COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2019/1009 as regards the digital labelling of EU fertilising products
Date: 2023-02-27
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: EC conformity marking, EU environmental policy, digital transformation, digitisation, fertiliser, fertiliser industry, harmonisation of standards, labelling, market approval, single market

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   EUROPEAN COMMISSION  Brussels, 27.2.2023  SWD(2023) 49 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT    Accompanying the document proposal for a Regulation of the European Parliament and of the Council  amending Regulation (EU) 2019/1009 as regards the digital labelling of EU fertilising products {COM(2023) 98 final} - {SEC(2023) 99 final} - {SWD(2023) 48 final} - {SWD(2023) 50 final}  
 
 
Table of contents 

1. 

INTRODUCTION .................................................................................................................. 1 

  The fertilising products industry .................................................................. 5 

  The EU agriculture ....................................................................................... 7 

2. 

PROBLEM DEFINITION ...................................................................................................... 7 

2.1.  Preliminary remarks .............................................................................. 7 
2.2.  What are the problems? ......................................................................... 8 
2.2.1.  Problem 1- Labels are difficult to read for users .......................................... 9 

2.2.2.  Problem 2- Labels are difficult to manage for economic operators ........... 10 

  Driver 1: extensive labelling requirements................................................. 11 

  Driver 2: there are no rules regarding the voluntary digitalisation of the labels

12 

  Driver 3: some labelling information changes frequently .......................... 12 

  Driver 4: Some EU fertilising products change their labels before reaching 
the end-users ............................................................................................................. 13 

  Driver 5: products sold in bulk need personalised leaflets ......................... 14 

3.  WHY SHOULD THE EU ACT? .......................................................................................... 15 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................. 16 

The links between the problems identified and the objectives of this initiative 
are presented in Table 4.1. ................................................................... 16 
4.1.  General objectives ............................................................................... 17 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ...................................................... 18 

5.1.  What is the baseline from which options are assessed? ...................... 18 
5.1.1 

The socioeconomic context ........................................................................ 18 

5.1.2  Agriculture .................................................................................................. 18 

5.1.3  Hobby market ............................................................................................. 19 

5.1.4  Digital divide .............................................................................................. 19 

5.1.5 

Share of companies already embracing digitalising product information .. 20 

5.1.6  Continuation of the existing legal framework ............................................ 21 

5.1.7  Digital product passport ............................................................................. 21 

5.2.1.  Differences between professional and non-professional users ................... 23 

5.2.2.  The stability of the information provided over time .................................. 24 

5.3.1. 

Information which could be moved from the physical label to digital label
27 

5.3.2.  Principles for digital labelling .................................................................... 29 

5.5.1.  Replacing  the  physical  labels  with  digital  labels  for  all  EU  fertilising 
products 32 

5.5.2.  Mandatory digital labelling ........................................................................ 34 

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5.5.3.  Centralised database for providing information digitally ........................... 34 

5.5.4.  Digitalisation of incremental information requirements. ........................... 35 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................. 35 

6.2.  Policy Option 1: Development of a Guidance Document only ........... 36 
6.2.1.  Economic impacts ...................................................................................... 36 

6.2.2. 

Impact on the environment ......................................................................... 36 

6.2.3.  Social impact and on human health ............................................................ 36 

6.2.4.  Stakeholders view on PO1.......................................................................... 37 

6.3.1.  Economic impacts ...................................................................................... 38 

6.3.2. 

Impact on the environment ......................................................................... 45 

6.3.3.  Social impact and on human health ............................................................ 46 

6.3.4.  Stakeholders view on PO2a- PO2e............................................................. 47 

6.4.1.  Economic impacts ...................................................................................... 48 

6.4.2. 

Impact on the environment ......................................................................... 50 

6.4.3.  Social impact and on human health ............................................................ 51 

6.4.4.  Stakeholders view on policy option 3 ........................................................ 51 

7.  HOW DO THE OPTIONS COMPARE? .............................................................................. 51 

8. 

PREFERRED OPTION ........................................................................................................ 57 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................... 59 

ANNEX 1: PROCEDURAL INFORMATION .............................................................................. 61 

1. 

LEAD DG, DECIDE PLANNING/CWP REFERENCES .................................................... 61 

ORGANISATION AND TIMING ................................................................................................. 61 

2. 

3. 

CONSULTATION OF THE RSB......................................................................................... 61 

EVIDENCE SOURCES AND QUALITY ............................................................................ 63 

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) .................................. 65 

1. 

THE CONSULTATION ACTIVITIES ................................................................................ 65 

1.2  Open public consultation ..................................................................... 67 
1.3  A targeted stakeholder survey ............................................................. 69 
1.4  The survey experiment ........................................................................ 72 
1.5  Focus groups ........................................................................................ 73 
1.6  Usability testing ................................................................................... 74 
1.7  Ad-hoc expert group meeting on options for digitalisation of labels .. 75 
1.8  Survey:  focus  on  costs  and  benefits  related  to  various  digitalisation 
options ................................................................................................. 76 

ANNEX 3: WHO IS AFFECTED AND HOW? ............................................................................ 78 

1. 

2. 

3. 

PRACTICAL IMPLICATIONS OF THE INITIATIVE....................................................... 78 

SUMMARY OF COSTS AND BENEFITS ......................................................................... 79 

RELEVANT SUSTAINABLE DEVELOPMENT GOALS ................................................. 85 

ANNEX 4: ANALYTICAL METHODS ....................................................................................... 86 

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1.  OVERVIEW ......................................................................................................................... 86 

2. 

3. 

LIMITATIONS ENCOUNTERED AND MITIGATION MEASURES .............................. 88 

BASELINE COSTS: ............................................................................................................. 89 

4.  ASSUMPTIONS: COSTS AT THE LEVEL OF EU BUSINESSES: .................................. 91 

5.  ASSUMPTIONS: ENTERPRISE COSTS AT EU LEVEL .................................................. 96 

6.  ASSUMPTIONS:  BENEFITS  FOR  ENTERPRISES 

(PRODUCERS,  SUPPLIERS, 
ETC.) ................................................................................................................................... 101 

7.  ASSUMPTIONS: COMPARISON OF COSTS AND BENEFITS AT EU LEVEL .......... 110 

ANNEX 5: THE FPR AND ITS LABELLING PROVISIONS ................................................... 114 

1. 

INTRODUCTION OF THE FERTILISING PRODUCT REGULATION:........................ 114 

ANNEX  6  –  GUIDANCE  DOCUMENT  ON  THE  LABELLING  OF  EU  FERTILISING 
PRODUCTS ........................................................................................................................ 117 

ANNEX 7: POLICY OPTIONS ................................................................................................... 181 

1. 

2. 

3. 

4. 

5. 

6. 

PFC 1 (FERTILISER) ......................................................................................................... 181 

PFC 2 (LIMING MATERIAL) ........................................................................................... 197 

PFC 3 (SOIL IMPROVER) ................................................................................................ 202 

PFC 4 (GROWING MEDIUM) .......................................................................................... 208 

PFC 5 (INHIBITOR)........................................................................................................... 213 

PFC 6 (PLANT BIOSTIMULANT) ................................................................................... 215 

ANNEX 8: EXAMPLE OF POLICY OPTIONS (PHYICAL LABELS) .................................... 221 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

POLICY OPTION 1 – FULL PHYSICAL LABEL ............................................................ 221 

POLICY  OPTION  2A  –  CERTAIN  INFORMATION  MOVES  DIGITALLY  (TEXT  IN 
GREEN MAY BE PROVIDED DIGITALLY) .................................................................. 223 

POLICY OPTION2C – MOST OF THE INFORMATION MOVED DIGITALLY (TEXT IN 
GREEN IS ALLOWED TO GO DIGITAL) ....................................................................... 224 

POLICY OPTION 2B - PROFESSIONAL USERS - MEASURE 3A (TEXT IN GREEN IS 
ALLOWED TO GO DIGITAL) ......................................................................................... 225 

POLICY OPTION 2E - PROFESSIONAL USERS - MEASURE 5A (TEXT IN GREEN IS 
ALLOWED TO GO DIGITAL) ......................................................................................... 226 

POLICY  OPTION  2B  –  NON-PROFESSIONAL  USERS  -  MEASURE  3B  (TEXT  IN 
GREEN IS ALLOWED TO GO DIGITAL) ....................................................................... 227 

POLICY  OPTION  2D  –  NON-PROFESSIONAL  USERS  -  MEASURE  5B  (TEXT  IN 
GREEN IS ALLOWED TO GO DIGITAL) ....................................................................... 228 

ANNEX 9: CASE STUDIES ........................................................................................................ 231 

1. 

2. 

3. 

CASE STUDY 1: LARGE MANUFACTURER ................................................................ 231 

CASE STUDY 2: MID-SIZE FIRM ................................................................................... 232 

CASE STUDY 3: A MID-SIZE DISTRIBUTOR, IBERIAN BRANCH ........................... 233 

ANNEX 10: TRENDS IN DIGITALISATION ............................................................................ 236 

1.  DIGITAL LITERACY AND SKILLS AND INTERNET ACCESS .................................. 236 

2.  DIGITAL DIVIDE – DIGITAL SKILLS ........................................................................... 237 

3.  DIGITAL DIVIDE – ACCESS TO THE INTERNET ....................................................... 238 

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Glossary 

Term 
acronym 

CAP 

CLP 

DESI 

DPP 

EU 

FPR  

or 

Meaning or definition 

Common Agricultural Policy 

Classification,  labelling  and  packaging  of  substances  and  mixtures  (CLP) 
Regulation 

Digital Economy and Society Index 

Digital Product Passport 

European Union 

Fertilising  Products  Regulation,  Regulation  (EU)  2019/1009  of  the  European 
Parliament and of the Council of 5 June 2019 

EC 
Regulation  

Fertilisers 

Regulation (EC) No 2003/2003 of the European Parliament and of the Council 
of 13 October 2003, predecessor to the FPR  

NGO 

Non-Governmental Organisation 

The Nitrates 
Directive 

PFC 

SDGs 

SMEs 

TFEU 

Council Directive 91/676/EEC of 12 December 1991 

Product Function Category 

Sustainable Development Goals 

Small and medium-sized enterprises 

Treaty on the Functioning of European Union 

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1.  INTRODUCTION  

Fertilising  products  are  substances,  mixtures,  micro-organisms  or  any  other  materials, 
applied on plants or their rhizosphere, or constituting the rhizosphere, for the purpose of 
providing the plants with nutrients or improving their nutrition efficiency. 

Manufacturers  of  fertilising  products  may  choose  freely  if  to  place  on  the  market  their 
products as:  

1.  harmonised products, if they comply with Regulation (EU) 2019/10091, hereafter 
‘the FPR’2 (‘EU fertilising products’); such products move freely in the internal 
market; or  

2.  non-harmonised products, in accordance with national rules applicable in the EU 
country where they market the products; such products may move within the EU 
in accordance with the mutual recognition rules3.  

This  impact  assessment  concerns  the  digitalisation  of  the  labelling  of  EU  fertilising 
products4.  

1.1. 

Political Context 

Commission President von der Leyen stressed in her political guidelines the need for 
Europe to lead the transition to a healthy planet and a new digital world5. In the Green 
Deal6, the Commission announced its intention to address the twin challenge of the green 
and the digital transformation. Soon after, the COVID-19 pandemic has radically changed 
the role and perception of digitalisation in our societies and economies and accelerated its 
pace.  In 2020, 22% of EU enterprises had e-commerce sales, a  1-percentage point (pp) 
increase compared with 2019 and 6 pp up from 13% in 20107. The pandemic revealed the 
need for a faster transition towards a more digital economic and industrial model, in order 
to enhance Europe’s drive towards sustainable competitiveness8. 

1 Regulation (EU) 2019/1009 of the European Parliament and of the Council of 5 June 2019 laying down rules on the 
making available on the market of EU fertilising products and amending Regulations (EC) No 1069/2009 and (EC) No 
1107/2009 and repealing Regulation (EC) No 2003/2003, OJ L 170, 25.6.2019, p. 1. 
2 For more details on the aims and the most important new elements introduced by Regulation (EU) 2019/1009 in the 
field of fertilising products, see Annex 5. 
3  Articles 34-36 TFEU and Regulation (EU) 2019/515 of the European Parliament and of the Council of 19 March 2019 
on  the  mutual  recognition  of  goods  lawfully  marketed  in  another  Member  State  and  repealing  Regulation  (EC)  No 
764/2008, OJ L 91, 29.3.2019, p. 1.  
4 See Annex 1 for procedural details.  
5 Available here political-guidelines-next-commission_en_0.pdf (europa.eu)  
6 Communication from the Commission to the European Parliament, the European Council, the Council, the 
European Economic and Social Committee and the Committee of the Regions, The European Green Deal, 
COM/2019/640, 11.12.2019. 
7 Online sales continue to grow among EU enterprises - Products Eurostat News - Eurostat (europa.eu) 
8 Communication from the Commission to the European Parliament, the Council, the European Economic and Social 
Committee and the Committee of the Regions, Updating the 2020 New Industrial Strategy: Building a stronger Single 
Market for Europe’s recovery, COM(2021) 350, 5.5.2021.  

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The 2021 Digital Compass Communication9 maps out a clear path towards a common 
vision and actions for Europe to succeed in the Digital Decade. It puts forward the ’digital 
by default’ principle and outlines a way ahead for broad-based digitalisation of society.  

In its Work Programme 202210, the Commission indicated that it would follow up on its 
path  to  the  digital  decade  to  deliver  on  the  EU’s  digital  transformation  by  2030.  The 
Commission is determined to lead the way in the global race for trustworthy, secure and 
human-centric technology.  

With a particular focus to the agricultural sector, its digital transformation will facilitate 
cooperation across the value chain, support farmers, and offer opportunities for innovative 
SMEs. Technologies, such as artificial intelligence (AI), robotics, the Internet of Things 
(IoT),  Edge  Computing,  5G,  blockchain  and  supercomputing,  all  have  the  potential  to 
make  agriculture  more  efficient,  sustainable,  and  competitive.  26  European  countries 
signed a Declaration of cooperation on ‘A smart and sustainable digital future for European 
agriculture  and  rural  areas’11  to  take  a  number  of  actions  to  support  the  successful 
digitalisation. It recognises the potential of digital technologies to help tackle important 
and urgent economic, social, climate and environmental challenges facing the EU's agro-
food sector and rural areas. 

The more efficient use of, in particular, fertilisers is an important element in the Farm to 
Fork Strategy12, which specifies a target of 50% reduction of nutrient losses and aims to 
reduce fertiliser use by 20% by 2030. Use of digital tools is a key enabler in this process, 
for example in tracking the Gross Nutrient Balances baselines and targets for countries and 
collection of data at regional level. 

The digitalisation of the labels  of EU fertilising products  complements the efforts done 
towards the digitalisation of the agriculture.  

Given  the  links  to  the  goals  of  the  European  Green  Deal,  in  particular,  nutrient  loss 
prevention  and  the  green  and  digital  transition  of  the  EU  industry,  the  objectives  (see 
section  4)  also  contribute  to  the  achievement  of  the  United  Nations  Sustainable 
Development Goals (SDGs). Four of which are directly relevant for this initiative: SDG 
#3  Good  health  and  well-being,  SDG  #6  Clean  water  and  sanitation,  SDG  #9  Industry, 
innovation and infrastructure, SDG #12 Ensure sustainable consumption and production 
patterns (see Annex 3, Part 3 for more details). 

9 Communication from the Commission to the European Parliament, the Council, the European Economic and Social 
Committee  and  the  Committee  of  the  Regions,  2030  Digital  Compass:  the  European  way  for  the  Digital  Decade, 
COM(2021)118, 9.3.2021.  
10 Communication from the Commission to the European Parliament, the Council, the European Economic 
and  Social  Committee  and  the  Committee  of  the  Regions,  Commission  work  programme  2022,  Making 
Europe stronger together, COM(2021) 645, 19.10.2021.  
11EU Member States join forces on digitalisation for European agriculture and rural areas | Shaping Europe’s 
digital future (europa.eu) 
12 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52020DC0381&from=EN  

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There  is  a  general  trend  of  digitalisation  of  the  labels  or  documents  accompanying 
products. Rules are in  place  for  construction products13 and medical  devices14 or under 
preparation for batteries15, detergents16, cosmetics17, hazardous chemicals18.  

The coherence of all the EU initiatives (i.e. for CLP, Detergents, Fertilising Products and 
Cosmetics) is one of the Commission’s objectives. Besides the advantages for the users of 
these various chemical products, coherence is absolutely necessary for products covered 
by two initiatives at a time (fertilising products may also be labelled according to CLP, so 
the two sets of rules have to work together).  

As a first step to ensure this coherence, the digital labelling will only be allowed subject to 
some fundamental principles (please see section 5.3.1 of the report) in order to protect end-
users and to ensure the accessibility, availability and quality of digital information. The 
digital principles proposed across the different initiatives will be consistent, and support 
creating a level playing field for the chemicals industry.  

In  all  digital  labelling  of  chemicals  coherence  will  further  be  ensured  as  regards  to  the 
overall architecture of each piece of regulation. In each initiative it will be proposed what 
information could be provided only digitally (adapted to the specific requirements of each 
Regulation).  

In all initiatives concerning digital labelling of chemicals (i.e. under the CLP, Detergents, 
Fertilising  Products  and  Cosmetics  Regulations)  consistency  and  synergies  have  been 
ensured across the different proposals throughout the assessment and drafting processes. 
The  Commission  will  ensure  coherence  in  supplementing  the  general  principles  via 
delegated  acts,  in  a  second  step,  after  the  adoption  of  the  amendments  needed  by  the 
European Parliament and the Council.     

A policy initiative relevant for fertilising products is also the proposal for a Regulation on 
Ecodesign for Sustainable Products19, which will establish a Digital Product Passport 
(DPP). The  DPP  gathers  data  on  a  product  and  its  value  chain20  to  support  sustainable 
production,  to  enable  the  transition  to  circular  economy,  to  provide  new  business 
opportunities, to support consumers in making sustainable choices, and to allow authorities 
to  verify  compliance  with  legal  obligations.  The  DPP,  in  the  version  proposed  by  the 
Commission,  will  introduce  the  mandatory  adoption  of  digital  ways  of  communicating 

13 Regulation (EU) No 305/2011 of the European Parliament and of the Council of 9 March 2011 laying down harmonised 
conditions for the marketing of construction products and repealing Council Directive 89/106/EEC, OJ L 88, 4.4.2011, 
p. 5. 
14  Regulation  (EU)  2017/745  of  the  European  Parliament  and  of  the  Council  of  5  April  2017  on  medical  devices, 
amending  Directive  2001/83/EC,  Regulation  (EC)  No  178/2002  and  Regulation  (EC)  No  1223/2009  and  repealing 
Council Directives 90/385/EEC and 93/42/EEC, OJ L 117, 5.5.2017, p. 1. 
15 Proposal for a Regulation of the European Parliament and of the Council concerning batteries and waste batteries, 
repealing Directive 2006/66/EC and amending Regulation (EU) No 2019/1020, COM(2020)798. 
16 Detergents – streamlining and updating the EU rules (europa.eu)   
17 EU chemicals strategy for sustainability – Cosmetic Products Regulation (revision) (europa.eu)  
18 Chemicals – simplification and digitalisation of labelling requirements (europa.eu)  
19 Proposal for a Regulation of the European Parliament and of the Council establishing a framework for setting ecodesign 
requirements for sustainable products and repealing Directive 2009/125/EC, COM/2022/142, 30.03.2022. 
20 Circular economy action plan (europa.eu) 

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information  about  all  regulated  products,  including  fertilising  products  (for  more 
information regarding the interplay between the two initiatives see section 6.1.7).  

