainty and economic viability for producers.
A case for better regulation
“These regulatory requirements undermine the EU’s goals for competitiveness, circularity, and sustainability. We, alongside other industry bodies, urge the Commission to align the Fertilising Products Regulation with the principles of Better Regulation and re-enable innovation.”
The position paper includes economic impact examples and regulatory comparisons to reinforce its case. The message in this paper is reinforced in EBIC’s new position paper calling for simplification in EU regulation, in which it stresses that the EU risks falling behind other global regions with more agile regulatory frameworks.
Help us restore REACH
Let’s work together to ensure EU Fertilising product rules are proportionate, practical, and innovation-friendly. We invite you to:
- Share the REACH position paper with your networks and relevant policymakers
- Promote it on your website or social media
- Join us in advocating for smarter, more effective regulation
If you have any questions about this article, please contact Hélène on helene@prospero.ag.