COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Consultative Communication on the Sustainable Use of Phosphorus
Date: 2013-07-08
Institutions: European Commission
Subjects: environmental impact, phosphorus, pollution control, security of supply, supply and demand, supply balance sheet, sustainable agriculture

EUROPEAN 
COMMISSION 

Brussels, 8.7.2013  
COM(2013) 517 final 

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS 

Consultative Communication on the Sustainable Use of Phosphorus 

(Text with EEA relevance) 

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COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS 

Consultative Communication on the Sustainable Use of Phosphorus 

(Text with EEA relevance) 

1. 

INTRODUCTION 

Phosphorus  is  an  essential  building  block  of  life.  It  is  an  irreplaceable  part  of  modern 
agriculture,  as  there  is  no  substitute  for  its  use  in  animal  feed  and  fertiliser.  The  current 
situation, involving waste and losses at every step of the phosphorus life cycle, contributes to 
concerns  about future supplies  and water and soil pollution, both in the EU and worldwide. 
With  efficient  production  and  use,  as  well  as  recycling  and  minimisation  of  waste,  major 
strides could be made towards the sustainable use of phosphorus, thereby setting the world on 
a  path  towards  resource  efficiency  and  ensuring  that  reserves  are  still  available  for  the 
generations to come. 

The purpose of this Consultative Communication is to draw attention to the sustainability of 
phosphorus  use  and  to  initiate  a  debate  on  the  state  of  play  and  the  actions  that  should  be 
considered. It is not designed with specific legislation on phosphorus in mind. This action was 
announced in the Roadmap to a Resource Efficient Europe1 and should be seen as part of the 
overall drive to improve resource efficiency in the EU and worldwide.  

Phosphorus resources are relatively abundant globally and reserves are significant. However, 
there are several factors that together mean that for the EU, the issues affecting the security of 
supply should be monitored. Firstly, within the EU, there are only small reserves of phosphate 
bearing rock. Secondly, there has been recent price volatility - in 2008, prices of phosphorus 
rock rose by 700% in a little over a year, contributing to increases in fertiliser prices. Thirdly, 
there is little scope to switch from less important uses of phosphorus, as the essential use of 
feed and fertiliser already consumes around 90% of the total mined resource. Improving the 
use of recycled phosphorus in the EU and worldwide would help safeguard the supply of this 
fundamental  raw  material  and  encourage  a  more  even  distribution  of  phosphorus  at  both 
regional  and  global  level.  Economically,  diversifying  the  supply  of  phosphate  to  the  EU 
businesses  that  depend  on  it  would  improve  their  resilience  faced  with  any  future  price 
instability and other trends that might aggravate their import dependency. 

In addition, the environmental and resource use benefits of increasing efficiency and reducing 
losses would be significant. The current use of phosphorus is inefficient at many stages of the 
life  cycle,  causing  problematic  water  pollution  and  the  waste  of  a  wide  range  of  associated 
resources.  Contaminants  such  as  cadmium  and  uranium  in  the  raw  material  may  also  cause 
health  and  environmental  problems.  Independently  of  the  total  volume  of  mined  phosphate 
available  and  the  security  of  supply  aspects, these  benefits  alone  would  justify  action  being 
taken  to  use  and  recycle  phosphorus  more  efficiently.  The  actions  taken  to  improve  the 
efficiency  of  phosphorus  use  and  recycling  would  have  a  wide  range  of  other  advantages  – 
better soil management would have climate and biodiversity benefits, for example. 

Addressing these issues is not straightforward. Regions in the EU with arable crop production 
tend  towards  a  stabilisation  in  soil  phosphorus  levels,  but  continue  to  depend  on  the 

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COM/2011/0571 final. 

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application  of  mineral  phosphate  fertilisers.  Intensive  animal  production  is  concentrated  in 
specific areas close to ports, major population centres and available labour and expertise. This 
concentration has led to an oversupply of manure into these regions, with a gradual build-up 
of the phosphate content of soils and increased risks of water pollution. Likewise, the growth 
of  major  cities  means  that  phosphorus  containing  sewage  and  food  waste  is  increasingly 
distant from the arable farms where it might be used following appropriate treatment.  

Despite this there is a great deal of scope for improving the situation. Major routes for losses 
of usable phosphorus include soil erosion and leaching, as well as inefficient use of manure, 
biodegradable  waste  and  waste  water.  Flow  analyses  from  France,  for  example,  show  that 
50% of the total phosphorus used there is lost – around 20% in wastewater, the same through 
erosion and leaching and 10% in the form of food waste and other biowaste2. The sustainable 
use  of  phosphorus  has  now  become  the  subject  of  considerable  research.  In  the  UK,  work 
undertaken for the Department of Environment Food and Rural Affairs identified phosphorus 
as a future resource risk that was significant for agriculture, and one where the Member State 
alone  could  do  little  to  address  the  risk3.  Numerous  scientific  publications  have  set  out  the 
dangers and costs of our current approach. 

Measures have already been taken at national, EU and international level, mainly to address 
water pollution problems from phosphorus and to reduce the waste of materials such as food 
or  other  biodegradable  waste  that  also  contain  phosphorus.  However,  these  actions  were 
devised with the prevention of water pollution in mind or for other policy objectives, rather 
than for the purposes of recycling and saving phosphorus. Initiatives that are directly focused 
on phosphorus efficiency and recovery remain scattered, and are rarely considered in policy 
development. An exception is Sweden, where a national interim target was established: "By 
2015, at least 60% of phosphorus compounds present in wastewater will be recovered for use 
on  productive  land.  At  least  half  of  this  amount  should  be  returned  to  arable  land".  The 
Netherlands  has  put  in  place  a  phosphate  value  chain  agreement,  in  which  a  range  of 
stakeholders have committed themselves to targets such as using a set percentage of recycled 
phosphorus  in  their  manufacturing  process4.  Germany  is  working  on  legislation  planned  to 
reduce  the  waste  of  phosphorus.  Following  the  first  European  Conference  on  Sustainable 
Phosphorus,  a  European  Phosphorus  Platform  has  been  set  up  by  stakeholders  in  order  to 
create  a  European  recycled  phosphorus  market  and  to  achieve  a  more  sustainable  use  of 
phosphorus5. 