1.2.  Legal context 

The FPR has been adopted in 2019 and starts applying as of 16 July 2022. It replaces the 
harmonisation  rules  laid  down  in  Regulation  (EC)  No  2003/2003  on  fertilisers  (EC 
Fertilisers Regulation)21.  

EU  fertilising  products  may  be  covered  by  several  EU  rules  and  therefore  they  are 
accompanied by the following: 

 

 

 

 

information  regarding 
importers, 
distributors), traceability requirements, CE mark, in accordance with Articles 6(5) 
and (6), 8(3), 11 and 17 of the FPR;  

the  economic  operators  (manufacturers, 

the labelling requirements laid down in Annex III to the FPR;  

the  labelling  requirements  under  CLP  Regulation  (EC)  No  1272/200822,  if  the 
product  contains  a  substance  classified  as  hazardous  in  accordance  with  this 
Regulation;  

in some cases, other information, such as the ECOLABEL, in the conditions laid 
down in Decision (EU) 2015/209923 or information on compatibility with organic 
farming, in the conditions laid down in Implementing Regulation (EU) 2021/116524 
(these rules are not applicable to all fertilisers).  

This  impact  assessment  looks  into  the  possible  digitalisation  of  the  labelling 
requirements  included  in  Annex  III  to  the  FPR,  which  represents  the  bulk  of  the 
information included on the label of an EU fertilising product. Annex III lays down: 

  general labelling  requirements, applicable to  all  EU fertilising products,  such as 

indicating the quantity or the ingredients;  

  specific labelling requirements, for each of the seven product function categories 
(PFCs):  fertilisers,  soil  improvers,  liming  materials,  growing  media,  inhibitors, 
plant biostimulants and blends. 

The correct labelling of a fertilising product is  a condition for its CE-marking.  It is the 
responsibility of the manufacturer, meaning the economic operator producing the product 
or  having  it  designed  and  placing  it  on  the  market  on  its  own  name.  Under  specific 
circumstances, importers or distributors, which package or repackage products, may also 
label products (see also Section 2.5 under driver 5). 

21 Regulation (EC) No 2003/2003 of the European Parliament and of the Council of 13 October 2003 relating to fertilisers, 
OJ L 304, 21.11.2003, p. 1. 
22 Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on classification, 
labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, 
and amending Regulation (EC) No 1907/2006, OJ L 353, 31.12.2008, p. 1. 
23 Commission Decision (EU) 2015/2099 of 18 November 2015 establishing the ecological criteria for the award of the 
EU  Ecolabel  for  growing  media,  soil  improvers  and  mulch  (notified  under  document  C(2015)  7891),  OJ  L  303, 
20.11.2015, p. 75. 
24 Commission Implementing Regulation (EU) 2021/1165 of 15 July 2021 authorising certain products and substances 
for use in organic production and establishing their lists, C/2021/5149, OJ L 253, 16.7.2021, p. 13. 

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Fertilising products must have either a physical label and/or an accompanying leaflet: 

  where a product is supplied in a package, the information appears on a label affixed 
to  that  package;  if  the  package  is  too  small  to  contain  all  the  information,  the 
information  that  cannot  be  provided  on  the  label  has  to  be  provided  in  a  leaflet 
accompanying that product;  

  where the product is supplied without packaging, all the information is provided in 

a leaflet. 

The  information  must  be  provided  in  a  language  easily  understood  by  end-users,  as 
determined by the national authorities of the EU country where the product is marketed. 
As a rule, the information must be provided in the official language(s) of the respective 
EU  country.  Some  EU  countries  accept  a  written  agreement  from  professional  users  to 
receive  a  product  labelled  in  another  language  than  the  official  one(s),  for  example,  in 
English. 

A comprehensive list of all labelling requirements is included in Annex 7. 

The Commission published guidance and examples concerning the visual appearance of 
the labels referred to in Annex III to the FPR (Annex 6)25. An example of a label can be 
found in Annex 8. 

1.3.  Market context 

  1.3.1.  The fertilising products industry 

According to 2019 EUROSTAT data26 the EU fertilising products industry has an annual 
turnover of around €31 billion.  It employs approximately 100,000 people. 

There are about 1347 enterprises active in the inorganic fertilisers category, and 3595 in 
fertilising products overall. According to the stakeholders survey launched as part of the 
‘digital labelling study’27, some 91.3% of enterprises either carry out the whole labelling 
process in-house (59.4% out of 69 responses), or partly (31.9% out of 69 responses).           

A handful of enterprises accounts for some 80% of the turnover for inorganic fertilisers, 
while 99.8% of enterprises are SMEs for the other categories of products. Production of 
inorganic fertilisers is concentrated in a few EU Member States28, while the distribution of 
enterprises between large companies and SMEs in other categories of fertilising products 
than inorganic fertilisers is more balanced within the EU. Inorganic fertilisers account for 
approximately 80% of turnover.  Figure 1.3 presents the turnover shares of the different 
fertilising products.  

25 Communication from the Commission concerning the visual appearance of the label on EU fertilising products referred 
to in Annex III to Regulation (EU) 2019/1009 of the European Parliament and of the Council, 2021/C 119/01 
C(2021)726, OJ C 119, 7.4.2021, p. 1. 
26 Available at: https://ec.europa.eu/eurostat/web/structural-business-statistics/data/database 
27 CSES (Jan Smit, Mark Whittle and James Rampton) and PPMI (Zalan Tamas Jakab, Donatas Pocius and 
Arnas  Aleksandravičius),  Study  to  support  the  Impact  Assessment  on  the  use  of  digital  labelling  for  EU 
fertilising products, 2022, not yet published. 
28 According to Eurostat data, nearly 60% of EU production is located in four member states: Germany (21%), France 
(13%), the Netherlands (12%) and Spain (11%). With Italy and Belgium it represents to 74% of EU production. 

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Figure 1.3: EU fertilising products shares in the EU market (by turnover)  

Liming materials 
2%

Growing media
6%

Soil improvers
2%

Inhibitors
1%

Plant bio-
stimulants
2%

Organo-mineral 
fertiliser
2%

Organic fertiliser
5%

Inorganic 
fertiliser
80%

Sources: Halleux (2019), Commission (2016), Eurostat, Growing Media Europe. 
More statistical data are provided in the ‘digital labelling study’29, in section 5.1.  

1.4.1.1.1.3.1.1 

Industrial users  

Industrial users (economic operators buying EU fertilising products to make it available 
on  the  market)  constitute  an  important  element  of  the  fertilising  products  industry. 
Blenders purchase fertilising products in order to mix and relabel them and then place them 
on the market as fertilising product blends. These blends are designed to be targeted at very 
specific uses and application methods and can be highly efficient and cost effective.  

In general, the quantities of fertilising products bought and shipped tend be large – often it 
is in the form of truck-loads (sometimes carrying single deliveries, sometimes pallet loads) 
or  specialised  tankers  for  the  transport  of  liquids,  regulated  by  specific  rules  related  to 
transport and handling of dangerous products. 

However,  thought  the  data  collection  phase  of  this  Impact  Assessment,  obtaining  data 
about this part of the market has proved to be a major challenge, as manufacturers tend not 
to distinguish between bulk shipments to blenders/ resellers and large-scale users who buy 
in bulk. The data provided below is based on the information provided by the main EU 
industry associations in the fertilising products by the digital labelling study.    

  Share  (turnover)  of  products  sold  to  industrial  users,  including  blenders,  varies 

between 5 – 50% of all sales; 

  Bulk sales to end-users varies between 15-40% of all turnover. 

29 CSES (Jan Smit, Mark Whittle and James Rampton) and PPMI (Zalan Tamas Jakab, Donatas Pocius and 
Arnas  Aleksandravičius),  Study  to  support  the  Impact  Assessment  on  the  use  of  digital  labelling  for  EU 
fertilising products, 2022, not yet published. 

6 

 
 
 
                                                 
  1.3.2.  The EU agriculture 

According  to  the  information  available  on  EUROSTAT  for  the  period  2005-2016,  EU 
farms used 173 million hectares of land for agricultural production in 2016, 39 % of the 
total land area of the EU. More than half of this land was used by large farms, with more 
than 100 ha. The number of farms in the EU diminished with approximately a quarter in 
the same period, 85% of them being small farms with less than 5 ha. The amount of land 
used for production has remained steady30. Farmers were typically male and relatively old, 
according to 2016 statistics31.  

Professional users of fertilising products include primarily the farming and horticultural 
community. In terms of volume and value of fertilising products used, the largest share of 
users of fertilising products is  the agricultural  sector  – farms which,  according to  some 
estimates, represents 80—90% of the value of the overall market.32 Non-professional users 
of fertilising products include hobby gardeners.  

2.  2. PROBLEM DEFINITION 

2.1. 

2.1. 

Preliminary remarks 

The FPR starts applying as of 16 July 2022. As there is no experience with the application 
of the FPR, a number of assumptions have been made in this impact assessment based on 
the information available on the application of the EC Fertilisers Regulation. This has two 
inconveniences:  

 

firstly, the previous  EC  Fertilisers  Regulation followed a different legislative 
approach where types of products were described in detail in the Regulation and 
the labelling requirements attached were less extensive; the FPR sets out a more 
flexible framework and has higher ambitious for the protection of health and the 
environment, thus more extensive labelling requirement.   

  secondly,  EC  Fertilisers  Regulation  covered  fewer  types  of  products,  in 
particular inorganic fertilisers and certain liming materials. The FPR covers seven 
PFCs, as explained in Annex 7. The extrapolation of the analysis to other categories 
of products might not be completely accurate. 

In addition, it remains the free choice of manufacturers whether to apply the FPR or 
rely  on  national  rules.  Therefore,  it  is  difficult  to  estimate  the  number  of  economic 
operators who would make this choice as of 16 July 2022 or in the following years. 

30 Farms and farmland in the European Union - statistics - Statistics Explained (europa.eu)  
31 Farmers and the agricultural labour force - statistics - Statistics Explained (europa.eu)  
32 CSES and PPMI study mentioned before, see section 5.1.2. 

7 

 
 
                                                 
2.2. 

2.2. 

What are the problems? 

Based  on  the  input  gathered  from  stakeholders  during  the  preparation  of  the 
implementation of the FPR and the evidence gathered during the digital labelling study33, 
the following problems have been identified: 

1.  EU fertilising products’ labels are difficult to read for users; 
2.  EU fertilising products’ labels are difficult to manage for economic operators.  

The relationship between drivers of problems, the problems and their consequences is set 
out in problem tree table 2.1 

Table 2.1: Problem tree- Links between drivers, problems and consequences 

Drivers 

Problems 

Consequences 

Driver  1:  The  extensive 
labelling 
requirements 
under  the  FPR  leads  either 
to overcrowded labels or to 
labels  complemented  by 
leaflets 

Driver 2: there are no rules 
the  voluntary 
regarding 
digitalisation  of  the  labels, 
so  there  are  no  minimum 
standards 
the 
quality  of  the  information 
provided digitally 

to  ensure 

Driver  1  (as  above):  The 
extensive 
labelling 
requirements under the FPR 
take a lot of space 

Driver  3:  Some  labelling 
information 
changes 
frequently  

Driver  4:  some  economic 
operators  redo  the  labels 
before  the  product  reaches 
the  end-users,  because  the 

1: 
Problem 
labels 
are 
difficult  to  read 
for users  

For  users:  as  it  is  difficult  to  distinguish  between 
essential and less relevant information, users may end 
up  using  wrongly 
fertilising  products,  with 
consequences on the quality/quantity of their crop  

the 

environment: 

For 
sub-optimal  use  of 
information  important  for  the  protection  of  the 
environment can lead to over-fertilisation   

For  society:  sub-optimal  realisation  of  health  & 
safety  

2: 
are 
to 
for 

Problem 
labels 
difficult 
manage 
economic 
operators 

Increased labelling costs for the industry due to: 

 

 

 

fewer languages can be included on the package 
for  products,  which  are  CE  marked  with  the 
main  purpose  of  circulating  freely  in  all  EU 
countries. 
frequent  reprinting  of  labels  either  because  of 
the  frequent  changes  of  the  information  or  the 
need to relabel and  
the difficulty to anticipate exactly when a new 
label is needed so that to avoid wasting already 
printed labels 

33 CSES and PPMI study mentioned before.  

8 

 
 
 
 
                                                 
products are either blended, 
repackaged or rebranded.  

No  level  playing  field  for  operators  opting  for  the 
digitalisation of labels 

for 

need 

Driver  5:  products  sold  in 
leaflets 
bulk 
each 
personalised 
implies 
customer  which 
administrative 
unjustified 
burden  given 
the 
also 
specificity of the bulk sales 

Increased packaging waste with potential negative effects 
on the environment  

  2.2.1.  Problem 1- Labels are difficult to read for users 

The FPR contains numerous labelling requirements in order to ensure that the users are 
correctly  informed  about  the  agronomic  efficiency  of  the  product,  the  content  of  the 
product,  the  safety  of  the  product  and  information  for  the  user  after  purchase,  such  as 
storage conditions or use instructions34. Yet, overcrowded labels are difficult to read by 
product  users.  This  could  make  it  difficult  for  product  users  to  find  essential  product 
information,  particularly  on  safety.  At  present,  evidence  from  studies  by  industry  and 
feedback  from  the  public  consultation  suggests  that  not  all  product  users  read  the 
information on the label and understand it, in particular non-professional users35.  

For  users,  it  becomes  difficult  to  distinguish  between  essential  and  less  relevant 
information, and users may end up using wrongly fertilising products, with consequences 
on  the  quality/quantity  of  their  crop.  Incorrect  use  of  products  also  has  impacts  on  the 
environment, as a potential outcome of unclear labels is over-fertilisation. For society, this 
could  mean  sub-optimal  realisation  of  health  and  safety.  So,  although  currently  all 
information is on a physical label, including safety information, the labels are considered 
overloaded and therefore protection of on the environment and human health is destitute.  

This  problem  is  further  linked  with  the  issue  that  the  label  contains  overly  technical 
language  on  a  product,  which  non-professional  users  often  do  not  understand36.  This 
contributes to ‘information overload’ and results in users and readers ‘giving up’ reading 
the  label  (due  to  limited  information  search  and  processing  capacities  according  to 
behavioural economics). As a result, they might miss the information that is essential for 
them to be able to use the product in the best and safest manner for themselves and the 
environment37.  

 The use of multilingual labels might mean that font sizes are reduced to a smaller font size 
to be used to communicate information, makes it more difficult for users to identify the 
information  relevant  to  them.  As  the  labelling  information,  according  to  the  regulation 

34 See Annex 6 for detailed information on the labelling requirements. 
35 CSES and PPMI study mentioned before, Section 2.2.5. 
36  Most  non-professional  do  not  use  more  technical  information  subcategories  (e.g.  neutralising  value, 
chelating and complexing agents, list of ingredients), because it is not relevant or they do not understand 
such information. 
37 CSES and PPMI study mentioned before, Section 3.2.5. 

9 

 
 
 
                                                 
should be clear, understandable and intelligible, this could further lead to non-compliance 
with the FPR. 

The readability of the labelling information is also affected in case of small packages when 
part of the information is included in the label and the remaining information in a separate 
leaflet.  Providing  information  in  various  places  makes  it  difficult  to  identify  the 
information needed.  

  2.2.2.  Problem 2- Labels are difficult to manage for economic operators 

The extensive labelling requirements under the FPR, however necessary and useful they 
are, lead to either overcrowded labels or artificial separation of the information (a part of 
it is provided on the label and the other part in a leaflet).   

Findings from the stakeholder survey on policy options as part of the digital labelling study 
(also referred to as the ‘policy option survey’) highlight negative feedback from industry 
in terms of costs and benefits of the status quo. There are concerns that the information 
requirements  are detailed in  the FPR and industry  stakeholders  expressed concerns that 
they would not be able to manage adequately to put all the information required onto a 
physical label. Both the capital costs and human resource costs of producing physical labels 
were viewed as being quite high38. The current one-off costs associated with the purchase 
of a machine printing labels was estimated to cost circa EUR 20,000/ factory by a medium-
sized  company  in  Ireland39.  Such  capital  investment  was  seen  as  necessary  due  to  the 
increased labelling requirements under the FPR. However, there can be the possibility for 
businesses to outsource the printing of labels to specialist printing companies that provide 
labelling  services  for  other  products.  In  those  cases,  such  one-off  costs  would  not  be 
incurred. 

The recurring cost of a physical label and leaflet combined for a 50 kg bag was seen as 
being  potentially  excessive  under  the  FPR40,  if  the  labelling  requirements  are  not 
digitalised,  but  no  precise  quantification  could  be  provided.  The  digital  labelling  study 
estimated the costs of providing an additional leaflet with the required label information 
with each bag as being 0.25 – 0.35 EUR on average41.  

In  addition,  industry  stakeholder  voiced  concerns  regarding  additional  requirements  for 
separate storage facilities for different languages with complicated logistics. Such factors 
have cost implications on the industry42. 

38 Expressed by several fertilising product producers during the interviews of the digital labelling study. 
39 Example used, as not enough data was collected to estimate a general figure, see Annex 9 for more details 
on the case study.  
40 As found during the interviews as part of the CSES and PPMI study mentioned before. For more details 
please see section 5.2.2. 
41 CSES and PPMI study mentioned before, Section 5.3.1.  
42 For a full breakdown of the costs associated with managing label information please refer to Annex 4.  

10 

 
 
                                                 
The lack of harmonisation rules on the provision of labelling information by digital means 
could also lead to different national rules or practices that would create difficulties in the 
free movement of EU fertilising products in the internal market. 

An environmental consequence is the increased waste of labels and packaging as all the 
labelling requirements, including those that are considered ‘frequently changing’ remain 
on the physical label, there will be frequent changes of the labels. In addition, there would 
not  be  enough  space  for  multilingual  labels.  When  using  separate  bags  produced  for 
different markets (with different languages), those need to be estimated up front often with 
long lead times. It is not always possible for economic operators to predict the quantities 
to  be  sold  in  different  markets  before  certain  changes  of  the  label  are  needed  or  what 
languages are required. As a result, this practise could result in excess printed product bags 
and labels, which are disposed of. 

