Since the entry into force of Regulation (EU) 2019/1009 (FPR) on fertilising products, the CE Marking system has sought to harmonise and facilitate the free movement within the internal market of fertilising products that comply with common technical, safety and labelling criteria throughout the European Union.
The so-called ‘REACH+’ requirement, a provision of the FPR that imposes additional registration, reporting and data requirements under the REACH Regulation (EC) 1907/2006, even for substances that are manufactured or used in low volumes or in applications typically exempt from REACH requirements, has created the following obstacles:
- Extended registration and evaluation are required for certain substances or additives used in fertilisers that would have fewer requirements under the general REACH framework.
- This generates costs and administrative burdens that are much higher than in other sectors and have a multiplier effect on the cost of formulation and raw materials.
- As a result, many manufacturers find themselves in a situation where, even though their fertiliser products may meet the technical requirements of the FPR (e.g. composition, agronomic and environmental safety), they cannot obtain the CE marking without complying with this additional REACH+ requirement threshold.
In view of these difficulties identified by multiple stakeholders (manufacturers, industry associations and technical impact assessments), in 2025 the European Commission presented a proposal to amend the FPR as part of a package to simplify EU chemicals legislation.
The main reasons for proposing the removal of the ‘REACH+’ requirement are:
- Disproportionate administrative burdens and level of risk, as the REACH framework itself already covers such protection with an approach based on volume and hazard.
- Competitive burden compared to other sectors and markets, as the ‘REACH+’ requirement places fertiliser manufacturers at a competitive disadvantage compared to other sectors that use similar chemicals without equivalent burdens (detergents, paints or other consumer goods) and, even compared to non-CE marked products that operate under more flexible conditions regulated under national regulatory frameworks.
- Facilitate innovation and the circular economy by allowing greater introduction of secondary raw materials, recovered waste or innovative additives.
The proposed amendment, included in a broader legislative package to simplify chemical product regulations, contemplates:
- Removing references from the FPR that require compliance with additional REACH requirements (REACH+), avoiding the application of stricter requirements than those provided for in REACH itself.
- Ensuring that human and environmental health protection is maintained.
- Introducing complementary simplification measures such as flexibility in modifying categories of component materials and the digitisation of labelling.
At Kaeltia Consulting, we would be delighted to work with your company to obtain CE marking for your fertiliser products. Please do not hesitate to contact us.