The complete replacement  of  phosphate  mined in the EU by recycled phosphorus is neither 
feasible nor necessary in the foreseeable future. However, greater recycling and use of organic 
phosphorus where it is needed could stabilise the amounts of mined phosphate required and 
mitigate the soil contamination and water pollution issues. This will then put us on track to 
close the phosphorus cycle in the long term, when the physical limitations of the resource will 
become increasingly important. 

2. 

THE SUPPLY AND DEMAND PICTURE TO 2050 AND BEYOND 

Historically,  the  first  phosphorus  fertilisers  came  from  organic  sources  –  mainly  manure 
through mixed farming systems and then from bone meal and guano, the first major tradable 

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5 

http://www.bordeaux-
aquitaine.inra.fr/tcem_eng/seminaires_et_colloques/colloques/designing_phosphorus_cycle_at_country
_scale 
Review of the future resource risks faced by UK Business and an assessment of future viability, AEA, 
2010 
http://www.nutrientplatform.org/?p=306  
http://www.phosphorusplatform.org/  

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fertiliser  commodities.  Efficient  techniques  for  mining  and  manufacturing  fertiliser  from 
phosphate  rock  were  then  developed,  and  this  was  one  of  the  conditions  for  the  'green 
revolution'  in  agricultural  productivity  from  the  1940s  onwards.  Although  animal  manure 
remains an essential part of phosphorus supply in fertiliser (in the EU, it is a key source - 4.7 
million tonnes of manure are applied as fertilisers annually6), mineral phosphate fertiliser has 
become  the  main  source  of  phosphorus  to  crop  production  globally,  as  well  as  the  original 
source of all new phosphorus in the cycle. 
Fig 1: Historical global sources of phosphorus fertilisers7 

Historical global sources of phosphorus fertilizers (1800-2000) 

Phosphate rock 
Guano 
Human excreta 
Manure 

Year 
Phosphorus (MT/yr) 

2.1. 

The supply of phosphorus  

Current production of phosphate rock is concentrated in a limited number of countries. None 
are in the EU, with the exception of Finland where there is a small amount of production. In 
2011, the EU’s import dependency rate was around 92%8. Two thirds of the current phosphate 
rock  reserves  identified  in  the  most  recent  research  from  the  International  Fertilizer 

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Phosphorous imports, exports, fluxes and sinks in Europe, Richards and Dawson 2008 
The Story of phosphorus: Global food security and food for thought, Cordell et al, 2009 
Import dependence is calculated as "net imports / (net imports + production in EU) – methodology from 
COM(2011) 25 'Tackling the challenges in commodity markets and on raw materials' 

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Development Center (IFDC)9 on the subject come from Morocco/Western Sahara, China and 
the US, although there are many countries that have smaller reserves. In this report, the large 
new reserves identified in Morocco/Western Sahara are noted as being subject to caution. 

Consequently, it is difficult to forecast precisely the extent of supplies of phosphate rock and 
the  ability  of  these  supplies  to  meet  demand  in  the  long  term.  However,  the  best  available 
evidence  indicates  that  there  are  sufficient  supplies  for  several  generations,  and  that  new 
reserves  are  regularly  being  identified,  with  a  clear  trend  towards  a  broadening  of  the 
geographical area of future production. There will be a point at some stage in the future when 
supplies will begin to diminish, but it is not immediate.  

Some statistical information on fertiliser use worldwide is collated by the FAO, but this does 
not  cover  phosphate  rock  resources  and  reserves.  Company  phosphate  rock  reserves  are 
widely covered for commercial purposes by the Australian JORC10 code or equivalent, which 
is an industry standard for classification and harmonisation of reserve descriptions, but this is 
not designed as a basis for the compilation of national or international reserves. The reference 
source  for  such  information  has  always  been  the  United  States  Geological  Survey  (USGS), 
but between 1990 and 2010 the USGS statistics were not fully updated with information from 
non-governmental sources. As noted above, in 2010 the International Fertilizer Development 
Center  (IFDC)  reported  new,  significantly  higher  estimates  of  reserves  based  on  industry 
information,  and  in  2011  the  USGS  updated  its  resource  estimates  accordingly11.  These 
figures, and the definitions of resource and reserve from the USGS, have been used wherever 
possible in this paper. Figure 2 shows the change in the estimates of reserves. 
Fig 2: Impact of revision of phosphate rock reserves – expressed as billion tonnes P20512 

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50

40

30

20

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0

Morocco/ W.
Sahara

China

Other

2010 USGS 2010 IFDC 2011 USGS

Morocco/W. Sahara 
China 
Other 

USGS (United States Geological Survey) 
IFDC (International Fertilizer Development Center) 

The  question  of  whether  it  is  necessary  to  set  up  an  official  reporting  system  and  statistical 
follow  up  has  been  posed  in  several  academic  publications.  This  would  need  to  allow 
information to be collated in a way that respects commercial confidentiality, but at the same 
time  gives  public  bodies  and  other  stakeholders  confidence  that  they  have  accurate 
information. Integration of existing national geological survey organisations would be crucial. 

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World Phosphate rock reserves and resources, IFDC, 2010 
Joint Ore Reserves Committee - more information available at www.jorc.org 
http://minerals.usgs.gov/minerals/pubs/commodity/phosphate_rock/mcs-2011-phosp.pdf  
Adapted from a presentation by Blanco, 2011 

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Organic sources of phosphorus are often heavy and voluminous materials such as manure or 
sewage sludge that cannot easily be transported over long distances. However, supplies could 
be better distributed at the regional level, and availability of the material could be improved 
both quantitatively and qualitatively. This issue is further explored in section 4.  

2.2. 

Increasing demand for fertiliser to feed the world 

FAO  forecasts  of  the  global  demand  for  fertiliser  suggest  that  world  use  of  fertilisers  will 
continue to expand. They indicate projected increases for phosphate as a fertiliser nutrient of 
up  to  43.8  million  tonnes  per  annum  in  2015  and  to  52.9  million  tonnes  in  203013.  These 
figures are based on the assumption that the undesirable situation of very low fertiliser use in 
some  developing  countries,  especially  in  Sub-Saharan  Africa,  is  maintained.  As  far  as 
phosphorus is concerned, current world consumption is around 20 million tonnes per annum. 
Demand for phosphorus in feed is also predicted to rise, driven by large increases in animal 
production14. 

