Regulation (EU) 2019/1009 – the Fertilising Products Regulation (FPR) cross-references the REACH Regulation (EC)1907/2006 but imposes stricter requirements for substances produced in amounts less than 10 tonnes per year if they are used in EU Fertilising Products. According to EBIC’s calculations, these requirements will be onerous in terms of both time and cost for manufacturers, with disproportionate effects on small companies and innovative substances that do not have a large market to offset the costs of data requirements. Furthermore, they will multiply requirements for animal testing. Yet, there is no evidence there will be any gain for health and safety, especially for substances that have already been approved for use in food and/or feed.