2.3.  What are the problem drivers? 

  2.3.1.  Driver 1: extensive labelling requirements 

The label must at least contain the following information, according to Annex III to the 
FPR: 

 

 

 

 

the agronomic efficiency of the product, such as content of nutrients in a fertiliser;  

the content of the product, such as quantity or physical unit (granules, powder, etc.); 

the safety of the product, in  a broad sense, such as information  on nitrogen and 
phosphorus  relevant  for  the  implementation  of  the  measures  to  protect  the 
environment set out in the Nitrates Directive43;  

information  used  mainly  after  purchase,  such  as  storage  conditions  or  use 
instructions.  

The labelling requirements in the FPR are much more extensive compared to the labelling 
requirements in the EC Fertilisers Regulation44.  

Such extensive information is necessary because: 

  The label must accommodate the needs of different categories of readers:  

o  professional  users  (such  as  farmers),  mostly  interested  in  agronomic 
information,  and  less  in  use  instructions  as  they  know  how  to  use  the 

43 Council Directive 91/676/EEC of 12 December 1991 concerning the protection of waters against pollution caused by 
nitrates from agricultural sources, Official Journal L 375 , 31/12/1991 p. 1. 
44 In Annex 7 in the third column, it is mentioned if corresponding labelling requirements are laid down in 
EC Fertilisers Regulation for the categories of products covered by that Regulation.  

11 

 
 
                                                 
products and generally either rely on technical advice from consultants or 
are very familiar with the products they use45 46. 

o  The non-professional users (hobby gardeners) are less interested in various 
in  detailed  use 

interested 

agronomic  characteristics,  and  more 
instructions47.  

o  The conformity assessment bodies and market surveillance authorities use 
the  labelling  elements  so  that  they  can  easily  identify  the  relevant  legal 
requirements  applicable  to  the  respective  product  in  order  to  check  their 
compliance.  

  The  label  includes  information  used  at  different  points  in  time:  before  the 

purchase of the product, before or during its use or even for its disposal.  

  The  use  of  fertilising  products  may  vary  significantly  depending  on  external 
factors,  such  as  the  climatic  conditions,  type  of  soils,  type  of  crops,  season. 
Therefore, use instructions must be detailed, in order to be meaningful.  

  Fertilising products are at the beginning of the food chain. Therefore, the label 
holds information to ensure that their use will not compromise the crops’ quality.  
  The  use  of  fertilising  products  may  have  an  impact  on  the  environment. 
Therefore, various labelling requirements are needed to reduce negative impacts.  

  2.3.2.  Driver 2: there are no rules regarding the voluntary digitalisation of the 

labels  

According to the public consultation, more than two-thirds of manufacturers (100 out of 
138 respondents) provide information about their products online, but only 26% (47 out 
179) of them provide online the same information as the one included on the physical label.  

If an economic operator decides to provide information digitally, there are no rules on how 
this has to be done. Therefore, there are no guarantees that the user will receive all the 
labelling  requirements  in  the  digital  format  and  not  only  a  selection  of  the  respective 
information.  Such  information  could  be  mixed  with  marketing  data,  thus  making  more 
difficult the identification of the essential information in the digital format.  

  2.3.3.  Driver 3: some labelling information changes frequently 

Some  of  the  details  to  be  included  on  the  label  are  subject  to  frequent  changes.  The 
frequency  with  which  information  on  the  label  changes  is  an  important  trigger48  for 

45 CSES and PPMI study mentioned before, Section 52.1.3. 
46 In the case of professional use of plant biostimulants, for example, the sale is linked with the distributor/ 
consultant/ fertilisation report. The professional user knows the products, the conditions of use, because of 
accessing a technical data sheet, before ordering the product. 
47  Non-professional  users  in  general  are  more  reliant  on  labelling  information.  Primarily,  they  use 
information relevant after purchase as they are not as familiar with fertilising products as professionals are. 
Most non-professional do not use more technical information subcategories (e.g. neutralising value, chelating 
and  complexing  agents,  list  of  ingredients),  because  it  is  not  relevant  or  they  do  not  understand  such 
information. 
48 in response to a stakeholder survey,  manufacturers indicated that it is somewhat  harder to  manage  the 
frequently changing information categories on fertilising labels than the amount of labelling information in 
itself (33% compared to 29%, out of 62 responses). 

12 

 
 
                                                 
updating  and  revising  labels  –  which  might  mean  that  existing  bags  on  which  the 
information has been pre-printed, or labels already produced, become redundant and have 
to  be  discarded  and  disposed  of.  For  instance,  for  organic  fertilisers,  the  content  of  the 
organic carbon may vary from one batch to another, depending on the quality of the input 
materials used.  Therefore, it is useful to identify what information changes frequently and 
to consider whether that can be removed from the physical label and be digitalised in order 
to economise on redundant labels, bags and the resultant waste and potential harm to the 
environment from disposal of such labels and bags. 

This  issue  was  mentioned  in  the  course  of  the  interview  programme  by  several  major 
fertilising product manufacturers who pre-order bags, by industry associations of fertiliser 
producers  responding  to  the  inception  impact  assessment,  as  well  as  during  the  Expert 
Workshop where frequently  changing information as presented in  the spreadsheets (see 
Annex 7) was validated. For some smaller economic operators who print their own labels 
in-house this was found to be less of an issue49.    

For  a  comprehensive  overview  of  all  the  labelling  requirements  subject  to  frequent 
changes, see the fifth table column in Annex 7.  

  2.3.4.  Driver 4: Some EU fertilising products change their labels before reaching 

the end-users 

EU fertilising products may be bought by industrial users, meaning economic operators 
who are not end-users. The following categories of industrial users have been identified: 

1.  Blenders,  
2.  Importers or distributors placing products on the market under their own name or 
brand (they assume the role of a manufacturer and the producer of the product as 
such is no longer mentioned on the label) and 

3.  Importers or distributors packaging or repackaging products, without assuming the 
role  of  a  manufacturer  (for  instance,  they  may  repackage  products  in  smaller 
packages, mention the name of the producer on the label and their own name as 
repackagers). 

On the first category, the FPR creates extensive opportunities for the placing on the market 
of  fertilising  product  blends.  Blends  are  products  obtained  by  mixing  two  or  more  EU 
fertilising products without changing the nature of the respective products. Blenders: 

  buy  various  EU  fertilising  products,  which  are  already  labelled  and  which 

successfully passed a conformity assessment procedure; 
 mix them without changing their nature;  

 
  perform a limited conformity assessment procedure of the resulting blend with the 

scope of proving that no change in nature occurred and 

49 CSES and PPMI study mentioned before, Section 2.3.2.  

13 

 
 
                                                 
  Re-label  the  blend  by  including  the  information  requested  for  the  component 

products, presented in relation to the blend itself. 

On the second and third categories, importers or distributors buy EU fertilising products 
and relabel them before further selling. Rebranding seems to be a practice used extensively 
by the industry given the big interest shown by the industry in the legal rules applicable to 
this situation50. As regards packaging, as an example, ammonium nitrate fertilisers of high 
nitrogen content may be sold in bulk to importers or distributors but have to be packaged 
before being sold to the end-users.  

In all the three scenarios, the industrial users have to re-do the labels before selling the 
products. This increases the labelling costs for the industry as a whole, with no benefits for 
end-users.  

More generally, in some cases, manufacturers impede or limit distributors’ ability to source 
goods from other EU countries  (also known as territorial supply constraints) than the one 
in which they are based.  In some instances, distributors operate parallel trade and need to 
re-label  the  products  (often,  because  of  linguistic  and  labelling  requirements).  A  study 
carried out for the Commission51 found out through interviews that many distributors and 
manufacturers  organise  their  cross-border  operations  in  markets  that  share  the  same 
languages, such as in Benelux countries, France and Belgium, and Austria and Germany. 
Similar arrangements can be seen in countries with similar and mutually understandable 
languages,  such  as  in  the  Scandinavian  market.  In  the  same  way,  different  labelling 
practices regarding other aspects than language, such as eco-labels, might cause additional 
labelling costs. Digital labelling could make it easier and economically more interesting to 
engage in parallel imports. 

  2.3.5.  Driver 5: products sold in bulk need personalised leaflets 

Fertilising  products  are  also  sold  in  bulk.  Bulk  products  are  predominantly  used  by 
professional users, as they are more likely to buy in big quantities (e.g. 500 kg – 1000 kg 
of products)52. In such a case, manufacturers include the labelling requirements in a leaflet.  

Difficulties  in  implementing  this  obligation  of  providing  a  leaflet  with  all  the  labelling 
information have been flagged53 because the quantity of the product sold in bulk has to be 
included in such a leaflet. Or, by definition, the quantity of a product sold in bulk varies 
with each sale and is sometimes known just before the deal is concluded.  

In addition, a leaflet accompanying products sold in bulk does not necessarily fulfil the 
same  function  as  a  label  attached  to  a  package.  Immediate  access  to  the  labelling 

50 See the documents and recording of the info  session for industry ‘How to CE-mark your products’, 23 
May  2022.  More  than  1300  participants  registered  for  this  event  and  many  questions  have  been  sent  in 
advance regarding this issue.  
51  Half  of  EU  fast  moving  consumer  goods  sellers  experience  supply  constraints  based  on  their  location 
(europa.eu)  
52 CSES and PPMI study mentioned before, Sections 5.2.2.3 and 5.2.2.5. 
53 CSES and PPMI study mentioned above, Section 5.3.1.2. 

14 

 
 
                                                 
requirements  is  not  guaranteed  given  the  physical  separation  between  a  leaflet  and  a 
product.  

2.4.  How likely are the problems to persist? 

Without any policy intervention, the problems associated with labels that are difficult to 
read and manage will subsist given that their drivers are linked to provisions of the FPR.  

As FPR applies only as of 16 July 2022, it has been impossible to predict the percentage 
of  enterprises  opting  for  FPR  rules  compared  to  those  opting  for  national/mutual 
recognition rules. This will be determined in the first report on the application of the FPR 
in 2026. Even so, it will present the picture at a certain point in time, and not necessarily 
how it would evolve. The decision to opt for the harmonisation rules is neither irreversible 
nor subject to a deadline. Therefore, manufacturers can make this choice anytime and may 
also  change  this  decision  depending  on  their  interests.  It  is  estimated  that  the  2003 
Fertilisers Regulation54, covered 50% of inorganic fertilisers available on the EU market, 
while the other 50% are known as ‘national fertilisers’ and can circulate within the EU 
based on meeting the equivalence of applicable  national requirements under the mutual 
recognition principle and the 2019 Regulation on Mutual Recognition55. 

As  the  2003  Fertilisers  Regulation  only  covers  inorganic  (mineral)  fertilisers,  the 
percentage of EU fertilising products covered by the FPR is expected to increase. One of 
the  main  drivers  of  adopting  the  FPR  has  been  to  open  the  market  to  more  innovative 
products, thereby attracting more manufacturers and boosting the internal market.  

The social, economic and environmental consequences are expected to grow because: 

  Taking  opportunity  of  the  free  movement  of  fertilising  products  on  the  internal 
market, under the FPR, more and more manufacturers will most likely make the 
choice to rely on the harmonisation rules in the coming years, given the advantages 
of the CE-marking; 

  a growing number of economic operators will adopt digital labelling in different 
formats in the context of e-commerce or to better promote their products. This will 
further accentuate the already envisaged discrepancies, as economic operators will 
have no obligations in terms of the information to be provided digitally and the way 
to do it.  

54 Regulation (EC) No 2003/2003 of the European Parliament and of the Council of 13 October 2003 relating 
to fertilisers 
55 Regulation (EU) 2019/515 of the European Parliament and of the Council of 19 March 2019 on the mutual 
recognition  of  goods  lawfully  marketed  in  another  Member  State  and  repealing  Regulation  (EC)  No 
764/2008; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019R0515 

15 

 
 
                                                 
3.  3. WHY SHOULD THE EU ACT?  

3.1.  Legal basis 

The  FPR  is  based  on Article  114 TFEU  on  the  approximation  of  national  rules  for  the 
establishment  and  well-functioning  of  the  internal  market.  This  initiative  concerning 
possible amendments to the FPR would have the same legal basis.  

This initiative is subject to the shared competence of the EU, and therefore the subsidiarity 
and proportionality principles apply. 

3.2. 

Subsidiarity: Necessity of EU action 

This initiative aims to improve communication of the information on the label of fertilising 
products  to  facilitate  their  free  movement  in  the  internal  market,  while  maintaining  the 
high  standard  of  protection  of  human,  animal  and  plant  health,  of  safety  and  the 
environment.  

The extensive labelling requirements are laid down in Annex III to the FPR and have to be 
provided  on  the  physical  label.  Part  of  the  information  requested  therein  is  subject  to 
frequent changes and, in accordance with the same Regulation, labels of certain products 
have to change before reaching the end-users. The FPR is a Regulation directly applicable 
in  all  Member  States.  Therefore,  Member  States  cannot  adopt  efficient  national 
measures to improve the readability of labels or avoid their frequent changes.  

The  problems  identified  have  a  strong  cross-border  dimension.  Inorganic  fertilisers 
subject  to  EC  Fertilisers  Regulation  are  produced  in  a  handful  of  EU  countries56  and 
products are sold all over the EU. The FPR aims both at maintaining these products within 
its  scope  and  at  attracting  new  products,  which  have  not  been  previously  covered  by 
harmonisation rules.  

The objective of this initiative cannot be achieved sufficiently by the Member States, but 
can be better achieved at Union level.  

3.3. 

Subsidiarity: Added value of EU action 

Member States could tackle at national level part of problem 2, by adopting national rules 
regarding minimum standards for the digitalisation of the labels, given that this issue is not 
yet  covered  in  the  FPR  itself.  Such  an  approach  would  unavoidably  lead  to  different 
practices all over the EU and create obstacles in the functioning of the internal market. It 
could  lead  to  inequalities  in  terms  of  potential  cost  savings  and  communication  of 
information. It would also increase costs for industry to adapt to divergent digital labelling 
requirements in Member States. On the contrary, introducing at EU level the conditions for 
the digital label has the added value of harmonising the various practices. By creating a 
level playing field, such an initiative would improve the functioning of the internal market, 
while ensuring the high standard of protection required by the FPR.  

The benefit of EU action also lies in the existence of potential economies of scale in the 
fertilising products industry. The harmonisation of digital labelling requirements across the 

56 see footnote 26. 

16 

 
 
                                                 
EU  could  facilitate  the  use  of  multi-lingual  labels  and  thus  support  the  distribution  of 
products with the same label in more than one Member State.  

4.  4. OBJECTIVES: WHAT IS TO BE ACHIEVED? 

The links between the problems identified and the objectives of this initiative are presented 
in Table 4.1. 

17 

 
 
 
 
 
Table: 4.1 Links between problems and objectives 

Problems 

Objectives 

labels  are 
Problem  1: 
difficult  to  read  because  of 
the  extensive  requirements 
under the FPR 

General objective 1: achieving a high level of protection of human, 
animal and plant health, of safety, and of the environment 

Specific  objective  1:  Improve  the  readability  of  the  labels  of  EU 
fertilising products 

Problem  2: 
labels  are 
difficult to manage because 
extensive 
of 
requirements under the FPR 

the 

General  objective  2:  Ensure  the  effective  functioning  of  the 
Internal Market in fertilising products through harmonisation across 
the EU-27 

Specific objective 2: Facilitate the managing of labels by economic 
operators 

4.1. 

4.1. 

General objectives 

In accordance with Article 114 TFEU, the general objectives of this initiative are same as 
the FPR objectives.  

1.  General objective 1: achieving a high level of protection of human, animal and 

plant health, of safety, and of the environment 

A detailed assessment of all labelling requirements in Annex III has been done and 
all the information linked to the protection of human, animal and plant health, of 
safety and of the environment has been identified and classified as ‘safety’ (S). For 
a  comprehensive  overview,  see  the  fourth  column  in  Annex  7.  Some  policy 
measures keep on the label all the Safety labelling requirements, while others 
keep all those requirements linked to imminent risks. For more details, see Section 
5.3 on policy measures.  

2.  General  objective 2: Ensure the  effective functioning of the  Internal  Market  in 

fertilising products through harmonisation across the EU-27 

Some  fertilising  products  manufacturers  are  already  using  digital  labelling  on  a 
voluntary basis, in addition to the physical label. By defining the general digital 
labelling  principles  (see  section  5.3.1.)  that  have  to  be  followed  by  all 
manufacturers who opt for the digital labelling of EU fertilising products, as well 
as what information can be provided only on the digital label, this initiative would 
create a level playing field among economic operators and thus facilitate the free 
movement in the internal market. 

4.2. 

Specific objectives 

  SO1: Improve the readability of the labels of EU fertilising products  

The  readability  of  labels  contributes  to  a  high  protection  of  human,  animal  and 
plant health, safety and the environment. It can be improved by putting in place the 
rules needed for the digital labelling of EU fertilising products.  

18 

 
 
Yet, any such option to address this problem should also take account of the digital 
divide, which may exist for certain social groups (e.g. elderly segments of society, 
farmers with small holdings, others who may lack basic digital skills) or difficulty 
in accessing the internet (e.g. in rural areas). 

  SO2: Facilitate the managing of labels by economic operators 

Especially in times when fertilising products are more expensive than ever before, 
it  is  important  to  ensure  that  they  can  circulate  more  freely.  Extensive  labelling 
requirements,  particularly  in  a  specific  language,  could  impede  or  discourage 
manufacturers  from  applying  the  FPR  and  sell  their  products  in  other  Member 
States and from benefiting from the economies of scale and the lower production 
costs that result from them. 

In the digital labelling study, during the interviews with industry representatives it 
was further found that those enterprises currently selling in multiple markets within 
the  EU  may  face  problems  related  to  space  on  physical  labels,  as  economically 
seen, it is better to provide one label with more languages. 

5.  5. WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1. 

5.1. 

What is the baseline from which options are assessed? 

The  baseline  includes  a  brief  description  of  the  wider  socioeconomic  context  and  the 
relevant  market  and  legal  developments  that  might  impact  on  the  magnitude  of  the 
problems 

  5.1.1  The socioeconomic context 

The fertilisers industry faces difficult challenges because of the high prices of energy and 
gas, as well as the availability of certain raw materials following the war of aggression of 
Russia against Ukraine.  

Consequently, in the course of the next decade: 

  Further improvements in the efficiency of the production process and the promotion of 

the products are to be expected; 

 

Industry will probably also massively invest in the production of fertilising products 
out of various waste streams or by-products, making good use of the circular economy 
opportunities in the FPR.  

  5.1.2  Agriculture 

The efforts undertaken for the digitalisation of the agriculture will intensify.  

As already indicated, commitments have been made at political level to reduce the loss of 
nutrients and consequently the use of fertilisers by 2030.  

In the next decade, it is estimated that: 

19 

 
 
  a further concentration of the land within larger farms is to be expected, which would 
imply a more centralised management of fertilising products, with less obvious digital 
divide; 

  Digital tools, including precision fertilisation by using various digital tools will be used 

more and more, with decisive role in nutrient use efficiency. 