In the longer term, a number of factors indicate that demand is likely to continue to grow. The 
world population is predicted to rise to more than nine billion people by 2050. This, combined 
with changes in dietary habits, has led the FAO to predict a demand for 70%15 more food by 
that date, if the current unsustainable trends persist. In turn, this is likely to mean more land in 
agricultural  production,  and/or  greater  intensification  on  existing  farm  land.  This  will  then 
drive demand for fertiliser.  

The increase in demand for fertilizer will also be driven by the increase in global production 
of biofuels. 16. In 2007/8 fertilizer use associated with the production of biofuels was already 
estimated at 870,000 tonnes of phosphate per annum.17.  

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Forecasting Long-term Global Fertiliser Demand, FAO, 2008. 
Rosegrant et al, 2009 for predictions in growth of animal numbers 
New assessments may indicate values closer to 60% - see NPK foresight study by the JRC, 2012 
The Impact of First-Generation Biofuels on the Depletion of the Global Phosphorus Reserve, Hein and 
Leemans, 2012 
Medium  Term  Outlook  for  Global  Fertilizer  Demand,  Supply  and  Trade  2008-2012  Heffer  and 
Prud'homme, 2008 

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2.2.1.  Global imbalances in phosphorus use 
Fig 3: Global map of agronomic P imbalances for the year 200018 

P deficits (kg P ha-1 yr-1) 

Lowest quartile (0 to -0.8) 
Lower-middle quartile (-0.8 to -1.9) 
Upper-middle quartile (-1.9 to -3.2) 
Top quartile (-3.2 to -39.0) 

P surpluses (kg P ha-1 yr-1) 

Lowest quartile (0 to 2.5) 
Lower-middle quartile (2.5 to 6.2) 
Upper-middle quartile (6.2 to 13.0) 
Top quartile (13.0 to 840.0) 

Figure  3  is  the  result  of  a  study  that  seeks  to  calculate  phosphorus  balances  worldwide.  It 
shows  that  there  are  many  developing  countries  where  there  are  significant  phosphorus 
deficits19.  These  levels  are  below  what  would  be  necessary  to  maintain  the  long-term 
productivity  of  soils  and  to  allow  the  improved  crop  yields  that  will  be  necessary.  Some  of 
this additional requirement could come from better use of local organic sources, but it is likely 
that much of this demand will have to be supplied by phosphate rock. As the growth in the 
human  population  is  forecast  to  be  in  the  developing  world,  the  greatest  need  for  increased 
phosphate  fertiliser  will  be  in  those  areas  which  currently  have  the  lowest  soil  phosphate 
levels.  

Increases in demand  at world level will be  partially slowed by decreases in phosphorus use 
around  areas  of  intensive  animal  production,  where  soils  now  contain  more  available 
phosphorus than is required for crop production, as a result of excess manure spreading (parts 
of  the  EU,  US,  China).  Such  decreases  may  be  due  to  economic  factors,  since  extra 
phosphorus on saturated land brings no benefit for the crop, or to environmental regulations 
aimed at tackling water pollution. However, it should be noted that, if animal production in 
these areas is not reduced, the phosphorus demand via animal feed will remain the same. 

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Agronomic P imbalances across the world's croplands, Macdonald et al, 2011 
See also http://www.africafertilizer.org/ 

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2.3. 

The balance between supply and demand 

Since  industrial  fertiliser  production  began,  the  constant  increases  in  demand  for  fertiliser 
have  been  consistently  matched  by  the  increasing  volumes  of  phosphate  rock  being  mined. 
There have been occasional blips due to wider geopolitical events, notably when the collapse 
of the Soviet Union in the 1990s led to a temporary fall in the global demand for fertiliser, but 
otherwise the rise has been continual. 

2.3.1.  The 2008 price spike 

From 2007-8 the price of phosphate rock went up by over 700% in a fourteen-month period. 
In  2008,  China  imposed  an  export  duty  of  110-120%  on  phosphate  rock,  which  was  then 
reduced in several stages to the level of 35%, which is still applied today. Global operating 
capacity  for  phosphoric  acid  peaked  at  close  to  the  maximum  possible.  This  high  price 
attracted considerable interest from the press and stakeholders. The spike was followed by a 
collapse during the global recession, although prices have been rising again since the start of 
2011.  Price  rises  for  phosphate  rock  are  essentially  a  function  of  supply  and  demand,  with 
increased demand from biofuel crops being one factor. They also mirror food prices and may 
also  be  a  minor  contributing  factor  to  rises  in  food  prices,  although  they  are  much  less 
significant than oil prices in that regard. 

2.3.2.  The discussion around 'peak phosphorus' and security of supply 

Based  on  the  USGS  statistics,  which  were  the  only  publicly  available  source  at  that  time,  a 
number of academic and other commentators predicted that “peak phosphorus”, i.e. the point 
in  time  when  global  production  of  phosphate  rock  would  reach  its  peak  and  would  start  to 
decline,  might  happen  in  the  medium  term20,  or  may  even  have  passed21.  Since  then,  the 
USGS  has  updated  its  reserve  estimates  and  these  calculations  are  no  longer  relevant.  In 
addition,  a  number  of  academic  commentators  have  argued  that  examining  reserves  using  a 
Hubbert  curve22  is  essentially  inappropriate  for  phosphorus,  particularly  due  to  the  fact  that 
phosphorus can be recycled. They also argue that as the price goes up, other resources will be 
found, even if some of these sources are more complex to mine or contain more impurities.  

Whilst peak phosphorus due to phosphate rock depletion seems unlikely to be an issue for the 
coming generations, the security of supply issues that were raised by that discussion remain 
relevant. Although new mines and new technologies – notably seabed resources – are being 
developed and new reserves are being reported, other sources are diminishing. Under current 
technological and environmental conditions, mines in the US may not have a lifetime much 
beyond fifty years or so. The lifetime of China’s internal production is not clear, but given the 
huge  internal  needs  there  seems  little  likelihood of  this  source  being  available  for  export  in 
significant quantities in the future.  

2.3.3.  Raw materials Initiative 

In 2010 a European Commission Working Group assessed 41 raw materials with the aim of 
identifying which materials are of critical importance for the EU. After the WG evaluated the 
economic importance, supply risk and environmental impact of each and every material, the 
Commission adopted a list of 14 raw materials that it deemed as critical. This assessment will 
take place again in 2013 and will include an evaluation of phosphate rock. 

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A rock and a hard place – peak phosphorus and the threat to our food security, Soil Association, 2010 
'Peak P' what it means for farmers, Déry and Anderson, 2007 
A  Hubbert  curve  is  an  approximation  of  the  production  rate  of  a  resource  over  time,  first  used  to 
predict peak oil, and since applied to estimate depletion of other resources (definition from Wikipedia). 

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2.3.4.  Quality of the phosphate rock reserve 

More  than  the  size  and  location  of  reserves,  it  is  the  heavy  metal  content  of  the  remaining 
deposits  that  is  a  potential  cause  for  concern.  Rock  phosphate  is  generally  contaminated  to 
some degree by cadmium, which is a toxic element. The phosphate rocks which are mined in 
Finland,  Russia  and  South  Africa  are  igneous  and  have  very  low  cadmium  contents 
(sometimes  below  10  mg  cadmium/kg  P2O5).  In  contrast,  those  found  in  North  and  West 
Africa  and  in  the  Middle  East  are  sedimentary  and  generally  have  much  higher  cadmium 
levels,  above  60  mg  cadmium/kg  P2O5  in  the  worst  cases.  The  need  to  control  the 
contamination  of  soil  with  cadmium  from  fertilisers  (section  3.3)  means  that,  if  cleaner 
sources  are  depleted,  the  cost  of  producing  fertiliser  that  meets  soil  protection  standards  is 
likely to rise, or higher standards in the EU will lead to material with higher cadmium content 
being sold elsewhere. Inefficient use of clean reserves will bring us more rapidly to this point, 
unless decadmiation23 technologies become economically viable. 

Q1  –  Do  you  consider  that  the  security  of  supply  issues  for  the  EU  in  relation  to  the 
distribution  of  phosphate  rock  are  a  matter  of  concern?  If  so,  what  should  be  done  to 
engage with producing countries in order to tackle these issues? 

Q2 – Is the supply and demand picture presented here accurate? What could the EU do 
to  encourage  the  mitigation  of  supply  risks  through  i.e.  the  promotion  of  sustainable 
mining or the use of new mining technologies? 

Q3  –  Do  you  consider  that  the  information  on  the  worldwide  supply  and  demand  of 
phosphate  rock  and  fertiliser  is  sufficiently  available,  transparent  and  reliable?  If  not, 
what would be the best way to obtain more transparent and reliable information at EU 
and global level? 

3. 

ENVIRONMENTAL IMPACTS THROUGHOUT THE PHOSPHORUS CYCLE 

Sustainable  use  of  phosphorus  goes  wider  than  the  issues  around  that  one  element.  When 
phosphorus  is  wasted,  the  energy,  water  and  other  resources  contributing  to  its  production 
cycle are wasted along with it. In addition, phosphorus ending up in water bodies causes its 
own environmental problems, notably in the shape of eutrophication. Figure 4 shows the scale 
of inefficiency along the chain. 

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Removal of cadmium from the processed product 

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Fig 4: Losses along the phosphorus chain 24 

P in earth crust = 4x1015 tonnes 
Phosphate rock resources 
Phosphate rock reserves = 2x109 tonnes P 

Sufficient concentration (%P) 
Identified and physically accessible 
Economically, energetically and geopolitically feasible 
Available for fertilizer (minus substantial mine-to-field losses) 
Plant available (P in soil solution) 
Available for food (minus substantial field-to-food losses) 
Available for consumption (minus food waste) 

3.1.  Mining, processing and transformation into fertiliser or feed 

Modern  phosphate  mining  is  mostly  carried  out  in  open  cast  mines.  This  type  of  mining 
requires large areas of land25. As well as the land that is mined, land is also needed for spoil 
heaps and for clay settling ponds. The quantities of total solid waste produced can be high, 
but they vary significantly between plants – one study reports findings where, for one tonne of 
phosphoric acid produced, 9.5 tonnes of phosphate ore are required and 21.8 tonnes of diverse 
wastes and 6.5 tonnes of tailings are produced26. 

Phosphoric acid plants also produce large quantities of a by-product called phosphogypsum. 
In some countries phosphogypsum is stored in large stacks due to regulation of radioactivity 
levels or because the alternatives (natural gypsum and flue gas gypsum) are more competitive. 

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Sustainable use of phosphorus, Cordell et al, 2010 – figures from date of publication 
Florida phosphate mining disturbs about 5,000 – 6,000 acres annually, at 9,000 tonnes US per acre of 
land mined  
Global phosphorus flows in the industrial economy from a production perspective, Villalba et al, 2008 

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In  a  few  countries  such  as  Brazil  and  China,  however,  it  is  increasingly  being  used  in 
construction and in agriculture27.  

The  mining  and  processing  of  phosphate  rock  also  uses  a  great  deal  of  water.  Although 
modern mines can reuse as much as 95% of the water taken, this level of efficiency is by no 
means universal. In addition, there can be a risk of spills or seepage of highly acidic process 
water,  notably  from  pools  on  the  phosphogypsum  stacks,  and  this  can  contaminate  aquatic 
ecosystems.  As  phosphate  rock  deposits  are  often  located  in  water  deficient  regions,  water 
supply can be a significant limiting factor in the development of phosphate mining. 

The mining process is also energy intensive. The only comprehensive surveys of energy use 
across  the  industry  are  now  quite  dated,  but  they  give  figures  of  2.4  GJ  of  primary  energy 
required per tonne of final product – this amount would be double if transport to Europe were 
taken into account28. Recent efficiency gains in phosphate mines are likely to have improved 
this situation, which in any case varies from mine to mine. Each year, millions of tonnes of 
rock and fertilisers are transported worldwide, with the environmental transport costs that this 
entails.  

3.2.  Water pollution from agriculture and waste water 

Excess  phosphorus,  mainly  from  intensive  agriculture  and  horticulture  is  a  major  cause  of 
eutrophication of lakes and rivers. Uncontrolled or poorly controlled waste water from human 
excreta and other household uses, as well as industrial pollution, also contributes significantly 
to these problems. Mineral fertiliser is less often the cause of the regional imbalances that are 
symptomatic of these problems, but can be a contributing factor in some regions. 