  Farmers will keep more and more often various registries in a digital format, including 
those  regarding  the  use  of  fertilising  products  and  the  information  needed  to  prove 
compliance with the limit-values in the Nitrates Directive57.   

  5.1.3  Hobby market 

The number of people in the hobby market within the EU is well over 100 million.58  

Given the general trend to motivate non-professional users to try indoor planting, the aging 
of  the  population,  the  increased  life  expectancy,  the  longer  growing  seasons  (global 
warming), as  well as sustainability  and ecological  trends, it is  estimated that the hobby 
market will continue growing in the next decade.59 

  5.1.4  Digital divide  

Digital literacy is not uniform across the EU-27. It varies by age group and social group. 
Younger  people  are  considerably  more  digitally  literate  than  older  people  are.  Basic 
computer skills have been consistently growing in most of the EU Member States. 
Access to broadband internet has improved significantly in the past decade60. This has been 
driven by different factors, such as major increases in investment in fixed line and mobile 
broadband  access61  62.  The  increasing  ubiquity  of  smart  mobile  phones  has  made 
broadband access much easier for professional and non-professional users on the move to 
access information about fertilising products. 

Some professional  users can be at  a disadvantage in  the context  of the digitalisation of 
fertilising product labels because many farms are located in rural areas, which have worse 
internet connectivity, and farmers are often older citizens, potentially having limited digital 
skills63.  

57 The Nitrates Directive aims to protect water quality across Europe by preventing nitrates from agricultural 
sources polluting ground and surface waters and by promoting the use of good farming practices. 
58 https://de.statista.com/statistik/daten/studie/171446/umfrage/besitz-eines-gartens/  
59 Gardening in Europe: Emerging Markets and Future Prospects - Euromonitor.com   
60  The Digital Economy and Society Index (DESI) | Shaping Europe’s digital future (europa.eu) 
61 The Digital Economy and Society Index  DESI reports on broadband internet access at national level. 
62 The most recent 2021 DESI Scoreboard found that the problem of the digital divide in rural areas may not 
be as pronounced today as it was 5-10 years ago due to rapid rollout of broadband, with mobile broadband 
making internet access widely accessible except in some rural pockets. The 2021 DESI Scoreboard found 
that 97% of the EU (including rural areas) provide access to either a fixed or mobile broadband connection, 
or both. 
63Digital society statistics at regional level - Statistics Explained (europa.eu)   

20 

 
 
                                                 
During the Covid-19 pandemic, digital divides have grown in significance, widening pre-
existing inequalities and becoming a key factor of social exclusion.64   

It  is  expected  that  in  the  next  decade  the  digital  divide  will  attenuate,  given  the  steady 
progress made both in improving the digital skills and in expanding the internet access65.  

  5.1.5  Share of companies already embracing digitalising product information 

The digital labelling study found that there is a positive trend in digitalisation of fertilising 
product information generally, and labelling in particular. According to the policy options 
survey,  43.8%  (14  out  of  32  respondents)  of  fertilising  product  manufacturers  already 
provide some labelling information digitally, primarily through 2Dcodes (QR codes) and 
websites or a URL link. Moreover, the targeted stakeholder survey launched as part of the 
digital labelling study (also referred to as the ‘stakeholder survey’) found that somewhat 
more, 65.4% of manufacturers provide information in a digital format via the physical label 
(17 out of 26 respondents, of these, approximately half were SMEs). Furthermore, in the 
public  consultation  26%  (47  out  of  179)  of  respondents  indicated  that  they  provide  the 
same information via IT or digital tools as they provide on the physical label, and 48% of 
respondents indicated that they provide additional/ complimentary information to that on 
the physical label (74% in total). These data are important data for the baseline as they 
suggest  that  between  almost  50%  (1798)  and  75%  (2696)  of  the  3595  enterprises  in 
fertilising products industry are already digitalising product information to some degree, 
which  will  have  an  important  bearing  on  future  user  take-up  and  the  costs  under  the 
different policy options. During the data gathering process of the digital labelling study, it 
was found that none of the Member States have set rules on digitalisation of labels under 
their  national  fertilising  product  rules.  This  means  that  the  manufacturers  providing 
information digitally do so voluntarily and only on top of the rules set for physical labels 
(i.e. they provide the same information or additional information digitally).Furthermore, 
according to the Public Consultation, about half (52.1%, out of 153) of  the respondents 
indicated  that  they  would  evaluate  a  shift  to  digital  labelling  of  at  least  some  product 
information positively: moderately positively (16.2%) or very positively (35.9%), if some 
information was removed from the physical label and could only be obtained via digital 
labels. The stakeholder survey also showed that 47.7% of manufacturers would be ‘very 
likely’  and  15.4%  ‘likely’  to  provide  some  of  the  information  required  under  FPR  in  a 
digital format (total of 41 out of 65 responses). 

Within  the  dynamic  baseline,  it  is  also  worth  noting  that  the  percentage  of  enterprises 
operating a website is likely to increase year-on-year. EUROSTAT data shows a figure of 
94% of large enterprises and 77% of SMEs (in all non-financial sectors) having a website.66 
Moreover, there has been a steady increase since 2012 when the comparable figures were 
93% of large enterprises and 69% of SMEs with a website. In this context, it is likely that 

64 Study on post Covid measures to close the digital divide (europa.eu) 
65 See Annex 10 for more details on trends in digitalisation.  
66 Data available at: https://ec.europa.eu/eurostat/statistics-
explained/index.php?title=File:Enterprises_having_a_website,_by_functionality_and_size_class,_EU,_202
1_(%25_of_enterprises).png  

21 

 
 
 
                                                 
many enterprises will introduce digital labelling as part of a broader strategy to digitalise 
their operations or at least provide a website.  

  5.1.6  Continuation of the existing legal framework  

Details of how the dynamic baseline was developed can be found in the digital labelling 
study, section 5.1.  

The analysis of the dynamic baseline shows that:  

  As the manufacturers of EU fertilising products will continue to provide on the physical 
label all the relevant information in Annex III to the FPR, they will have to pay the 
costs of frequent changes of the label and of multiple labels to cover all the official 
languages needed.  

  Given the general trend towards encouraging increased uptake of digital labelling by 
EU  regulators,  it  is  estimated  that  the  number  of  economic  operators  providing 
information digitally regarding their products will increase steadily.  

  We assume that the European Parliament and the Council will accept digital labelling 
as part of the revision of the CLP Regulation,  and that  information requested under 
CLP  Regulation  for  fertilising  products  containing  hazardous  substances  will  be 
provided digitally. The precise timing of entry into force and the labelling information 
considered are unknown. So, take-up of digital labelling by producers of fertilisers may 
therefore  be  influenced  by  the  extent  to  which  other  EU  legislation  requires  or 
voluntarily encourages digital labelling. 

  Distributors might have to take on board the cost for the translation of the label in the 

official language of the EU country where they sell the products. 

  Given that there are currently no general principles or rules, the users are not offered 
any  guarantees  on  the  quality  of  the  information  provided  digitally  and  the  digital 
information that is provided may be incomplete.  

As a general conclusion, the negative consequences identified in this section are expected 
to increase.  

  5.1.7  Digital product passport 

The  proposal  for  a  Regulation  on  Ecodesign  for  Sustainable  Products  sets  out  the 
framework for a Digital Product Passport (DPP). According to this proposal, the DPP will 
include new mandatory information relevant to product sustainability (such as recyclability 
or energy efficiency) and regulatory compliance information about the product (technical 
file, declaration of conformity). In addition, an inventory of all materials and raw materials 
used in a product, and a full list of chemical contents may be required. This could make it 
easier to facilitate tracking along the supply chain, for instance, for substances of concern.  

The  detailed  requirements  will  be  determined  on  a  product-by-product  basis  in  a 
subsequent step. Consequently, product-specific requirements are not yet determined for 
fertilising products, nor are these products, so far, included on the ‘priority’ list currently 
under development by the Joint Research Centre. The methodology of identifying products 
or  product  groups  for  such  a  list  is  currently  being  developed.  In  the  preliminary 
discussions, EU Fertilising products have not been considered as a priority, mainly as the 

22 

 
 
 
potential for contribution to achieving Union climate, environmental and energy efficiency 
objectives, and the potential for improving circularity and sustainability performance of 
other product groups has been identified with room for great improvement and therefore 
priority over EU fertilising products. Therefore, the DPP is not considered in the dynamic 
baseline scenario (10 years).  

Nevertheless,  the  requirements  set  under  the  DPP  will  necessarily  influence  how  far 
manufacturers in the sector will be required to provide digital information, and will lead to 
increased  digitalisation  of  product  information,  also  for  fertilising  products.  Therefore, 
establishing  a  framework  for  digital  labelling  under  this  initiative,  can  contribute  to 
futureproofing  the  Regulation,  ensuring  consistency  with  trends  of  digitalisation. 
Synergies between the two initiatives have been considered as regards how the information 
is to be provided (i.e. in a decentralised system) and accessed (e.g. via one QR code placed 
on a product, which would lead to information under the DPP, labelling information as 
well as other information). Thus, even though the type of information to be provided is 
different, it is important to ensure that when information is provided digitally concerning 
a product, it ends up all in one place. The information that could need to be provided under 
the DPP has thus far only been set in broad terms in the regulatory proposal for the Eco-
design  for  Sustainable  Products  Regulation  from  March  30th  2022.  The  detailed 
implementing  rules  will  be  determined  on  a  product-by-product  basis.  However,  the 
information required under the DPP will be additional to the labelling requirements of the 
FPR,  e.g.  information  relevant  to  product  sustainability,  such  as  information  about 
components and their recyclability, and therefore no overlaps or inconsistencies  can be 
expected in terms of online information as part of applying the two rules. 

5.2.  Description of the policy options 

All FPR labelling requirements are necessary to protect the user and the environment, and 
they  are  essential  for  the  correct  application  of  the  fertilising  product.  Therefore,  their 
partial abolition was not envisaged.  

Furthermore, it is also important, both for the protection of the user and the environment 
as for the correct application of the fertilising product, that the information is available in 
a language easily understood by the user. Correspondingly, any changes in the language 
regime of the labels was also discarded in the design of the policy options.  

Details on the methodology of how the policy measures and options were developed can 
be found in Annex 4. The selection of the information that could be moved to a digital 
label  under  the  policy  measures  take  into  account  which  categories  of  information  is 
essential to which categories of stakeholders, and their attitude toward digital labelling. 

The  table  below  gives  an  overview  of  the  findings  from  the  different  data  collection 
activities67  of  the  digital  labelling  study  of  the  views  of  stakeholders  towards  certain 

67 Findings from the interviews, public consultation, focus groups and survey experiment as part of the CSES 
and PPMI study mentioned before. 

23 

 
 
 
                                                 
categories of information required to be labelled on an EU fertilising product (for more 
information please see the digital labelling study, section 5.2.1): 

Table:  5.2  Views  of  stakeholders  towards  certain  categories  of  information 

required to be labelled on an EU fertilising product 

Type of user 

Category of information on a label 

Professional 
users 

Non-
professional 
users 

Agronomic efficiency 

  Generally essential 
  Nutrient content is 
most important 

  Less important 
  Nutrient values are 

read by avid 
hobbyists 

  Complex technical 
information is hard 
to understand (e.g. 
neutralizing value, 
references to 
chelating and 
complexing agents) 

Safety 
requirements 
 Important, but 

75.5% 
perceived can 
be digitalised 
either fully or 
partially  

 Essential 

Information relevant 
after purchase 

Information on content 

  Less important 
  Use instruction are 

  Important 
  Granulometry was 

mostly read when the 
fertilising product is 
unfamiliar 

  Storage conditions are 

not important 

divisive 

  Form of physical unit 

may be provided 
digitally 

  Essential 
  Use instructions and 
target plants are most 
important 

  Less important overall 
  Granulometry, form of 
physical unit are less 
important 

  Production and 
expiration date 

  List of ingredients was 

divisive 

Manufacturers 

  Essential 

 Essential 

  Would prefer 
digitalisation  

  Would prefer 
digitalisation 

Brief explanation of what is included in the different categories of information: 

  Agronomic efficiency (AE): information directly linked to the function of the EU 
fertilising product (example: nutrients for fertilisers; neutralising value for liming 
materials). 

  Safety requirements (S): those labelling requirements ensuring high protection of 
human health and the environment (example: risk management measures, nitrogen 
and phosphorus content relevant for the implementation of the Nitrates Directive, 
urea effects on air quality). 

  Information relevant to after purchase (AP): this information is predominantly 
referred  to  after  the  product  is  bought  (for  example,  use  instructions,  storage 
conditions or disposal measures). 

  Information on content (IC): other information on what the product contains, not 
directly  linked to  its agronomic efficiency  (for  example:  physical  unit, quantity, 
production date). 

  5.2.1.  Differences between professional and non-professional users 

The design of the policy options took account of stakeholder consultations that confirmed 
differences in views both between, and within particular stakeholder categories regarding 
attitudes towards digital labelling and regarding the information on product labels, which 

24 

 
 
 
could be subject to digitalisation. Some of the main differences were between professional 
and non-professional users in terms of attitudes towards whether some information could 
be fully moved digitally or not. Generally speaking, professional users were slightly more 
in favour of more digital labelling, compared to non-professional users68. Further, the type 
of information  a professional  user considers essential,  differs substantially  from  what  a 
non-professional user finds essential. For example, professional users might be interested 
in technical aspects of the product, such as the content of all various forms of nitrogen, 
inhibitors,  chelated  and  complexing  agents,  while  they  are  not  that  interested  in  use-
instructions. This is because they have well defined fertilisation plans and mostly rely on 
technical advice on how to use products69. On the other hand, such technical information 
is often not understood by non-professional users, who rather use a fertilising product label 
to obtain use instructions; i.e. on which plants the product can be used, in which quantities 
and through which application methods. 

Further, criteria that help product users purchase products vary considerably. The digital 
labelling study found that most (47.4%, out of 253) of professional users rely on the advice 
from  colleagues  and  advisors  to  help  make  a  purchase  decision,  while  most  non-
professional  users  (35.8%,  out  of  327)  research  products  ahead  of  buying  them.  Both 
professional and non-professional users rarely indicated that they rely on the label to make 
an on-the-spot decision to purchase a product in a shop (11.9%, out of 253 and 15.9%, out 
of 327 respectively).  

Such differences raised the question if a clear distinction between professional and non-
professional users can be made in the labelling requirements of the FPR in determining  
what  information  should  remain  on  the  label  physically  and  what  information  can  be 
presented digitally. Such a distinction is therefore made in some of the policy measures 
presented, and the relevant impacts of such a distinction are assessed. Under those policy 
measures that do not make a distinction, the information moved online gives precedence 
to the information used more by professional users and less by non-professional users.  

A distinction between products destined for the different user groups is currently not made 
in  the  FPR.  However,  during  the  ad-hoc  meeting  of  the  Commission  expert  group  on 
fertilising  products  on  15  March  202270  (also  referred  to  as  the  ‘ad-hoc  expert  group 
meeting’). organised to discuss the different policy options, it was raised by authorities and 
industry associations that generally there was no concern regarding the implementation of 
such a distinction, mainly because products destined for professional use are often supplied 
in large quantities.  

  5.2.2.  The stability of the information provided over time  

As explained in section 2, the frequency with which information on the label changes is an 
important trigger for updating and revising labels, as fast changing information might mean 
that existing labels already produced become redundant and have to be reprinted, meaning 

68 During the survey experiment, 80,1% of professional users indicated preferences for full or partial digital labelling, 
while 72.4% of non-professional users indicated preferences for full or partial digital labelling of EU Fertilising products.  
69 CSES and PPMI study mentioned before, Section 2.3.5. 
70 minutes available here: Circabc (europa.eu)) 

25 

 
 
                                                 
the  old  ones  are  discarded  and  disposed  of.  Therefore,  in  the  development  of  policy 
measures, it was important to identify what information changes frequently and to consider 
with priority  whether that can be removed from  the physical label and be digitalised in 
order to economise on redundant labels and the resultant waste and potential harm to the 
environment from disposal. To this end, as part of the development of policy measures, the 
stability of information over time (frequently changing or not) has been assessed for each 
labelling requirement (see the fifth column in Annex 7).  

5.2.  Presentation of the policy measures: 

The  policy  options  have  been  constructed  by  selecting  from  a  comprehensive  list  of 
potential policy measures based on the extensive findings of the digital labelling study (see 
section  5.2  for  more  details).  These  measures  were  screened71  to  identify  those  policy 
option bundles that should be retained for further analysis. The screening process resulted 
in  a  list  of  6  policy  measures  retained  for  the  impact  assessment  (see  Table  5.3).  The 
measures are packaged into 6 policy options which address the specific objectives.  

Table: 5.3 Presentation of the policy measures 

Measure  Description 

Details 

Measure 
1 

Retaining all information 
on  physical  labels  and 
supporting  the  voluntary 
use of digital labels by a 
guidance document 

Measure 
2 

Certain information may 
be  provided  digitally 
(without 
distinction 
between 
professional/non-
professional users) 

on 

the 

provided 

Under this non-legislative measure, all label information 
is 
label/accompanying 
document/leaflet.  The  only  difference  regarding  the 
current practice is that the Commission would develop 
guidelines  (with  best  practises  and  examples)  for 
operators who would intend to provide the information 
digitally, too.   

Amendment to the FPR to allow some label information 
to be provided only digitally, on a voluntary basis. 

The  information  that  may  be  provided  only  digitally 
includes; 
 

safety 

linked 

to 
changing 

Information subject to frequent changes, if it is 
(e.g. 
not 
from 
frequently 
categories:  agronomic  efficiency,  information 
relevant  to  after  purchase,  information  on 
content72).  

requirements 
information 

  Various technical details not subject to frequent 
changes, if it is not linked to safety criteria (e.g. non- 
frequently  changing  information  from  categories: 

71 Screening (see CSES and PPMI study mentioned before, Section 5.4) was developed in accordance with 
Tool #17 of the Better Regulation Toolbox. The longlist of measures were assessed against eight criteria, 
namely:  legal  feasibility,  technical  feasibility,  stakeholder  acceptability,  effectiveness,  efficiency, 
proportionality, EU value added and coherence. 
72 For a full list of what information can be moved to a digital label under measure 2 please see Annex 7, the 
8th column.  

26 

 
 
                                                 
Measure 
3 

a 

Certain information may 
be  provided  digitally 
distinction 
with 
users 
professional 
3a)/non-
(measure 
professional 
users 
(measure 3b) 

Measure 
4 

be 

Most  of  the  information 
provided 
may 
(without 
digitally 
distinction 
between 
professional/non-
professional users) 

Measure 
5 

be 

Most  of  the  information 
provided 
may 
the 
digitally 
distinction 
between 
professional  users  (5a) 

with 

agronomic efficiency, information relevant to after 
purchase). 

As measure 2, with the following differences: 

  The information allowed under the digital label 
depends on the need of immediate access to the 
information for a particular user (professional or 
non-professional).  

  Most  of  the  information  relevant  to  after 
rates)73  under 
(e.g.  application 

purchase 
measure 3a for professional users.  