Soil  erosion  can  carry  significant  amounts  of  soil-bound  phosphorus  into  surface  water.  A 
recent model of soil erosion by water constructed by the JRC has estimated the surface area 
affected in EU-27 at 1.3 million km²29. Almost 20% of this affected area is subjected to a soil 
loss  in  excess  of  10  tonnes  per  hectare  per  year.  Run-off  from  recently  applied  fertiliser  or 
manure  can  contribute  further  to  water  pollution.  Loading  soils  with  very  high  levels  of 
phosphate will generally not impair crop growth, but may affect plant biodiversity in natural 
ecosystems, while increased migration of phosphates to nearby bodies of water will also upset 
the  biological  balance.  In  addition  to  indirect  losses,  manure  is  still  directly  discharged  into 
watercourses or into the sewage system in some parts of the world, adding to pollution from 
urban  waste  water.  While  soil  erosion  is  the  main pathway for phosphates to enter water in 
sandy soil areas or where there are slopes without vegetation, leaching into surface water can 
also be a significant factor in saturated areas. 
According to the SOER 201030, agricultural emissions of phosphorus to freshwater exceed 0.1 
kg of phosphorus per hectare per year across much of Europe, but reach levels in excess of 1.0 
kg P/ha/year in hotspots. As a consequence, several marine and coastal waters across the EU 
have high or very high concentrations of phosphorus. Preliminary results of the assessment of 
river  basin  management  plans31  show  that,  in  82%  of  river  basins,  agriculture  is  causing 
significant  phosphorus  pressure  on  watercourses.  Some  studies32  have  argued  that  we  have 
already exceeded the planetary boundaries for freshwater pollution by phosphorus. 

27 

28 

29 
30 
31 
32 

It should be noted that natural radioactivity levels in phosphate rock can differ widely, depending on the 
geology of the mine  
Materials flow and energy required for the production of selected mineral commodities, Kippenberger, 
2001 (but the energy figures themselves date from 1994) 
The implementation of the Soil Thematic Strategy and ongoing activities, COM(2012) 46 final 
The European environment - state and outlook 2010: http://www.eea.europa.eu/soer 
Based on 38 River Basin Management Plans 
Reconsideration of the planetary boundaries for phosphorus, Carpenter and Bennett 2011 

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Losses of phosphorus and other nutrients via these routes and due to wastewater pollution can 
cause an increase in the growth of plants and algae. This results in eutrophication, which can 
then lead to an  imbalance between the processes of plant/algal  production and  consumption 
which has adverse effects on species diversity and the suitability of water for human use. It 
can also cause very severe algal blooms, some of which consist of harmful species that cause 
the death of fish and other marine fauna and which – once decomposed – can poison humans 
and  animals  due  to  emissions  of  hydrogen  sulphide.  Such  a  situation  takes  years  to  remedy 
even when the source of pollution has been eliminated, because phosphorus becomes part of 
the  sediments  which  are  subject  to  frequent  disturbance,  triggering  repeats  of  the 
eutrophication process. 

3.3. 

Soil contamination 

The  contaminant  present  in  phosphate  fertilisers  (unless  removed  by  decadmiation 
technologies) that is currently of most concern is cadmium, although other heavy metals may 
also  need  monitoring.  Once  present  in  soil,  cadmium  cannot  be  easily  removed,  but  can 
migrate  and  accumulate  in  plants.  Certain  plants  (sunflowers,  colza,  tobacco,  etc.)  tend  to 
accumulate larger amounts of cadmium.  

In  2002,  the  Commission  asked  the  Scientific  Committee  on  Toxicity,  Ecotoxicity  and  the 
Environment (SCTEE) for its opinion33 on the likelihood of an accumulation of cadmium in 
soils resulting from the use of phosphate fertilisers. Based on risk assessment studies carried 
out by eight EU Member States (and Norway) and additional analysis, the SCTEE estimated 
that phosphate fertilisers containing 60 mg cadmium/kg P2O5 or more are expected to result in 
cadmium  accumulation  in  most  EU  soils,  whereas  phosphate  fertilisers  containing  20 mg 
cadmium/kg  P2O5  or  less  are  not  expected  to  cause  long-term  soil  accumulation  over  100 
years if other cadmium inputs are not considered. Some soils naturally contain high levels of 
cadmium, and therefore a more cautious approach is required in those areas. 
In terms of health impacts, the EU Risk Assessment Report34 on cadmium and cadmium oxide 
was  issued  in  December  2007.  It  found  that  the  major  risk  of  cadmium  is  kidney  damage 
through  food  consumption  and  smoking.  The  Risk  Reduction  Strategy  for  cadmium  and 
cadmium oxide recommended measures to reduce cadmium content in foodstuffs, in tobacco 
blends  and  for  phosphate  fertilisers,  taking  into  account  the  range  of  different  conditions 
throughout the EU35. This was confirmed by the risk assessments on cadmium in food carried 
out by the European Food Safety Authority (EFSA) in 200936 and 201137, as well as by the 
conclusions of the Joint FAO/WHO Expert Committee on Food Additives (JECFA)38 in 2010. 
So far, the preparatory work for most of these measures is not finished, but risk management 
decisions have been taken based on the maximum residue levels in feed and food. 

Soil and groundwater contamination by uranium – mainly from natural background presence, 
but  possibly  exacerbated  by  the  presence  of  uranium  in  phosphate  fertilisers39  –  has  been 
reported  in  areas  with  sandy  soil  in  Germany,  with  consequences  for  the  processing  of 
drinking water in some cases. This contamination could result in extra precautions and costs 
in the areas of drinking water and agricultural production. 

33 
34 
35 
36 
37 
38 

39 

http://ec.europa.eu/health/ph_risk/committees/sct/documents/out162_en.pdf. 
http://esis.jrc.ec.europa.eu/doc/risk_assessment/REPORT/cdmetalreport303.pdf  
OJ C 149, 14.06.2008, p. 6 
EFSA Journal (2009) 980, 1-139; http://www.efsa.europa.eu/en/efsajournal/pub/980.htm 
EFSA Journal (2011); 9(2):1975; http://www.efsa.europa.eu/en/efsajournal/pub/1975.htm 
WHO  Food  Additives  Series  64,  73rd  meeting  of  the  Joint  FAO/WHO  Expert  Committee  on  Food 
Additives (JECFA), Wold Health Organisation, Geneva, 2011 
Rock phosphates and P fertilizers as sources of U contamination in agricultural soils, Kratz and Schnug, 
2006 

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Q4 – How should we handle the risk of soil contamination linked to phosphorus use in 
the EU?  

4. 