  The various technical details under measure 3b 
for non professional users focus in particular on 
  and  Agronomic 
Information  on  Content 
Efficiency (e.g. declaration of presence of forms 
of nitrogen (N)74). 

As measure 2, with the following differences: 

Information  that  may  be  provided  digitally  includes 
additional 
in 
particular: 

requirements 

including 

labelling 

  Most  of  the  information  relevant  to  after 

purchase (e.g. application rates)75.  

  Most of the information on content (e.g. form of 

the physical unit)76. 

  Most of the information relevant to agronomic 
efficiency  (e.g.  the  content  of  the  declared 
primary  nutrients  total  nitrogen  (N),  total 
phosphorus in the form of phosphorus pentoxide 
(P2O5)  or  total  potassium  in  the  form  of 
potassium oxide (K2O))77. 

As measure 3, with the following differences:  
Information  that  may  be  provided  digitally  includes 
additional labelling requirements, in particular: 

For measure 5a: 

73 For example, over 90% of all possible AP label information is allowed to be included under the digital 
labelled for a PFC 1 (fertiliser) product. For the full list of information which could be moved to a digital 
label under measure 3a please see Annex 7, the 9th column. 
74 For a full list of what information can be moved to a digital label under measure 3a and 3b please see 
Annex 7, the 9th and 10th columns. 
75 For example, over 90% of all possible AP label information is allowed to be included under the digital 
label only for a PFC 1 (fertiliser) product. For the full list of information which could be moved to a digital 
label under measure 4 please see Annex 7, the 11th column. 
76 For example, over 90% of all possible IC label information is allowed to be included under the digital label 
only for a PFC 1 (fertiliser) product.  
77 For example, over 88% of all possible AE label information may be included under the digital label only 
for a PFC 1 (fertiliser) product.  

27 

 
 
 
 
                                                 
non-professional 

and 
users (5b) 

 

Information subject to frequent changes, if it is 
not  linked  to  imminent  risks  to  human  health 
and  environmental  protection  (this  included 
parts of Safety information, e.g. declaration of 
the  content  of 
the  substance  exceeding 
maximum residues limits78)  
the 

information  on  content and 

  Most  of 

Measure 
6 

information 
All 
provided  digitally 
certain 
products 

is 
for 
categories  of 

agronomic efficiency. 

For measure 5b:  

-  Most  of  the  information  on  content  and 

agronomic efficiency information. 

Amendment  to  the  FPR  to  allow  all  information  in 
Annex III to be provided only digitally on a voluntary 
basis for: 

(1) products sold in bulk79 (without product packaging) 
and; 

(2) products for industrial users (blenders, packagers, re-
packagers).  

  5.3.1.  Information which could be moved from the physical label to digital label 

Information requirement 

Table 
5.3.1: The 
table below 
sets out the 
information 
that can be 
digitalised 
under 
Measure 2. 
Category 

IC 

AE 

 
 
 
 
 

 
 
 

 

List of all ingredients above 5 %, including the name of the substances 
Relevant CMC  
Identification number of the substance  
Production date (PFC 1, PFC 4, PFC 6)  
Declaration of counter-ions of micronutrients in the inorganic micronutrient fertiliser 

Content of organic carbon (PFC 1, 2) 
Dry matter 
Content of water-soluble calcium oxide (CaO), magnesium oxide (MgO), sodium oxide (Na2O) 
and sulphur trioxide (SO3)  
The ratio of organic carbon in total nitrogen (PFC 1, 3) 

78 For all safety information moved under option 5a, please refer to Annex 7, the 12th column. 
79 Such products are mostly used by professional users. 

28 

 
 
  
 
                                                 
Information requirement 

Table 
5.3.1: The 
table below 
sets out the 
information 
that can be 
digitalised 
under 
Measure 2. 
Category 

 

 

Declaration of the water-soluble content of micronutrients in an organo-mineral fertiliser or an 
inorganic fertiliser  
Declaration of the amount of chelated/complexed micronutrients in an organo-mineral fertiliser 
or an inorganic fertiliser  

  Where  the  declared  micronutrients  are  chelated  by  chelating  agent(s),  the  pH  range 

guaranteeing acceptable stability  

  % of fertiliser coated by each coating agent  
 
 

the typology of straight inorganic micronutrient fertiliser   
Reactivity  and  method  of  determination  of  reactivity,  except  for  oxide  and  hydroxide  limes 
(PFC 2) 
pH (PFC 3, 4) 
the content of inhibiting compound (PFC 1, 5) 
Effect claimed for each target plant (PFC 6) 
Concentration of micro-organisms (PFC 6) 

Certain use instructions 

 
 
 
 

 

AP 

Table 5.3.2: The table below sets out the information that can be digitalised under Measure 
3a.  

Category 

Information requirement 

IC 

AE 

AP 

 

Same as measure 2 

In addition to measure 2 
Content of various forms of nitrogen and phosphorus 
 
No longer digitalise certain technical information from measure 2 
 
 

Reactivity (PFC 2) 
pH (PFC 3, 4) 

 
 

all use instructions, except targeted plants 
all storage conditions 

Table 5.3.3: The table below sets out the information that can be digitalised under Measure 
3b. 

Category 

Information requirement 

IC 

AE 

In addition to measure 2 
granulometry 
 
forms of the physical unit 
 
content of organic nitrogen in PFC 3 
 

In addition to measure 2 
 
 
 

presence and content of various forms of nitrogen and phosphorus 
presence of water-soluble forms of nutrients 
declaration of chelating, complexing and coating agents 

29 

 
 
Category 

Information requirement 

 
 
 

 

AP 

the presence of inhibitors 
content of calcium oxide and magnesium oxide in PFC 2 
strains of microorganisms in PFC 6 

certain use instructions 

Table 5.3.4: The table below sets out the information that can be digitalised under measure 
4 and measure 5b (the information is the same).  

Category 

Information requirement 

IC 

AE 

In addition to measure 3a 
 
 

for of the physical unit 
presence of organic nitrogen in PFC 3 

In addition to measure 3a 
Content of nutrients 
 
Declaration of soluble forms of macronutrients 
 
Content  of micronutrients in macronutrient fertilisers 
 
Chelating, complexing and coating agents  
 
Reactivity for PFC 2 
 

AP 

Same as measure 3a 

Measure  5a:  The  table  below  sets  out  the  information  that  can  be  digitalised  under 
Measure 5a. That which is in addition to Measure 4 is indicated in bold text.  

Category 

Information requirement 

IC 

AE 

AP 

S 

Same as measure 4 

In addition to measure 4 
 

strains of microorganisms PFC 6 

 
 

All use instructions 
All storage conditions 

  Warnings  regarding  maximum  residues  limits,  animal  by-products,  when  using  fertilisers  with 

micronutrients 
Content of manganese, selenium, chloride 
Air quality impact of urea 
Content of copper and zinc 

 
 
 

  5.3.2.  Principles for digital labelling 

All possible measures would be underpinned by some fundamental principles in order to 
protect  end-users  and  to  ensure  the  accessibility,  availability  and  quality  of  digital 
information. To maximise efforts of consistency in terms of ‘how’ digital labelling could 
be  allowed,  these  principles  are  also  introduced  under  the  Impact Assessments  which 
include digital labelling for other areas of chemical legislation, i.e. CLP and Detergents. 
These principles should support creating a level playing field for the chemicals industry. 
They aim to safeguard the otherwise adverse impacts digital labelling could have on those 
impacted  by  the  digital  divide.  Such  principles  could  further  assist  in  enforcing  the 
labelling rules. 

30 

 
 
 
Economic  operators  could  only  put  digital  labels  on  their  products  under  any  of  the 
following Policy Options 2-6 when they would apply these mandatory principles.  

Principles for digital labelling: 

Digital labelling should at least comply with the following general requirements: 

1.  The obligation for the digital label to include the full set of labelling information (i.e. 
there should not  be a split  of information  between the physical  and digital  label), to 
ensure that the information provided is meaningful; 

2.  The  obligation  to  provide  all  digital  data  in  one  place,  separately  from  other 
commercial information (e.g. the mandatory information shall not be displayed together 
with  other  information  intended  for  sales  or  marketing  purposes).  Coherence  should 
also be sought with other digital provision of information on products (e.g. under the 
Digital Products Passport); 

3.  The format of the data provided digitally must be appropriate (e.g. rules on font 

size, the content of the digital label must be searchable); 

4.  The protection of personal data (e.g. prohibition of collecting and tracking user data 
or using that information for commercial purposes) in accordance with Regulation (EU) 
2016/679;80  

5.  Accessibility of the data both in terms of ease of access (e.g. “two-click” maximum 
rule to access the information), and in terms of accessibility for users (e.g. also for users 
with disabilities). Access to the digital label must be free and without a need for prior 
registration  or  a  password,  or  prior  download  of  applications. Access  limitations  for 
certain user groups (e.g. geo-blocking in accordance with Regulation (EU) 2018/30281 
) are not allowed; 

6.  Instead  of  prescribing  a  particular  technology,  a  set  of  minimum  technical 
requirements are to be defined and complied with, in order to ensure technological 
neutrality of the IT solutions used. The IT solution must be easily readable via widely 
used digital technologies (e.g. a QR code scanner/ reader). It must be ensured that the 
data can be accessed, navigated and read on, and is compatible with, all major operating 
systems and browsers. Information must also be available for old browser version and 
operating systems; 

7.  The information must be provided in a language which is easily understood by end-
users,  as  determined  by  the  Member  State  in  which  the  product  is  marketed82. 

80 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of 
natural persons with regard to the processing of personal data and on the free movement of such data, and repealing 
Directive 95/46/EC (General Data Protection Regulation): https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02016R0679-20160504 
81  Regulation  (EU)  2018/302  of  the  European  Parliament  and  of  the  Council  of  28  February  2018  on  addressing 
unjustified geo-blocking and other forms of discrimination based on customers' nationality, place of residence or place 
of establishment  within the internal market and amending Regulations (EC) No 2006/2004 and (EU) 2017/2394 and 
Directive 2009/22/EC: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32018R0302 

31 

 
 
                                                 
 
 
Additional  languages  are  permitted;  users  must  have  the  possibility  to  select  their 
language of choice, regardless of their physical location.  

8.  Economic operators who opt for the digital label shall ensure that appropriate alternative 
ways of providing information are available to end-users in case of lack of digital tools 
or skills, or in the absence of network access, both before buying the product and after 
having bought the product; 

9.  Where  an  EU  fertilising  product  is  supplied  in  a  package,  the  IT  solution  (e.g.  QR 
code) must be printed or placed physically on a label which is affixed to that package. 
Where the package is too small to contain IT solutions or the product is sold in bulk, 
the  IT  solution  shall  be  provided  in  a  separate  leaflet  accompanying  that 
package/product.  

10. 

The data contained under the digital label must remain accessible for as long 
as operators are required to keep the technical documentation of product that it refers 
to, i.e. 5 years after they sold the last EU Fertilising Product. The data present on the 
digital label must remain available even after an insolvency, a liquidation or a cessation 
of activity in the Union of the economic operator that created the digital label. 

As part of the digital labelling study, economic operators, national authorities, professional 
and non-professional users as well as other stakeholders such as NGOs were consulted on 
these principles, and feedback confirmed wide support for all of the principles.83  

5.3.  Presentation of policy options: 

The policy options retained for a detailed assessment range from a minimum intervention, 
without using regulatory means (PO1), to options implying amendments to the FPR (PO2 
and PO3).  

As regards PO2, it has been divided into 5 separate options (PO2a- PO2e) where the level 
of digitalisation varies from the least extensive in PO2a to the most ambitious in PO2e. All 
the different versions of policy option 2 are packages of 1 or 2 policy measures as presented 
in the previous Section. PO3 (which consists of measure 6) is the only option effectively 
addressing  drivers  4  and  5,  as  explained  in  Section  2.3.  The  full  digitalisation  of  the 
labelling requirements for products sold to industrial users is the only way of avoiding the 
double labelling of products before reaching the end-user. As regards products sold in bulk, 
the  full  digitalisation  of  the  leaflet  and  the  requirement  to  provide  the  information  via 
alternative means in cases where access to a digital label is not possible, effectively solved 
the problem identified. The impacts of PO3 (measure 6) differ substantially to the policy 
options under PO2. Any of the POs (1, 2 and 3) could be combined with any other policy 
option to create a package of the preferred combination.  

The table below presents the overview of the retained policy options. The different policy 
options may be combined. 

83 Majority of stakeholders responding (out of 84) to the ‘policy options’ survey ‘strongly agreed’ or ‘agreed’ with all 
10 principles. 

32 

 
 
                                                 
 
Policy Option  

Measures included 

List of what is allowed under the option 

PO0 

PO1 

Baseline (no measures) 

-  No changes to the status quo 

Measure 1 (only) 

All Annex III label information is provided via physical labels 
Digital labelling is voluntary 
The  Commission  develops  a  guidance  document  on  digital 
labelling 

PO2a 

Measure 2 

Certain information  can be  provided  digitally  only  without a 
distinction between professional/non-professional users. 

PO2b 

Measure 3 (3a and 3b)  

Certain  information  may  be  provided    digitally  only,  with  a 
distinction between professional/non-professional users. 

PO2c 

Measure 4  

Most of the information can be provided digitally only without 
a distinction between professional/non-professional users. 

PO2d 

Measure 5 (5a and 5b)  

Most of the information may be provided  digitally only, with 
a distinction between professional/non-professional users. 

PO2 

PO2e 

Measure 3a and 5b  

Certain  information  may  be  provided    digitally  only,  for 
professional users 

Most of the information can be provided only digitally for non-
professional users 

PO3 

Measure 6 

All  information  may  be  provided  only  digitally  for  products 
sold in bulk and products for industrial users. 

5.4.  Options discarded at an early stage 

In this section the discarded options longlisted but not selected for the final shortlist are 
provided and analysed. In particular, it is set out why specific alternative options were not 
considered  as  being  feasible  or  realistic,  considering  advantages,  but  also  crucial 
disadvantages of these POs.  

  5.5.1. 

 Replacing  the  physical  labels  with  digital  labels  for  all  EU  fertilising 

products 

The use of full digital labelling replacing physical labels for all EU fertilising products was 
discarded due to concerns about: (1) compromises to the safety and use of products (2) 
digital literacy of or access by product users. 

33 

 
 
 
 
 
Firstly, the use of full digital labelling only was seen as potentially compromising product 
safety. The digital labelling study found a broad consensus among most stakeholders84 that 
at the minimum, safety information and instructions for use should remain on the physical 
label.  In  the  survey  experiment85,  feedback  was  received  that  the  inclusion  of  safety 
information  on  physical  labels  was  “non-negotiable”,  irrespective  of  whether  such 
information is produced in parallel through digital labelling. Therefore, only having digital 
labelling  and  discontinuing  physical  labelling  for  all  EU  fertilising  products  was  not 
considered as being feasible as it would compromise product safety. 

Without basic safety information on the physical label, there were concerns that even if 
users  are  digitally-savvy,  they  may  not  always  look  up  the  corresponding  safety 
information  online  via  a  digital  label,  for  instance,  due  to  inertia  or  time  expediency 
reasons. Another issue is that there may be practical obstacles because of the (working) 
conditions in which the products are used. For example accessing information online in a 
situation or location when it is inconvenient or impractical, for instance out in a field, when 
weather-related conditions are prohibitive, or due to other external factors, for example, 
given  there  may  be  wet  soil  and  dust  present.  Therefore,  it  cannot  be  assumed  that 
accessing a digital label is realistic in all scenarios.  

Secondly, although the digital labelling study found that a high percentage of fertilising 
product users are digitally-savvy, and would be able to use digital labels, concerns were 
raised among consumer associations, economic operators, national authorities and some 
product  users  that  some  user  categories  (particularly  small  farmers,  and  older  hobby 
gardeners) may not be able to use digital tools, and that digital labels could leave behind 
those lacking digital literacy, especially older users (who make up a disproportionate share 
of hobby gardeners for instance86).  
While recognising that according to the DESI Scoreboard 2021 on the Digital Economy87, 
97%  of  European  citizens  have  access  to  either  a  fixed  or  a  mobile  broadband  internet 
connection,  this  masks  considerable  differences  between  Member  States,  especially  in 
rural areas where fertilising products are used more commonly. The digital labelling study 
found that while most respondents to the stakeholder survey indicated they were able to 
access  the  internet,  some  reported  challenges  regarding  internet  speed  and  stability. 
However, whilst “on-the-go” a relatively high percentage of both professional and non-
professional  users  indicated  they  do  not  have  internet  access.  Most  professional  users 
surveyed  indicated  that they  have the internet  at  home (85.7%) and the office (55.3%). 
Non-professional  users  said  that  they  have  the  internet  at  home  (96.2%)  and  on-the-go 
(64%).  Therefore,  while  in  theory,  most  users  of  EU  fertilising  products  are  internet-
connected, in practice, this depends on where they are (i.e. at home or on-the-go).  

84 Although 75.5% of Professional users perceived safety information could be digitalised either fully or partially based 
on the feedback received through the stakeholder survey. 
85  A  survey  experiment  was  conducted  as  part  of  the  CSES  and  PPMI  study  (mentioned  before),  and 
implemented a three-group, one-way design that explored the effects of labelling changes on key behaviours 
among professional and non-professional users of fertilising products. 
86 CSES and PPMI study mentioned before, section 5.1.2. 
87 Digital Economy and Society Index (DESI) 2021 | Shaping Europe’s digital future (europa.eu)  

34 

 
 
                                                 
For  the  above  reasons,  it  was  concluded  that  keeping  some  essential  information, 
particularly linked to safety, was necessary to remain on the physical label and allowing 
full  digitalisation  of  labels  for  all  EU  fertilising  products  was  not  proportionate  to  the 
problem at hand. 

  5.5.2.  Mandatory digital labelling 

This option was dismissed due to the expected significant costs that they would entail for 
businesses  –  SMEs  in  particular88.  Under  this  option  all  manufacturers  would  have  to 
implement digital labelling, even if none of the problems identified are experienced (for 
example  those  with  products  packaged  in  large  bags  without  label  space  limitations). 
Concerns  about  the  costs  for  SMEs  of  making  digital  labelling  mandatory  were  a  key 
finding  in  the  stakeholder  survey  results  of  the  digital  labelling  study.  Implementing 
mandatory  digital  labelling  would  incur  both  one-off  costs  (e.g.  purchasing  QR  code 
scanning  equipment)  and  recurring  costs  (e.g.  the  necessary  software  to  digitalise  user 
information and compliance information about their product inventory, updating websites 
with product information), even if economically digital labelling does not make sense. 

Interview  and case study feedback  from the digital  labelling study, as well as positions 
received  in  response  to  the  Inception  Impact  Assessment89  suggests  that  economic 
operators prefer to retain control to make their own decisions regarding labelling dependent 
on their businesses’ needs and the scale of their production facilities. 

Further, this initiative follows up on the concerns raised during the adoption of the FPR, 
particularly on the increased labelling requirements, and is proposed as a simplification 
measure intended to reduce, rather than increase administrative burdens for  industry, by 
allowing digital labelling as an alternative means of providing label information.  

  5.5.3.  Centralised database for providing information digitally 

During the consultation activities, public authorities expressed a generalised preference for 
this solution, albeit not seeing negatively the possibility for manufacturers to provide this 
information through their own website. Stakeholders from the industry, on the other hand, 
would rather have an electronic label directly linked to their own website in order to have 
greater  control  about  the  information  provided.  This  measure  was,  however,  discarded 
given the various disadvantages that it presented. First, in other chemical sectors, such as 
under the detergents regulation, manufacturers are already required to maintain their own 
website with product information. Therefore, for detergents, there already exists a suitable 
platform to  host the labelling information to  be provided digitally which  manufacturers 
own and manage by themselves. In order to keep consistency with the approach of digital 
labelling to the extent possible, between different initiatives, this is also relevant to EU 
Fertilising  products,  and  it  was  preferred  to  explore  a  consistent  (decentralised)  digital 
labelling  approach.  Further,  a  centralised  database  would  force  companies  to  adopt  a 
certain digital solution, the structure of which would be managed externally. This would 

88 SME United emphasised that mandatory digitalisation should not be put forward, since all companies do 
not have “sufficient options and experience in adding or using digital information” and therefore the choice 
should be available to provide certain information either digitally or on the packaging. 
89 Chemicals – simplification and digitalisation of labelling requirements (europa.eu)   

35 

 
 
                                                 
not allow the legislation to stay technologically neutral in order to allow innovation and 
the  uptake  of  future  technologies  and  its  establishment  would  be  time  consuming  and 
costly. The development of such a database would be very costly. Comparatively, the IA 
of the batteries proposal found that “the cost of a centralised database could be in the region 
of EUR 5.6 million plus EUR 1.3 million for maintenance” in the 2021-2030 period90. It 
was, therefore, concluded that the benefits of this measure would likely not outweigh the 
costs and shortcomings related to its implementation. 

  5.5.4.  Digitalisation of incremental information requirements.  

This option would involve allowing digital labelling of information requirements under the 
FPR that are additional to those already required under the EC Fertilisers Regulation.  

This option was initially considered on the basis that many stakeholders suggested this as 
a possibility during the consultations of the digital labelling study. However, in ensuring 
high  levels  of  safety  for  fertilising  products,  this  would  be  an  unacceptable  approach 
considering  that  some  of  the  additionally  required  information  is  safety  related,  and 
conveys crucial information, for example on maximum residues limits for food and feed, 
or safety information on the content of products, such as products with ricin, or products 
containing cocoa shells, which would trigger warnings such as ‘toxic to dogs and cats’. 
Further, the FPR contains new rules not only on fertilisers and liming materials (covered 
by the EC Fertilisers Regulation) but also for new product categories, including organic 
fertilisers,  soil  improvers,  growing  media,  inhibitors,  plant  biostimulants  and  fertilising 
product blends.  

6.  6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

The  impacts  were  assessed  for  each  separate  policy  measure  proposed,  and  a  detailed 
explanation is provided in the digital labelling study, section 5.4. PO2a – PO2e and PO3 
introduce  digital  labelling,  and  allow  varying  degrees  of  information  to  be  moved  to  a 
digital label (and in the case of PO3 all information), under the same conditions (i.e. with 
the application of the digital labelling principles).  

The impacts of the policy option PO2a –PO2e are discussed and analysed together, only 
explaining the differences between them. 

The following assessment provides a qualitative analysis of the impacts generated by each 
policy option, based on the evidence gathered from multiple sources. Whenever possible, 
it also provides a quantitative analysis of benefits and costs relating to the main economic 
and social impacts. The cost/benefits analysis, however, is not fully comprehensive due to 
significant data gaps and limitations. The quantification of costs and benefits is based on a 
number of assumptions coming from stakeholder feedback and expert knowledge of the 
contractor of the digital labelling study. The aim of this assessment is to provide ranges of 

90 Commission Staff Working Document - Impact Assessment Report - Accompanying the document - Proposal for a 
Regulation of the European Parliament and of the Council concerning batteries and waste batteries, repealing Directive 
2006/66/EC and amending Regulation (EU) 2019/1020, COM(2020)798, SWD(2020)334, Part 3/3, see pg. 290.  

36 

 
 
                                                 
the  magnitude  of  potential  impacts  generated  by  each  policy  option,  rather  than  exact 
monetisation91. 

6.1. 

6.2. 

Policy Option 1: Development of a Guidance Document only 

  6.2.1.  Economic impacts  

The baseline costs are estimated to remain the same with the development of a Guidance 
document. PO1 should have no particular impact on the competitiveness of the industry, 
considering that it would not entail any regulatory change and the provision of all label 
information would remain on physical labels. As digital labelling is not harmonised under 
PO1, a level playing field to this regard is not established for the industry. PO1 would not 
offer any solution to problem 2 (labels are difficult to manage) and does not contribute to 
the  general  objective  of  ensuring  the  effective  functioning  of  the  Internal  Market  in 
fertilising products, nor the specific objective of improving the free movement of fertilising 
products across the EU-27, as all label information remains on the physical label. Overall, 
the problems related to increased costs due to lack of space on the label will remain. There 
could  be  some  costs  for  the  Commission  related  to  the  development  of  a  Guidance 
document but they are considered as business as usual costs. 

  6.2.2.  Impact on the environment  

Digital labelling (according to current industry practises) may benefit from clear guidelines 
on how to convey digital information of EU Fertilising products more effectively. If an 
economic operator chooses to  follow the established  guidelines under the baseline, this 
could have limited positive indirect impacts on the environment and on human health, as 
the  information  provided  online  would  be  more  complete  and  clearer.  For  example,  a 
product user could more easily follow the use-instructions of a product due to increased 
quality of the layout of the information.  

  6.2.3.  Social impact and on human health 

All label information will remain on the physical label, and therefore this PO would not 
impact the digital divide and those with no access to the internet or those without digital 
skills. Further, health and safety related information will also remain on the physical label, 
so health risks will be no greater than in the case under the baseline. For those products 
already providing label information digitally, if the guidelines are followed, product users 
may  benefit  from  clearer  information.  This  could  have  positive  social  impacts,  as  for 
example, those users seeking out certain criteria on a EU fertilising products, suiting their 
personal needs or professional needs, could more easily find information relevant to them, 
for example, by making the digital information searchable. However, guidelines cannot be 
enforced  and  such  possible  benefits  would  not  be  harmonised  across  digitalisation 
practises.  There  will  also  be  no  benefits  in  terms  of  ease  of  reading  labels  and 
distinguishing between essential and less relevant information, as problem 1 (labels are 

91 More details on data gaps and limitation are presented in Annex 4.    

37 

 
 
 
                                                 
difficult to read because of the extensive requirements under the FPR) is not addressed, 
nor is the specific objective of improving the readability of the labels.  

  6.2.4.  Stakeholders view on PO1 

As many enterprises already provide product information online on their own initiative92, 
putting in  place  a  framework to  guide digitalisation for those enterprises was  generally 
welcomed93.  

Under this option, the mandatory label information would all be retained on the physical 
label, which would allay concerns among some stakeholders (e.g. some non-professional 
users and their representatives, in the form of consumer organisations) about moving any 
information from a fertilising product label94. However, in general, this policy option is 
not  supported  by  the  majority  of  stakeholders.  According  to  the  results  of  the  Public 
Consultation, 46% of respondents answered they would view it very positively, and 21% 
moderately positively, when asked how they would evaluate it if some information of a 
fertilising product label was removed from the physical label and could only be obtained 
via digital labels95. In terms of users, this PO is not optimal in the view of non-professional 
users, who will continue to receive detailed technical information on product labels which 
they do not understand.  

5.5.  Policy  Option  2:  Information  may  be  provided  digitally  for  EU 

Fertilising Products  

As explained above, the impacts of PO2a- PO2e are analysed together in this section, as 
there are limited differences between the impacts of PO2a-PO2e, and thus there is limited 
added value of discussing them separately. Where differences between options PO2a – 
PO2e exist, they are highlighted.  

The Public Consultation found that  overall the majority of all types of  stakeholders  are 
supportive of the introduction of digital labelling96, even if there may be some opposing 
views regarding the precise manner of its implementation or the labelling requirements, 
which could be provided only digitally.  

Allowing  for  some  digital  labelling  would  reflect  positively  the  evolving  situation 
internationally, as many countries, together representing over 56% of the world’s economy 
and 46% of the world’s population, have already adopted national e-labelling schemes for 

92 74% of manufacturers responding to the Public Consultation indicated they provide product information 
online, (out of 139 respondents).  
93 According to the Public Consultation, 56% (74 out of 132 respondents) preferred for digital label information to be 
presented in a decentralised system following standardised templates or guidelines. 
94 See, for example, BEUC’s publication ‘Why moving essential product information online is a no-go’  
95 Out of 153 responses  for Fertilising Products. Respondents included companies/business organisations 
(46.8%),  EU  citizen  (22.9%),  business  associations  (17.6%),  public  authorities  (17.6%),  other  (4.4%), 
consumer organisation (1.5%), Non-EU citizens (1%), trade union (0.5%) and NGOs (0.5%). 
96 67% of respondents indicated they would evaluate it positively if information was removed from the physical label 
and  could  be  obtained  digitally  only  (out  of  153  responses):  Chemicals  –  simplification  and  digitalisation  of 
labelling requirements (europa.eu)  

38 

 
 
                                                 
various  products97.  Development  of  an  online  presence  as  incentivised  under  PO2,  will 
contribute to technological development and the European Commission’s ambitions linked 
to the digitalisation of the economy.    

It  should  be  noted  that  any  option  introducing  digital  labelling  as  an  alternative  to 
mandatory labelling, the application of the digital labelling principles (see section 6.3.1) 
will be triggered. 

  6.3.1.  Economic impacts  

Costs: 

A first point to note here is that the voluntary nature of the proposals, means that PO2a –
PO2e would not impose any additional compliance costs on businesses across the EU, as 
businesses  could  avoid  incurring  additional  costs  simply  by  continuing  their  current 
method of providing all label information on the physical label only. 

A detailed breakdown of costs for businesses can be found in the Annex 4. All costs are 
considered administrative costs since they relate to information requirements. Based on 
the figures table below (estimate figures for total costs for SMEs and large enterprises), 
key  assumptions  should  be  noted,  and  particularly  that  many  businesses  will  already 
operate  a  website;  Eurostat  data  shows  a  figure  of  94%  of  large  enterprises  having  a 
website.98 Large enterprises (and even some SMEs) are also likely to have a website with 
high functionality. Keeping this in mind and considering the dynamic baseline, it is likely 
that  many  enterprises  will  introduce  digital  labelling  as  part  of  a  broader  strategy  to 
digitalise their operations or at least provide a website. For the purposes of the cost-benefit 
analysis  that  follows,  the  costs  of  developing  a  website  and  maintaining  webpages  is 
therefore treated as a business-as-usual cost.  

Compared to large companies, SMEs are currently found less likely to provide information 
about their products online, but not by significant amounts. Based on the results from the 
public consultation, 70% of the SMEs99 compared to 79% of the large companies100 already 
provide information about their products digitally. This illustrates that benefits as a result 
of the introduction of digital labelling would be very likely for SMEs. 

Further,  evidence  from  the  consultations  of  economic  operators  highlighted  that  the 
provision of any information in digital format requires a certain level of expenditure (in 
equipment, staff time, etc.) both on a one-off basis and an ongoing annual basis (e.g. to 
maintain equipment, retrain staff). However, once that investment is made, the incremental 
cost of providing more information in digital format is negligible. For example, there is 
little  cost  difference  in  providing  certain/most/all  information  in  digital  format  for  any 
particular  product.  Similarly,  the  costs  of  providing  digital  labelling  do  not  particularly 

97 E-labelling for Europe - key facts & figures - DIGITALEUROPE  

98 Enterprises having a website, by functionality and size class, EU, 2021 (% of enterprises).png - Statistics 
Explained (europa.eu)   
99 Multiple selection question. 58 out of 83 total selections. 
100 Multiple selection question. 59 out of 75 total selections. 

39 

 
 
 
 
                                                 
vary according to the types of fertiliser products. On that basis, the evidence suggests 
that  an  assumption  can  be  made  that  the  costs  of  providing  information  in digital 
format for any specific business would be more or less identical across PO2a-PO2e. 

Estimates for total one-off costs and ongoing annual costs are provided in the table below 
(for a full break down of the costs please see Annex 4). 

Table 6.1 Total enterprise-level costs of optional digitalisation (PO 2a-2e) 

Size of enterprise 

One-off administrative costs 
per company 

Ongoing (annual) 
administrative costs  per 
company 

Large enterprises) 
SMEs  

€14,998 – €29,998 
€1,796 - €6,046 

€2,700 - €7,700 
€1,170 - €3,770 

The ranges are calculated on the basis of the data collected during the stakeholder survey 
and the public consultation, which provided different data on the percentage of firms that 
do not yet provide any information about their products in a digital format: 

  According to the stakeholder survey, 56% of enterprises do not as yet provide any 
information  about  their  products  in  a  digital  format).  If  the  entirety  of  these 
enterprises chose to provide information in digital format, this would amount to  
2,013 enterprises (i.e. 56% x 3,595 enterprises). 

  According to the public consultation, only 26% of enterprises do not as yet provide 
any  information  about  their  products  in  a  digital  format.  If  the  entirety  of  these 
enterprises chose to provide information in digital format, this would amount to 
935 enterprises. 

The public consultation and stakeholder survey results differed quite significantly in terms 
of the proportion of firms that said they already produced information in a digital format. 
A reason for the big difference may be that in the stakeholder survey, was more technical 
compared  with  the  public  consultation,  meaning  that  stakeholders  were  specifically 
responding  about  digitally  providing  labelling  requirements  (whereas  in  the  public 
consultation  they  responded  more  generally).  For  this  reason,  the  figure  from  the 
stakeholder survey will be used in the calculation of overall costs  and benefits.  

The percentage of enterprises that operate in compliance with the FPR is not known, given 
that they can choose instead to comply with relevant national legislation. Thus, identifying 
the  percentage  that  would  move  from  physical  labelling  in  line  with  the FPR  to  digital 
labelling in line with the FPR cannot be determined. To address this, a best estimate is 
made taking the percentage of SMEs that export to other EU Member States as a proxy for 
compliance  with  the  FPR  rather  than  with  national  rules.101  According  to  a  Flash 
Eurobarometer survey, 30% of SMEs (in all sectors) had exported to another EU Member 

101 It is possible that some exporting enterprises will comply with national rules rather than the FPR where 
this is possible via mutual recognition between Member States. However, the research covered no data on 
the proportion of firms that take this approach. 

40 

 
 
 
                                                 
State in the previous three years.102 It is also assumed that all large enterprises comply with 
the FPR, since they are very likely to export to multiple EU Member States. 

Based on this, large enterprises and SMEs are divided into different categories, as shown 
in the table 4.5 of Annex 4. 

 

It  is  assumed  that  44%  of  Large  Enterprises  already  provide  some  form  of  digital 
labelling. It is assumed that they export to other Member States and comply with the 
FPR. Such enterprises would not incur additional costs (as they already digitalise) but 
would enjoy savings from any reductions in physical labelling requirements. 

  The  remaining  56%  of  Large  Enterprises  do  not  yet  provide  any  digital  labelling. 
However, it is assumed that they export to other Member States and would therefore 
choose to adopt digital labelling in compliance with the FPR. Such enterprises would 
incur  additional  costs  due  to  digitalisation  but  would  also  enjoy  savings  from  any 
reductions in physical labelling requirements. 

  Of the 44% of SMEs that provide digital labelling, it is assumed that 30% export within 
the EU (which is equal to 13% of all SMEs). These firms would not incur additional 
costs but would enjoy savings from any reductions in physical labelling requirements. 

  Of the 44% of SMEs that provide digital labelling, it is assumed that 70% do not export 
within the EU (equal to 31% of all SMEs). These firms would not incur additional costs 
and would not enjoy savings, as they would continue to comply with any national rules 
on labelling. 

  Of the 56% of SMEs that do not provide digital labelling, it is assumed that 30% export 
within the EU (equal to 17% of all SMEs). These firms are assumed to adopt digital 
labelling for the first time. They would therefore incur additional costs but would enjoy 
savings from any reductions in physical labelling requirements. 

  Of the 56% of SMEs that do not provide digital labelling, it is assumed that 70% do 
not  export within the EU (equal  to 17% of all SMEs). These firms  would not incur 
additional costs and would not enjoy savings, as they would continue to comply with 
any national rules on labelling. 

It  should  further  be  noted,  that  given  the  limited  evidence  base  for  the  costs,  a  full 
extrapolation  of costs to  EU level  is  problematic and risks providing a  false picture.  In 
practice, the actual costs would most likely be less than these maximum costs, as a certain 
proportion  of firms  would choose not  to  provide  digital  labelling.  Nonetheless, a broad 
indication  can  be  offered,  for  illustrative  purposes.  Maximum  EU-level  costs  for 
enterprises under PO2 (but also PO3) based on stakeholder survey data would be €1.2m 
(ranging from €0.6m to €3.7m) for one-off costs, and €0.7m (ranging from €0.4m to 
€2.4m)for ongoing (annual) costs, given the following main assumptions (for a full break 
down of assumptions please refer to Annex 4). 

The fertilising products sector features 3595 enterprises. Given that 99.8% of enterprises 
are SMEs, this means that approximately 14 are large enterprises, and 3581 are SMEs. 

102 Flash Eurobarometer 421: Internationalisation of Small and Medium-Sized Enterprises 

41 

 
 
                                                 
Under PO2, several types of costs can be estimated, namely (see details in section 4 and 5 
of Annex 4):  

1)  Ongoing costs103 related to providing and updating product information specific to 
PO2 online (e.g. re-training staff, maintenance of software and web pages).  

2)  One-off costs104: 

a.  Familiarisation costs  
b.  Cost  related  to  providing  and  updating  product  information  online  (e.g. 
training  staff,  purchase  or  development  of  software  and  development  of 
web  pages,  collating/uploading  information),  and  costs  of  changing 
physical  labels  to  include  QR  codes  on  the  product  (e.g.  purchase  of 
equipment reading QR codes). 

It should be noted that some costs may additionally be incurred by the economic operator 
opting for digital labelling, associated with the application of digital labelling principle 8 
(e.g. in terms of printing a leaflet with label information). Although such costs could not 
be quantified, they are expected to be marginal, given that product information would only 
be supplied to small portions of the target markets (and otherwise the label information 
could be provided on the physical label, incurring the baseline costs). 

In terms of direct impacts of PO2 on public authorities, despite positive aspects related to 
the  ease  of  managing  and  compiling  online  data,  public  authorities  could  require  some 
investment in equipment and training to facilitate access to digital labels, although it should 
be  noted  that  74.2%  of  Member  State  Authorities  and  Conformity  Assessment  Bodies 
replying to the stakeholder survey105 indicated they currently already use digital tools to 
access label information of products.  