POTENTIAL FOR AND OBSTACLES TO A MORE EFFICIENT USE OF PHOSPHORUS  

The flow analyses and research undertaken show that there are a number of key points in the 
phosphorus use cycle where significant quantities are currently being lost. Yet there are also 
techniques that can recover phosphorus or improve the efficiency of its use40. When prices of 
phosphate rock and its derived products reached a peak in 2008, a number of new alternative 
sources of recycled phosphorus became economically interesting. Since then, prices appear to 
have reached a new plateau at 200 dollars a tonne. Much of the previous analysis of the cost 
efficiency of phosphorus recycling dates from before the price rises in phosphate rock and is 
therefore  now  out  of  date.  Moreover,  as  the  technology  for  the  processing  of  the  most 
promising  sources  of  recycled  phosphorus  improves  and  efficiencies  of  scale  kick  in,  their 
costs  come  down.  Aside  from  the  price  issues,  the  major  economic  advantage  of  using 
recycled phosphorus is in terms of resilience – consistent flows, sourced locally, and without 
the price volatility of phosphate rock. 

Modelling undertaken in the context of resource efficiency suggests that the global increase in 
the  use  of  phosphorus  fertilisers  from  primary  sources  could  be  limited  to  11%  by  2050 
against  a  business-as-usual  scenario  of  40%41.  Economic  modelling  of  the  US  situation 
suggests  that,  if  prices  of  mineral  fertilisers  go  up  and  taxation  is  adjusted  to  cover  even  a 
small part of the externalities of excess phosphorus use, the use of phosphorus from recycled 
sources would spread to large areas of arable land42. Work done on the JRC project on NPK 
foresight has helped contribute to the knowledge base on likely developments43.  

Figure 5 shows one analysis of the flows and losses at a global level – in some respects, the 
EU picture will be significantly different, particularly as regards crop and post harvest losses. 
Other  global,  national  and  regional  analyses  can  still  differ  sharply,  and  some  of  the  losses 
announced are contested. Academic work is in progress to try and improve this global picture. 

40 
41 
42 
43 

A number of these techniques are set out at http://www.phosphorus-recovery.tu-darmstadt.de  
EU Resource Efficiency Perspectives in a Global Context, PBL, 2011 
Shakhramanyan et al, Working Paper, 2012. 
http://eusoils.jrc.ec.europa.eu/ESDB_Archive/eusoils_docs/other/EUR25327.pdf 

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Fig  5:  Global  phosphorus  flows  through  the  agricultural,  food  and  sewage  systems 
(figures rounded) 44 

Global phosphorus flows, 2000 
Million tonnes P per year 

Phosphate rock reserve 
Mined phosphate rock 
Fertilizer 
Feed additives 
Losses 
Arable soils stock +5.5 
Grassland soils stock -0.5 
Detergents  
Non-food uses/losses 
Food waste 
Non-sewage 
Harvest crops 
Human food 
Excretion 
Sewage 
Crop residues 
Livestock 
Excretion 
Treatment 
Sludge 
Surface water 

Q5 - Which technologies have the greatest overall potential to improve the sustainable 
use of phosphorus? What are the costs and benefits?  

44 

Global phosphorus flows through the agricultural, food and sewage systems, Van Vuuren et al. (2010) 

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Q6 – What should the EU promote in terms of further research and innovation into the 
sustainable use of phosphorus? 

4.1.  More efficient extraction, processing and industrial use 

Previous academic analysis of the efficiency of phosphate mining has shown that up to one 
third of the total rock can be lost through mining, processing and beneficiation operations45, 
and  a  further  10%  through  transportation  and  handling46.  However,  recent  investments 
following the price rises have led to significantly improved efficiency in some mines. There 
are numerous technological innovations being applied or under development that avoid waste 
of product or by-product, produce cleaner product, or save energy, water or chemicals. Higher 
prices and depletion of the optimal reserves are most likely to drive these improvements, but 
EU consumption requirements (particularly in terms of decontamination) may also play a part. 
Work  is  also  continuing  on  improving  fertiliser  safety  quality  and  transparency  of  fertiliser 
content via labelling, notably in the context of the revision of the Fertiliser Regulation. The 
recently adopted revision of the Detergents Regulation restricting the use of phosphates and 
other phosphorus compounds in consumer laundry and automatic dishwasher detergents will 
also  help  to  reduce  non-essential  use  and  to  limit  the  discharge  of  phosphorus  originating 
from detergent use. 

4.2.  More efficient use and conservation in agriculture  

Efficient  crop  production  means  having  enough  plant-available  phosphorus  in  the  soil  (the 
critical level) to meet the requirements of the plant throughout its development, but no more47. 
Within  the  EU,  several  initiatives  have  already  led  to  more  efficient  phosphorus  use  and 
reductions in phosphorus losses in agriculture. These include the codes of practice and action 
programmes  under  the  Nitrates  Directive48,  and  agri-environment  schemes  under  the  Rural 
Development  policy.  The  increased  interest  in  soil  protection  fostered  by  the  thematic 
Strategy  for  Soil  Protection,  together  with  the  soil  part  of  the  good  agricultural  and 
environmental  conditions  (GAEC)49  within  cross-compliance  in  the  Common  Agricultural 
Policy,  are  contributing  to  improved  soil  management  and  to  a  reduction  in  the  decline  and 
erosion of organic matter, both of which play a part in phosphorus loss. However, there still 
remains  considerable  scope  for  further  improvements  in  phosphorus  use  and  efficiency  at 
farm  level50.  This  includes  'precision  farming'  techniques,  such  as  manure  injection  and 
incorporation of inorganic fertiliser, although testing of field levels of phosphorus and manure 
content is also important to ensure that the right amount of fertiliser is used in the right place 
and at the right time – thus raising phosphorus to the critical level. Greater efforts to reduce 
erosion by wind and water, as well as increased crop rotation, would help in general to reduce 
losses of soil and the phosphorus it contains. The use of fertilisers in horticulture can also be 
improved, in particular through closed systems.  

Some new technologies that are either already on or coming on to the market could increase 
the efficiency of fertilizers, notably through enzyme-based techniques, such as innovations to 

45 
46 
47 
48 

49 

50 

Kippenberger 2001  
Phosphate rock, Lauriente 2003. 
Efficiency of soil and fertilizer phosphorus use, Syers, et al, 2008 
Council Directive 91/676/EEC concerning the protection of waters against pollution caused by nitrates 
from agricultural sources 
GAEC, Good Agricultural and Environmental Conditions, is a list of standards designed to ensure that 
all agricultural land is maintained in good agricultural and environmental conditions and is part of the 
cross-compliance system. 
Improved phosphorus use efficiency in agriculture: A key requirement for its sustainable use, Schroder 
et al, 2011 

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improve root development and the use of microbial inoculants, all of which are designed to 
improve the efficiency of phosphorus uptake by the plant.  

Techniques  to  improve  phosphorus  efficiency  within  animal  production  have  become  more 
widespread.  The  phosphorus  content  in  diets  in  particular  has  been  adapted  to  the  needs 
during the different life stages of the animals ("phase feeding") and the phytase enzyme has 
been  added  to  feed  for  mono-gastric  livestock.  These  approaches  are  contributing  to  a 
lowering  of  the  phosphorus  content  of  animal  feeds  because  the  animals  process  the 
phosphorus  more  efficiently.  However,  these  approaches  are  not  yet  being  fully  exploited. 
New phytase enzymes are steadily being authorised as feed additives in the EU. 

Costs and practicality of use are the main obstacles standing in the way of a wider take-up of 
these  technologies.  While  use  of  the  phytase  enzyme  is  already  widely  accepted,  other 
technologies will require robust investigation – including dedicated field trials – if they are to 
become standard. 

In  this  respect,  the  Research  Framework  Programme  for  2014-2020  and  forthcoming 
European Innovation Partnership for agricultural productivity and sustainability could play an 
important  role  in  developing  new  solutions  for  a  more  efficient  use  and  conservation  of 
phosphorus in agriculture. 

Q7 – Do you consider that the available information on the efficiency of phosphorus use 
and  the  use  of  recycled  phosphorus  in  agriculture  is  adequate?  If  not,  what  further 
statistical information might be necessary? 

Q8  –  How  could  the  European  Innovation  Partnership  on  "agricultural  productivity 
and sustainability" help to take forward the sustainable use of phosphorus? 

4.2.1.  Better use of manure 

During  the  past  decade,  the  implementation  of  the  Nitrates  Directive  has  been  a  driver  for 
much better manure management. There has been a surge of interest in manure processing and 
in  transforming  the  phosphorus-rich  solid  part  of  processed  manure  into  a  saleable  product 
outside its area of production, where fields are often saturated with nutrients. Although slurry 
manure starts off with a water content of about 95%, processing can reduce the volume of the 
solid  fraction  to  about  30%  of  the  original  slurry  manure,  but  a  number  of  obstacles  to 
exporting processed manure such as cost (transport, energy) – still remain. Acceptability by 
receiving farms is also still an issue.  
For  15  out  of  22  Member  States51,  the  main  supply  of  phosphorus  to  agricultural  land  is 
already in the form of recycled phosphorus in manure. However, in the other Member States, 
and in many regions across the EU, the opportunities for greater processing of manure and its 
use in place of mineral fertilisers are not yet being fully exploited.  

Q9  –  What  could  be  done  to  ensure  better  management  and  increased  processing  of 
manure  in  areas  of  over-supply  and  to  encourage  greater  use  of  processed  manure 
outside of these areas? 

4.3. 

Potential gains related to prevention and recovery of food waste 

Any reduction of food waste at the production and consumption stages would reduce the need 
to  introduce  new  phosphorus  into  the  system  from  the  rock  resource.  The  situation  around 
food waste has been exhaustively studied. Every person in the EU wastes on average 180 kg 
of food every year52. How we produce and consume food, the type and quantity of food we 

51 
52 

no data available for Cyprus, Luxembourg, Bulgaria, Romania and Malta 
EU Preparatory Study on food waste in EU 27; BIO IS, October 2010 

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eat  and  how  much  of  it  we  waste  has  a  significant  influence  on  the  sustainable  use  of 
phosphorus,  which  makes  this  an  area  where  there  is  great  potential  for  improvement.  This 
topic  will  be  further  explored  in  a  Communication  on  sustainable  food,  which  is  due  to  be 
adopted in 2013. This was announced in the Resource Efficiency Roadmap which has set a 
target to halve the disposal of edible food waste in the EU by 2020.  

As  well  as  preventing  food  waste,  we  could  also  make  better  use  of  the  food  waste  that  is 
generated.  Currently,  large  quantities  of  food  waste  and  biodegradable  waste  in  general  are 
incinerated,  and  often  the  phosphorus  in  the  ash  is  not  reused.  In  addition,  significant 
quantities  of  phosphorus  are  also  lost  to  landfill.  The  Landfill  Directive53  requires  Member 
States, by 2016, to gradually reduce the land filling of municipal biodegradable waste to 35% 
of  the  total  amount  of  such  waste  produced  in  1995.  The  Directive  has  led  to  a  very 
significant  increase  in  the  recycling  of  bio-waste  to  produce  biogas  and  nutrients  for  soil 
improvement and agriculture, but does not always direct the resource to the highest value use.  

Using biodegradable waste in the form of compost, digestate or ashes from green or kitchen 
waste would recycle significant quantities of phosphorus along with other nutrients. The take-
up  of  this  waste  stream  is  currently  hindered  by  highly  fragmented  approaches  to  the 
appropriate use and quality standards for biodegradable  waste  across  the  EU.  End  of  Waste 
criteria, defining when biodegradable waste ceases to fall under the waste definition, are being 
developed at Community level. This will help to remove legal obstacles.. The revision of the 
Fertiliser Regulation due for adoption in 2013 will also be significant. An opportunity will be 
examined in this context to further harmonise the access to the EU market for biodegradable 
wastes fulfilling these End of Waste criteria as they might then be used as input materials for 
organic fertilisers and soil improvers which will be proposed for extension of the scope in the 
future Fertilisers Regulation. 

In addition to this, there are a number of waste streams from agriculture and by-products from 
food production that could recycle significant quantities of phosphorus, if properly managed. 
For  some  of  these  resources,  public  health  problems  and  the  actions  needed  to  tackle  them 
have made this process less efficient in recent years. One notable example is meat and bone 
meal and processed animal protein, given that phosphorus is mainly concentrated in the bone 
structure. Although some meat and bone meal is incinerated and the ashes are used either as 
fertiliser,  directly  as  a  form  of  soil  improver,  or  in  phosphorus  production54,  much  of  the 
phosphorus  is  simply  wasted.  Processed  animal  protein  is  authorised  for  use  in  feed  and 
organic fertilisers and is available on the market in significant quantities. It may be possible to 
refine  the  legal  framework55  governing  the  uses  of  such  material  if  other  safe  uses  are 
identified. 