Benefits: 

Despite such potential costs, the possibility of providing certain information only digitally 
would lead to cost savings for the industry because: 

  The  manufacturers,  including  SMEs,  remain  free  to  decide  if  to  use  the  digital 
labelling. Consequently, such a decision would be taken by those manufacturers 
who estimate costs savings at least on medium or long term;  

  Digital labels are less expensive to update so in the long term some savings could 

be expected due to less frequent reprinting of labels; 

In the longer term, costs would be offset by savings related to updating physical labels. 
Feedback  from  the  fertilising  products  industry  associations  at  the  ad-hoc  expert  group 
meeting also confirmed that PO2a – PO2e will provide some alleviation of costs related 
to the lack of space on physical labels, in a granular manner (i.e. when some information 
is allowed to be digitalised some costs are saved, and when most information is allowed to 
be digitalised, more costs can be saved).  

103 Please refer to table 4.2 in Annex 4 for more details 
104 Please refer to table 4.1 in Annex 4 for more details 
105 Total number of responses = 31. 

42 

 
 
                                                 
Evidence from the digital labelling study suggests that businesses will be more likely to 
provide  digital  labelling  to  the  extent  that  they  can  remove  information  from  physical 
labels, since this will reduce costs. Under the baseline scenario, there are no cost savings 
to be made from digital labelling, since full physical labelling is still required. In contrast, 
the PO 2a-2e offer the potential for cost savings. 

By reducing the frequency of disposing of and redesigning physical labels, there could be 
some ongoing costs savings for enterprises  as digital labels are easier and less costly to 
update than physical labels. This relates to relabelling due to the (in)stability of product 
information  over  time  (e.g.  for  organic  fertilisers,  the  content  of  the  various  forms  of 
nutrients  may  vary  from  one  batch  to  another,  depending  on  the  quality  of  the  input 
materials used) changes to the product (e.g. different ingredients), changes in distribution 
of the product (i.e. additional countries) or due to regulatory changes. Evidence from the 
digital  labelling  study  suggests  that  the  need  for  redesigns  will  reduce  as  the  extent  of 
digitalisation increases (i.e. moving through the  PO 2a to 2e). The data available is not 
sufficient to specify the level of cost savings that would be achieved by allowing digital 
labelling to replace some/most/all information on physical labels. However, an indicative 
benchmark  for  the  cost  of  updating  a  product  label  is  available  from  a  previous  study, 
which found that it costs between €120 and €200 to redesign the physical label for a single 
detergent product, whereas it take only one hour to revise and upload an online information 
sheet106.  

Another factor making digital labels less expensive than physical labels is that, enterprises 
will incur fewer costs in purchasing and maintaining the machinery or equipment required 
to  make  physical  labels.  Evidence  from  the  stakeholder  survey  suggests  that  these  will 
reduce as the extent of digitalisation increases. And finally, enterprises will incur fewer 
costs in printing physical labels and fixing them to products. Again, the evidence from the 
stakeholder survey suggests that these will reduce as the extent of digitalisation increases. 

  The physical labels could include more languages107, allowing businesses otherwise 
faced with labelling space constraints to overcome such issues and improve the free 
movement of EU Fertilising products across the EU;   

PO2 would incentivise  economic operators to  improve the free movement  of fertilising 
products across the EU-27. By reducing the amount of information required on the physical 
label there should be more space for information in different languages, which according 
to manufacturers interviewed, will make it easier for them to remain and to grow in the 
internal  market.  The  consultations  with  industry108  indicated  that  being  able  to  include 
more languages on the packaging by moving some information under a digital label would 
mean that it is more cost-effective to distribute products to multiple Member States, which 
supports increased investment and economies of scale. Such cost savings are seen to be 
incremental (i.e. with least savings under PO2a where the least amount of information is 
digitised, and most under  PO2d), as it was found that digital label information is more 

106 Support to the evaluation of Regulation (EC) No 648/2004 (Detergents Regulation) - Publications Office 
of the EU (europa.eu) 
107 In the stakeholder survey relevant to industry, 73.86% of industry respondents (manufacturers, blenders and importers, 
distributors, sales)  indicated they provide multi- language labels (with a total of 68 responses). 
108 CSES and PPMI study mentioned before, Section 7.3.1  (specifically referenced above – data on how many 
languages, etc.) 

43 

 
 
                                                 
easily update with less costs.  
Around  74%  of  the  economic  operators  responding  to  the  stakeholder  survey  indicated 
they use multi-language labels (out of 70). Most economic operators indicated they provide 
3 languages on the label (29%, out of 40), while 24% indicated they provide 6 or more 
languages on a fertilising product label. Digital labelling and simplifying the physical label 
could help retailers or wholesalers to overcome the obstacles they sometimes face because 
of  territorial  supply  constraints109,  and  particularly  regarding  limited  space  on  physical 
labels to provide multiple languages.  
Also, harmonised rules and a level playing field on digital labelling could (indirectly) act 
as an incentive for those supplying national markets under mutual recognition rules, to CE 
mark their products, due to the creation of a level playing field. 
As there is scope for digitalising more information for professional users110, PO2b, PO2d 
and PO2e (with PO2d allowing overall the highest level of moving information to a digital 
label)  will  increasingly  support  the  competitiveness  of  those  enterprises  that  have 
challenges  regarding  space  constraints  of  labels  to  a  greater  extent.  It  is  particularly 
interesting  for  enterprises  who  supply  professional  markets  with  highly  knowledgeable 
buyers and users (who are therefore less reliant on the information on physical labels). At 
the  same  time,  by  making  a  distinction  between  users,  for  those  who  supply  non-
professional  markets,  under  these  option  manufacturers  should  continue  to  provide 
considerable  label  information  that  might  be  more  specifically  relevant  for  non-
professional users, as is deemed appropriate (see table 5.2 above), on the physical label.   

The  table  below  provides  a  summary  of  estimated  annual  benefits  that  might  accrue  to 
individual  enterprises  under  each  of  the  policy  options.  The  benefits  are  calculated  as 
follows (for a full break down of assumptions please see section 6 in Annex 4): 

  Baseline costs (except cost of redesigning physical labels) are mid-point estimates 
based  on  the  range  of  cost  estimates  provided  by  enterprises  responding  to  the 
policy options survey.  

  Costs of machinery/equipment to make physical labels varied widely in line with 
the size of the enterprise, number of product lines, country, etc. For that reason, an 
intelligent  mid-point  estimate  is  taken.  For  SMEs,  this  is  €5,000  and  for  large 
enterprises it is €25,000. 

  Cost of redesigning physical labels is based on the mid-point (€160) of the cost 
range identified for the redesign of a physical label111. This unit cost is multiplied 
by  estimates  for  the  number  of  product  lines  per  company  (based  on  the  policy 
options survey): 6 for SMEs and 300 for large enterprises.  

  Percentage annual savings are an average of cost savings anticipated by enterprises 

109 European Commission (2020). Study on territorial supply constraints in the EU retail sector   
110 See results of the stakeholder survey, Annex 2. 
111 An indicative benchmark for the cost of updating a product label is available from a previous study, which 
found that it costs between €120 and €200 to redesign the physical label for a single detergent product: 2018 
Support to the evaluation of Regulation (EC) No 648/2004 (Detergents Regulation) - Publications Office of 
the EU 

44 

 
 
                                                 
responding to the policy options survey for all costs except redesign of physical 
labels.112 

  Percentage  annual  savings  of  the  cost  of  redesigning  physical  labels  are  a  best 

estimate based on stakeholder interviews. 

It should be noted that enterprises are unlikely to enjoy significant one-off cost savings as 
a result of digital labelling under PO2a, where savings will be realised only on an ongoing 
annual basis. 

The differences in estimates of benefits (savings) between the different options under PO2 
are provided in the table 6.1 (for a full break down of the benefits please see Annex 4). 

Table 6.1 Benefits (savings) accruing per enterprise under policy option 2 

Savings against baseline113 
Redesigning physical labels114 
Machinery/equipment  to  make  physical 
labels115 
Printing physical labels  (incl. reducing the 
frequency of disposing) 
Fixing labels to packaging 
Mid-point cost estimates (€) - SMEs 
Redesigning physical labels 
Machinery/equipment  to  make  physical 
labels 
Printing physical labels  (incl. reducing the 
frequency of disposing) 
Fixing labels to packaging 

PO2a  PO2b 

PO2c 

PO2d  PO2e** 

0% 

5% 

8% 

5% 

0 

0% 

25% 

23% 

15% 

25% 

50% 

39% 

31% 

25% 

70% 

50% 

35% 

0% 

25% 

23% 

15% 

0 

120 

120 

0 

250 

1,250 

2,500 

3,500 

1,250 

167 

100 

450 

283 

775 

625 

1,000 

700 

460 

300 

Total annual savings (€) - SMEs 

517 

1,983 

4,020 

5,320 

2,010 

Mid-point  cost  estimates  (€)  -  Large 
enterprises 
Redesigning physical labels 
Machinery/equipment  to  make  physical 
labels 

0 

0 

6,000 

6,000 

0 

1,250 

6,250 

12,500 

17,500 

6,250 

112 The policy options survey collected 93 valid responses, 35.5% (33 out of 93) were economic operators 
(size of businesses; 33.3% large, 30.3% medium, 24.2% small, 12.1% micro (with only 1-9 employees).  
113 The percentages of annual savings were sourced from the policy options survey responses. A total of six 
economic operators provided estimates of the percentage savings for the policy options. These varied, so a 
mid-point estimate from amongst their estimates was selected. In addition, the responses to the qualitative 
policy options survey questions and the stakeholder interviews tended to support the finding that increased 
savings are associated with increased digitalisation. 
114  Percentage  annual  savings  of  the  cost  of  redesigning  physical  labels  are  a  best  estimate  based  on 
stakeholder interviews. 
115 Estimations based on 13 responses to the policy options survey. 

45 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Printing physical labels  (incl. reducing the 
frequency of disposing) 
Fixing labels to packaging 
Total  annual 
savings 
enterprises 
*Baseline costs are mid-point cost estimates based on the range of cost estimates provided 
by enterprises responding to the stakeholder survey. 

(€)-  Large 

36,000 

44,750 

12,500 

15,417 

4,583 

1,250 

5,625 

8,750 

3,542 

2,083 

7,813 

9,688 

5,625 

3,542 

15,417 

** It should be noted that there was a practical difficulty for the calculations of PO2e in 
that the policy options survey asked the economic operators to estimate future cost savings 
by measure but not by policy options (the policy options were not defined when the survey 
was launched). It’s therefore it is not possible to know what % of cost savings would be 
anticipated once the measures are combined into policy options. 

However, an intelligent estimate for PO2e can be calculated. An assumption is made based 
on the qualitative evidence found during the digital labelling study (e.g. interviews): there 
was a consensus that the distinction between professional and non-professional users could 
be problematic; different approaches for different types of users would therefore tend to 
limit cost savings, as firms might have to assume that any product might end up being used 
by  non-professionals.  On  that  basis,  it  is  assumed  that  combining  measures  3b+5a 
generates no additional cost savings compared to 3a+3b. 

  6.3.2.  Impact on the environment  

The digital labelling study found that introducing digital labelling could provide indirect 
environmental benefits, as it would increase the flexibility of changing label information 
after a label or product package has been printed (i.e. because the printed QR code or other 
IT solution would not need to be changed). Industry stakeholders voiced that moving some 
information could already contribute to environmental benefits of less waste of discarded 
labels, with such benefits increasing as the amount of label information increases.  

On the other hand, it should be noted that PO2d and PO2e propose to move some safety 
information116, for professional users, if it is subject to frequent changes, if it is not linked 
to imminent risks to human health and environmental protection. Even if such links are not 

116 For safety related label elements that can be moved under M5b include (PFC 1-6): declare the content of 
the substance exceeding MRL; warning on using the product in such a way to avoid exceeding MRL in the 
crop;  products  derived  out  of  animal  by-products;  declare  the  content  of  manganese  (Mn)  where  the  EU 
fertilising  product  contains  or  consists  of  thermal  oxidation  materials  and  derivates  or  pyrolysis  or 
gasification  materials;  declare  the  content  of  selenium  (Se)  where  the  EU  fertilising  product  contains  or 
consists of recovered high purity materials; declare the content of chloride (Cl-) where the EU fertilising 
product contains or consists of recovered high purity materials, declaration of the origin of organic matter 
(organic  nitrogen  is  declared);  air  quality  impact  of  urea;  caution  in  using  organo-mineral  and  inorganic 
macronutrient  fertilisers  with  micronutrients  and  inorganic  micronutrient  fertilisers;  declaration  of  the 
content  of  micronutrient  copper  (Cu)  or  zinc  (Zn)  in  an  organo-mineral  fertiliser  and  an  inorganic 
macronutrient fertiliser; content of nitrogen and phosphorus content when they are not declared nutrients; 
polymer  based  binding  material  or  mineral  growing  medium  -  instructions  on  safe  disposal;  declare  the 
content  of  manganese  (Mn)  where  the  EU  fertilising  product  contains  or  consists  of  thermal  oxidation 
materials and derivates or pyrolysis or gasification materials; declare the content of selenium (Se) where the 
EU fertilising product contains or consists of recovered high purity materials. 

46 

 
 
                                                 
imminent risks to the environment, adverse impacts, for example from incorrect use of a 
product could still occur (for example in the case of moving the declaration of the content 
of the substance exceeding maximum residues limits).  

  6.3.3.  Social impact and on human health 

First  of  all  it  is  important  to  note,  the  Public  Consultation  revealed  that  60.9%  of 
respondents  using  (both  professional  and  non-professional  users)  fertilising  products 
currently already access product information via digital means (out of 115 responses), and 
61.5% of responses indicated they look for product information online on a daily or weekly 
basis. 

From a social point of view, reduced information on the label has been carefully chosen 
based on what different users find essential on an EU fertilising product label. PO2a- PO2c 
do not remove any type of safety information (considered the most important information 
on a label by all stakeholders), with an aim to foremost protect those users who may not 
have access to digital information.  

Through the interview programme and the focus groups conducted in the framework of the 
digital labelling study, it was found that most stakeholders (including public authorities, 
product users and industry representatives), insisted that retaining safety information on 
the physical label was non-negotiable and particularly for non-professional users. Overall, 
the  findings  indicated  that  professional  users  were  overall  (for  all  categories  of 
information) more open to the digitalisation of at least some product information. For this 
reason under the PO2a and PO2c, where no distinction is made between the type of user, 
the information digitalised is mostly targeted at those pieces of information relevant for 
professional users. 

No  safety-related  information  is  removed  under  PO2a,  PO2b  or  PO2c,  ensuring  that 
effects human health are protected.  PO2d and PO2e, with the inclusion of measure 5b, 
where most of the label information can be provided digitally for professional users, allows 
for  some  safety  information  (if  it  is  not  linked  to  imminent  risks  to  human  health  and 
environmental protection) to be moved under the digital label117. Even if such links are not 
imminent, adverse impacts, for example from incorrect use of a product could still occur. 

Secondly, the information which remains on the physical label was found to be the most 
essential, and by reducing the amount of other label information provided on the physical 
label, such information could become clearer118. In terms of understanding ability of EU 
fertilising products users, PO2 makes it easier to distinguish between essential and less 
relevant  information,  and  identify  the  information  needed  at  various  points  in  time  by 

117 Please, refer to footnote 110 for a full list of safety information removed. 
118 Most respondents (24%, with 199 responses) to the Public Consultation indicated that simplifying the text 
of  labels  could  improve  the  communication  of  information  on  labels,  while  20%  indicated  that  less 
information  on  a  physical  label,  and  instead  providing  full  details  via  digital  labels  could  improve  the 
communication of label information.  

47 

 
 
                                                 
different users.119 Thirdly, it must be noted that the digital labelling principles (see section 
6.3.1) were developed to safeguard those not able to access digital information, in case the 
moved label information is required by those who consult the label. 

Concerns of moving under the digital label information relevant to after-purchase criteria 
(such as use and storage instructions) and safety information (also for professional users 
and also in terms of seasonal or migrant workers) in situations where a product user may 
not have internet access or digital literacy were raised120. Such information is proposed to 
be moved to a digital label under PO2b for professional users, and under PO2c – PO2e 
for all users. Here it is important to note that such concerns are expected to be mitigated 
by  the  application  of  the  digital  labelling  principles,  and  particularly  principle  8.121 
Although social impacts or impacts on human health of the digital labelling principles were 
not  analysed  under  this  assessment,  the  social  implications  of  the  digital  labelling 
principles are expected to be high. Particularly as digital labelling would only be allowed 
on condition of meeting those principles.  

Further,  if  digital  labelling  is  implemented,  it  may  become  easier  for  those  looking  for 
specific  information  to  find  that  relevant  information  under  a  digital  label,122  as  users 
would be able to search the label information by key words (and the digital information 
will be “complete”123 and “searchable”124). 

  6.3.4.  Stakeholders view on PO2a- PO2e 

Overall industry stakeholders (manufacturers) are in favour of PO2 as it provides scope 
for economic operators to avoid costs related to labelling, while providing the choice for 
those  who  do  not  want  to  digitalise  to  provide  all  information  on  the  physical  label. 
Industry saw PO2a as positive and is supportive especially if higher levels of digitalisation 
are not possible – it is a considered a reasonable step. In terms of the views towards PO2b 
and PO2d and PO2e one part of industry125  saw this PO as very positive, allowing the 
possibility of more cost savings and waste reduction through the ability to split between 
users.  Others126  doubted  that  it  was  possible  to  split  user  groups  in  reality,  as  this  is 

119 Evidence from studies by industry and feedback from the Public Consultation suggests that not all users 
and readers read the information on the label and understand it, in particular non-professional users.  
120 Issues mainly raised during interviews with public authorities. 
121 Digital labelling principle 8: Economic operators who opt for the digital label shall ensure that appropriate 
alternative ways of providing information must be available in case of lack of digital tools or skills, or in the 
absence of network access, both before buying the product and after having bought the product. 
122 According to Digital labelling principle 3: The format of the data provided digitally must be appropriate 
(e.g. rules on font size, the content of the digital label must be searchable); and Digital labelling principle 5: 
Accessibility  of  the  data  both  in  terms  of  ease  of  access  (e.g.  “two-click”  maximum  rule  to  access  the 
information), and in terms of accessibility for users (e.g. also for users with disabilities. Access to the digital 
label must be free and  without a need for prior registration or a password, or prior download of applications. 
Access  limitations  for  certain  user  groups  (e.g.  geo-blocking  in  accordance  with  Regulation  (EU)  2018/302)  are  not 
allowed. 
123 See digital labelling principle 1. 
124 See digital labelling principle 3. 
125 Based on feedback given by industry associations including for growing media, liming materials and plant 
bio stimulants in the ad-hoc expert group meeting. 
126   Based on feedback from industry associations including for blenders in the ad-hoc expert group meeting. 