Q10 – What could be done to improve the recovery of phosphorus from food waste and 
other biodegradable waste? 

4.4.  Waste water treatment 

Waste  after  human  consumption  is  inevitable,  but  there  are  a  number  of  technologies  that 
enable recovery of the phosphorus from waste water treatment plants. These techniques have 
developed significantly over recent years, with the setting up of several pilot projects and now 
commercial scale operations in western and northern Europe. 

53 
54 
55 

Council Directive 1999/31/EC on the landfill of waste.  
Thermochemical processing of meat and bone meal, a review, Cascarosa et al, 2011 
Animal by-products legislation and Transmissible Spongiform Encephalopathies (TSE) legislation. 

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Although  removal  of  phosphorus  from  waste  water  is  a  requirement  under  Article  5  of  the 
Urban Waste Water Treatment Directive56, this does not require extraction of the phosphorus 
in a useable form. One particular feature of the Directive is that it allows the flocculation of 
the  phosphorus  using  iron,  which  produces  a  strongly  bound  compound  from  which  the 
phosphorus  is  not  easily  commercially  recoverable  and  which  may  not  be  fully  available  to 
plants.  

There  are  alternative  techniques  to  extract  phosphorus  which  do  not  create  this  problem. 
These  include  removing  of  phosphorus  waste  water  in  the  form  of  struvite,  incinerating 
sewage sludge and using the ashes, and applying the sewage sludge directly onto fields after 
appropriate treatment. In all cases, the agronomic quality of the product is crucial to ensuring 
that  the  phosphorus  is  actually  available  and  being  taken  up  by  crops.  About  25%  of  the 
phosphorus contained in waste water is currently reused, the commonest method being direct 
application of sewage sludge on to fields. The total potential for recovery is quite high – about 
300,000  tonnes  of  phosphorus  per  annum  in  the  EU57  –  and  the  significant  discrepancies 
between the different Member States in the EU in terms of how much sewage sludge is used 
(either directly or in the form of ash) shows potential for harmonisation around best practice. 

The commercial and environmental viability of most of these approaches is dependent on the 
extent to which the resource has been diluted. Dewatering and moving large volumes of liquid 
around  is  an  energy-intensive  and  expensive  process.  The  absence  of  contaminants  is  also 
crucial, as it requires high standards and careful control procedures and, in the case of sewage 
sludge incineration, means that sewage sludge cannot be mixed with other waste during the 
incineration process.  
Although the Sewage Sludge Directive58 has established the conditions for safe use of sludge 
on agricultural land, it is now considered to be out of date, notably as regards the maximum 
limit  values  for  cadmium  and  other  contaminants  are  considered  to  be  too  high.  Sixteen 
Member  States  have  adopted  more  stringent  standards  than  those  set  out  in  the  Directive. 
Harmonisation  of  higher  quality  standards  would  encourage  greater  confidence  amongst 
farmers  and  consumers  on  the  safe  use  of  sludge  in  the  EU.  In  order  to  encourage  more 
efficient  resource  use  in  the  future,  these  issues  will  need  to  be  addressed  so  that  product 
standards  for  sewage  sludge  inspire  confidence  right  across  the  chain  of  end  users:  namely 
farmers,  retailers  and  ultimately  consumers.  Sewage  sludge  can  also  be  composted  and  the 
End of Waste criteria currently under development is examining whether this sludge compost 
can fulfil the stringent standards to safeguard its use by farmers once composted. 

Q11  –  Should  some  form  of  recovery  of  phosphorus  from  waste  water  treatment  be 
made  mandatory  or  encouraged?  What  could  be  done  to  make  sewage  sludge  and 
biodegradable waste more available and acceptable to arable farming? 

4.5. 

Use of organic fertilisers 

One  advantage  of  the  more  efficient  use  of phosphate  from  organic  by-products  and  wastes 
would  be  that  it  does  not  increase  the  overall  volume  of  cadmium  present  in  the  European 
ecosystem,  to  the  extent  that  these  by-products  and  wastes  come  from  food  and  feedstuffs 
produced in Europe, which in turn contain cadmium absorbed from European soils. However, 
copper and zinc contamination can be an issue with some organic fertilisers. 

56 
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58 

Council Directive 91/271/EEC concerning urban waste water treatment 
EUREAU position paper on the reuse of phosphorus, 2006 
Council  Directive  86/278/EEC  on  the  protection  of  the  environment  when  sewage  sludge  is  used  in 
agriculture 

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Although  many  industrial  technologies  for  the  recovery  of  phosphorus  (from  manure  and 
sewage and biodegradable waste) are already on-stream and used to varying degrees, there is 
no common strategy to promote the use of such renewable sources by farmers. The price of 
recovered  fertiliser  is  generally  higher  than  the  price  of  mineral  phosphate  fertiliser.  Much 
more could be done in terms of identifying markets for recycled phosphorus and barriers to its 
increased use, and in implementing the technologies that are already available. 

5. 

NEXT STEPS 

This Consultative Communication sets out for the first time at EU level the issues around the 
sustainability of phosphorus use. The intention is now to launch a debate on the state of play 
and the actions that should be considered. 

The European Institutions and all those interested – organisations or private individuals – are 
invited to submit their comments on the questions set out in the Consultative Communication, 
as  well  as  on  any  other  issues  that  they  wish  to  raise  concerning  the  sustainable  use  of 
phosphorus. 

All stakeholders are invited to send in their comments by 1 December 2013 at the latest, by e-
mail to: env-use-of-phosphorus@ec.europa.eu . 

It  is  important  to  read  the  specific  privacy  statement  attached  to  this  consultation  for 
information  on  how  your  personal  data  and  contribution  will  be  dealt  with.  Professional 
organisations  are  invited  to  register  in  the  Commission  register  for  Interest  Representatives 
(http://:ec.europa.eu/transparency/regrin).  This  register  was  set  up  as  part  of  the  European 
Transparency  Initiative.  The  Commission  will  publish  stakeholder  contributions  on  the 
Internet, unless you explicitly request us not to do so. 

The  results  of  the  public  consultation  will  help  shape  the  further  work  of  the  Commission 
regarding the contribution that the EU can make to the sustainable use of phosphorus.  

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