48 

 
 
                                                 
currently not the case in the FPR. Slight preferences among industry stakeholders was for 
PO2a and PO2d127 (PO2d allows for the highest amount of label information to be moved 
to a digital label). The difference in preference for these two options may be explained by 
the different level of digitalisation already exercised by different companies. 

General preferences of public authorities128 was for PO2a and PO2b129, and particularly 
as a model for transition (i.e. to gradually shift to more digital labelling once confidence is 
gained).  However,  it  should  be  mentioned  that  it  was  raised  that  is  was  preferred  to 
maintain physical labelling in a transitory period in order to safeguard the information for 
users with no digital access, and that only after evaluating the transitory period, a decision 
should be made whether to completely phase out information on the physical label. Further, 
in terms of PO2b, there was some disagreement between national authorities in terms of 
the feasibility of applying a distinction between professional and non-professional users.  

5.6.  Policy  Option  3:  All  information  is  provided  digitally  for  certain 

categories of products  

The impacts of the inclusion of PO3 differ substantially to any other policy options in terms 
of benefits. However, as the ‘digital labelling principles’ will apply to all policy options 
including digital labelling (which means if some label information is to be included on the 
physical label only, all the label information must be provided under that digital label), the 
costs  under  PO2  and  PO3  are  expected  to  be  the  same. As  indicated  above,  the  digital 
labelling principles will apply to all policy options including digital labelling, including 
PO3. 

  6.4.1.  Economic impacts  

Feedback  from  the  fertilising  product  industry  in  general  and  some  fertilising  product 
sectors in particular (e.g. growing media and blenders) suggest that there could be valuable 
cost savings generated by this sub-option (50% said this sub-option would offer ‘more’ or 
‘much  more’  economic  benefits  related  to  better  capture  and  management  of  data,  or 
efficient  use  of  products)130,  when  compared  to  the  current  situation. This  would  make 
industrial purchasing operations more efficient and manage better the (actual and amount 
of)  information  on  such  products.  For  products  for  industrial  use  this  means  access  to 
digital  information  is  more  easily  compiled  and  adapted  in  order  to  create  the  new 
fertilising  product  blends.  For  products  supplied  in  bulk,  having  such  information  in  a 
digital  format  could  contribute  to  ease  of  storing  and  re-accessing  such  information, 

127 As found in the policy options survey, please note the low amount of participation to this question, as 
only 16 responses were counted. 
128  A  general  low-response  rate  of  public  authorities,  conformity  assessment  bodies,  market  surveillance 
authorities should be noted. In case of Conformity Assessment Bodies and Market Surveillance Authorities 
might  be  explained  with  the  fact  that  there  few  bodies  that  are  directly  and  solely  responsible  with  the 
assessment and monitoring of fertilising labels, as the regulation applied only from 16 July 2022. 
129 Generally found to be preferred by public authorities during the feedback provided in the ad-hoc expert 
group  meeting  on  15  March  2022,  which  was  attended  by  public  authorities  as  well  as  EU  industry 
associations. 
130 Finding from the policy options survey, number of responses = 42. 

49 

 
 
                                                 
especially  when a bulk  batch of EU fertilising products  is  used over a longer period of 
time. 

PO3  significantly  contributes  to  the  second  identified  problem  (labels  are  difficult  to 
manage because of the extensive requirements under the FPR). PO3 further meets general 
objective 2 and specific objective 2, as the effective functioning of the Internal Market in 
fertilising  products  is  ensured,  by  improving  the  free  movement  of  fertilising  products 
across the EU. In this context, benefits in terms of no constraints of label space to allow 
for multi-language labels are relevant for products sold to industrial users, but also (to a 
lesser extent) to products sold in bulk131. 

 Table 6.2 Benefits (savings) accruing per enterprise under policy option 3 

Savings against baseline 
Redesigning physical labels 

Machinery/equipment to make physical labels 

Printing physical labels (incl. reducing the frequency of disposing) 
Fixing labels to packaging 
Mid-point cost estimates (€) - SMEs 
Redesigning physical labels 

Machinery/equipment to make physical labels 

Printing physical labels (incl. reducing the frequency of disposing) 
Fixing labels to packaging 

Total annual savings (€) - SMEs 

Mid-point cost estimates (€) - Large enterprises 
Redesigning physical labels 

Machinery/equipment to make physical labels 

Printing physical labels (incl. reducing the frequency of disposing) 
Fixing labels to packaging 

Total annual savings (€)- Large enterprises 

PO3 

50% 
80% 

65% 
40% 

240 
4,000 

1,300 
800 
6,340 

12,000 
20,000 

16,250 
10,000 
58,250 

Overall,  the  digital  labelling  study  found  under  PO3,  enterprises  are  unlikely  to  enjoy 
significant  one-off  cost  savings  as  a  result  of  digital  labelling.  However,  a  mid-range 
possible net annual benefits (based on the assumption that all enterprises that export would 
gain from savings associated with reduced physical labelling requirements because they 
already  provide  digital  labelling  or  would  newly  introduce  it;  i.e.  administrative  costs 

131 As here, currently bulk products are accompanied by a separate leaflet where space limitations are not as 
crucial as when affixed to the actual packaging. 

50 

 
 
  
 
 
 
 
                                                 
savings) to enterprises would be €1 M across the EU 27..132 133 Under PO3 it should be 
noted that the costs and benefits are based on 14% of total enterprises which are assumed 
to  only  provide  products  in  bulk  or  products  which  are  sold  to  industrial  users  (e.g. 
blenders) and can thus make savings under PO3 (i.e. 2 large enterprises and 150 SMEs). 

Cost  savings  are  expected  to  be  the  greatest  under  PO3,  compared  with  other  policy 
options. First, by utmost reducing the frequency of disposing of and redesigning physical 
labels, as digital labels are easier and less costly to update than physical labels. Evidence 
from  the  consultations  suggests  that  the  need  for  redesigns  will  reduce  as  the  extent  of 
digitalisation increases (i.e. moving through the Policy Options from 2a to 2e, with PO3 
offering the highest cost savings).  

As under the economic analysis of PO2, it should be noted that some costs may additionally 
be incurred by the application of ‘digital labelling principle’ #8 (e.g. printing a leaflet with 
label information). Although such costs could not be quantified, they are expected to be 
marginal given that product information would only be supplied to small portions of the 
target market. 

Overall, considering the target users of bulk and industrial use products, PO3 is a low risk 
– high impact option. Under this option, proportionally, the greatest cost savings arise, i.e. 
due to the flexibility provided when all information is digital. 

 6.4.2.  Impact on the environment  

A major driver for the support of PO3 overall is the positive environmental impact of using 
and wasting less product packaging and printed labels, particularly in terms of needing to 
change  product  labels  due  to  fast  changing  information,  and  products  which  will  be 
repackaged before reaching the end-user (those products for industrial use). Also for bulk 
products, label information under Annex III of the FPR would no longer be required to be 
printed and accompanying the bulk product in a leaflet. 

However, it must be noted that under PO3 all label information is provided only digitally, 
including safety-related information is removed from the physical label under this option, 
those users of bulk and industrial fertilising products would need to access all information 
digitally. Again, the digital labelling principles were established in order to protect those 
without  access  to  the  digital  information. Although  the  application  of  the  principles  is 
relevant, it should be noted that the environmental impacts of those principles have not 
been assessed.   

At the same time, even though all information, including use instructions and safety-related 
information is removed under PO3, it does not have the same consequence as for options 
under PO2. This is mainly due to the type of end user using products for industrial use and 
bulk  products  (mainly  companies  and  professional  users,  with  vast  experience  of  the 
products  they are using). Also, bulk  products  currently  are supplied  without packaging, 

132 See Annex 7 for a full breakdown of the costs and benefits. 
133 Assumptions remain consistent with those presented under section 6.3, for more details please refer to 
Annex 4. 

51 

 
 
                                                 
meaning  the  information  supplied  with  the  product  can  easily  be  misplaced  and  is  not 
attached to the product itself. This could ensure the information under the digital label is 
easier accessed and stored, allowing for the better use of fertilising products. 

It can further be noted that the use of fertilising products may differ depending on local 
climatic or soil conditions134, and due to less space limitations of a digital label, product 
use  instructions  could  be  communicated  in  more  detailed  and  specific  ways  to 
accommodate for precision application of a product. This could have indirect downstream 
environmental impacts, in terms of nutrient losses.   

 6.4.3.  Social impact and on human health 

As all information, including safety-related information is moved under this sub-option, 
(particularly relevant to industrial and professional) product users would have to ensure 
that they are able to access the information under the digital label. As stated above, this 
sub-option would trigger the ‘principles of digital labelling’, the economic operator placing 
on the market the product would need to ensure appropriate alternative ways of providing 
information in case of lack of digital tools or skills, or in the absence of network access, 
both before buying the product and after having bought the product. 

Similar to the environmental impacts under PO3, even though all information, including 
safety-related information is removed, it does not have the same consequence as for options 
under PO2. This is mainly due to the type of end user using products for industrial use and 
bulk products (mainly companies and professional users with vast experience). Also, for 
those  products  currently  supplied  without  packaging,  this  option  could  ensure  the 
information under the digital label is easier accessed and stored, allowing for the better 
protection of human health.  

 6.4.4.  Stakeholders view on policy option 3 

Overall,  strong  support  was  received  for  this  policy  option  through  the  policy  options 
survey  and  through  the  ad-hoc  expert  group  meeting135.  The  industry  stakeholders 
(manufacturers)  supporting  this  option  indicated  they  usually  have  digital  systems  (i.e. 
websites) operating already, but which would alone (without the present  physical label) 
not be allowed under the FPR. Clear benefits would arise from allowing digital labelling 
only under the FPR. 

For professional users, there would be some benefits of being able to access more technical 
information in digital form. Due to the specific types of products covered by this PO, non-
professional users are not affected. 

7.  7. HOW DO THE OPTIONS COMPARE? 

In the table below options are compared, and subsequently discussed. 

134 As raised during the interviews with stakeholders. 
135 See minutes available here Circabc (europa.eu) 

52 

 
 
                                                 
The degree of 
simplification 
of the label 
through 
digitalisation  

The type of 
information 
digitalised 

(-) 

Nil 

Nil 

Criteria 

Option 1 

Option 2a 

Option 2b 

Option 2c 

Option 2d 

(M2) 

+ 

A certain 
level 

(M3a+M3b) 

++ 

Partly more than 
PO2 (in the case of 
M3a) 

(M4) 

+++ 

(M5a+M5b) 

+++ 

Option 2e 

(M5a+M3b) 

+++ 

Option 3  

(M6) 

++++ 

A high level 

A high level 

A high level 

Highest level of digitalisation 
of all options 

Frequently 
changing 
information if 
not linked to 
S136; Some of 
AE137; AP138 

Frequently changing 
information if not 
linked to S; A good 
deal of AE; AP  

Frequently 
changing 
information if not 
linked to S; Some 
of AE, AP, IC139  

Some safety (S) 
information 
under M5a; most 
AE; AP and IC 

Frequently changing 
information if not linked to S 
for M3b, also some s FOR 
m5a; Some/most of AE, AP, IC  

All information, including S, 
for M6 

Split 
professional 
and non-
professional 
users? 

Economic 
impacts (cost 
savings, ease of 
market access 
and free market 

No 

No 

Yes 

No 

Yes 

Yes 

n/a140 

( ) 

Neutral 

+ 

Positive 
impacts  

+ 

++ 

++ 

+ 

+++ 

Positive impacts  

Strong positive 
impacts 

Strong positive 
impacts  

Positive impacts  

Very strong positive impacts 

136 Safety information. 
137 Information relevant to agronomic efficiency. 
138 Information relevant after purchase. 
139 Information on content (not linked with agronomic efficiency). 
140 This option is concerned only with professional and industrial users. The option targets different products and not users. 

53 

 
 
 
                                                 
Criteria 

Option 1 

Option 2a 

Option 2b 

Option 2c 

Option 2d 

(M2) 

(M3a+M3b) 

(M4) 

(M5a+M5b) 

Option 2e 

(M5a+M3b) 

Option 3  

(M6) 

movement 
across EU-27) 

Costs of 
implementatio
n 

Recurring 
annual savings 
(€, all 
enterprises 
EU27) 

Net recurring 
benefits141142 
(€, all 
enterprises 
EU27)) 

Nil 

In terms of individual enterprise costs, the costs of implementing PO2a-PO2e and PO3 options will be the same because if any information is moved 
to a digital label, the digital label must be complete. Differences between enterprises will only result from the extent to which they are already 
provide digital product information. As the implementation will be voluntary, cost savings are expected to be greater than any implementation costs. 
Total enterprise costs of optional digital labelling is expected to be: 

For large enterprises: between €14,998 – €29,998 for one-off costs and between €2,700 - €7,700 for ongoing (annual) costs. 

For SMEs: between €1,796 - €6,046 for one-off costs and between €1,170 - €3,770 for ongoing (annual) costs. 

0 

308,590 

487,500 

4,825,500 

5,523,000 

487,500 

1,067,500 

286,950 

465,900 

4,099,560 

4,797,060 

465,900 

966,520 

-
3,580,2
88 

141 Calculated at end of year 1; please, refer to Annex 3 for summary tables of costs and benefits, and Annex 4 for the assumptions used. 
142 This is modelled on the highest cost scenario. Given that the cost of implementation of digital labelling will be marginal, this was not considered for those enterprises already providing 
some product information online. So the net recurring benefits are mainly relevant for those companies not yet proving product information online, as an initial digitalisation cost will be 
incurred. Only benefits can be imagined for those companies already providing product information online. 

54 

 
 
 
                                                 
Criteria 

Option 1 

Option 2a 

Option 2b 

Option 2c 

Option 2d 

(M2) 

119,984 

(M3a+M3b) 

(M4) 

(M5a+M5b) 

119,984 

Option 2e 

(M5a+M3b) 

Option 3  

(M6) 

180,860 

Net one-off 
costs (€, all 
enterprises 
EU27) 

-
5,737,4
46 

Environmental 
impacts 

( ) 

None 

1,201,176 

1,201,176 

119,984 

+ 

Little detail is available regarding the quantification of environmental consequences of waste reduction. It has 
been identified as an indirect benefit. In principle, the more information is removed from the physical label, the 
greater the scope for reducing environmental impacts due to less packaging/label waste.  

However, if AP information (e.g. use instructions) is not followed due to not being on the label, this can have a 
counter effect and inadequate of products can have a negative impact on the environment. On the other hand, the 
digital labelling principles aim to safeguard those without access to the digital information by requesting that 
alternative means of communication are available.  

++ 

Although the data collected 
does not allow for 
quantification, of such an 
impact, major support was 
based on the positive 
environmental impact of 
using and wasting less 
product packaging and 
printed labels. 

Stakeholder 
impacts: 

- Industry 

- Professional 
users 

( ) 

+ 

+ 

Cost savings 

Cost savings 

Neutral 
as 
compare
d to the 
baseline 

++ 

Strong cost 
savings 

++ 

+ 

+++ 

Strong cost 
savings 

Cost savings 

Most cost savings 

( ) 

+  

- 

- 

( ) 

Neutral 
as 
compare
d to the 
baseline 

Not much 
affected, with 
a slight 
positive 
impact as the 
information 

Information on the physical label becomes 
clearer. Some professional users may find 
information elements missing from the 
physical label.  

Some professional users may think too much is 
removed, given that part of S information is 
removed. 

Neutral, although a slight 
positive impact may be 
experienced as those using 
bulk products may benefit 
from better access and 
clearer information. On the 

55 

 
 
 
  
  
  
 
Criteria 

Option 1 

Option 2a 

Option 2b 

Option 2c 

Option 2d 

(M2) 

(M3a+M3b) 

(M4) 

(M5a+M5b) 

Option 2e 

(M5a+M3b) 

Option 3  

(M6) 

- Non-
professional 
users 

on the 
physical label 
becomes 
clearer.  

other hand a slight negative 
impact may be experienced 
as all information, including 
safety information is only 
available digitally. 

( )  

+ 

+  

- 

+ 

( ) 

May find some information missing on 
the physical label – as some AP 
information is removed from the 
physical label. 

Same as for Option 2b 

Not affected. 

Neutral 
as 
compare
d to the 
baseline 

The 
information 
remaining on 
the physical 
label becomes 
clearer. 
Otherwise not 
much 
affected, as 
the 
information 
moved to a 
digital label is 
not so 
relevant.  

The information 
remaining on the 
physical label 
becomes clearer. 
Otherwise not much 
affected - non-
professional users 
think S and AP 
information are 
essential, so under 
M3a, such 
information remains 
on the label. 

Effectiveness  
SO1- Improved 
readability of 
the labels of 
EU fertilising 
products  

+ 

Potential
ly a 
more 
legible 
and 
effective 
version 

++ 

Increasing space on the label by reducing text requirements could provide the opportunity to make what remains 
clearer – more effectively communicated. 

The digital version of the label has the potential to provide more transparency and clarity (e.g. digital label 
information will be searchable), and act as a link to other useful information for which there is no space on the 
label (e.g. more detailed use instructions due to different locations, soil types and climates). 

n/a 

No data was collected in 
terms of the improved 
readability of labels 

56 

 
 
 
Criteria 

Option 1 

Option 2a 

Option 2b 

Option 2c 

Option 2d 

(M2) 

(M3a+M3b) 

(M4) 

(M5a+M5b) 

Option 2e 

(M5a+M3b) 

Option 3  

(M6) 

of the 
digital 
label 
only (if 
the 
guideline
s are 
used). 

( ) 

Neutral 

(SO1) 

Effectiveness 
SO2 -Facilitate 
the managing 
of labels by 
economic 
operators 

 (SO2) 

 +  

++  

+++  

++  

++++ 

Positively effective impact in terms of 
managing label information 

Highly effective 
impact in terms of 
managing label 
information 

Very highly 
effective in terms 
of  managing 
label information 

Highly effective impact in 
terms of managing label 
information 

Most highly effective in 
terms of managing label 
information  

57 

 
 
 
 
 
  
 
 
 
*The  take-up  rates  for  these  options  would  be  lower  than  the  estimates  used  here;  only 
companies  that  perceive  positive  net  benefits  would  choose  to  digitalise  (unless,  they 
perceive other benefits). The net benefits for these options would therefore be zero at worst.  

8.  8. PREFERRED OPTION 

The preferred option is PO2a, meaning the optional digitalisation of certain information of 
the label of EU fertilising products, without making a distinction between professional/non-
professional  users  combined  with  PO3,  meaning  the  optional  digitalisation  of  all  the 
information for products sold to industrial users or products sold in bulk. 

While PO2a is the most cautious in terms of the scope of the information to be provided 
only digitally, combining this option with PO3 ensures the objectives are most effectively 
addressed, keeping a balanced approach to the different views of stakeholders.  

Firstly, option 2a implies keeping all the safety related information on the physical label. 
By reducing the information to be included on the physical label, safety information will 
become  more  visible  thus  contributing  to  the  objective  of  protecting  the  health  and  the 
environment. As part of the support study, the interviews and focus groups confirmed that 
both  non-professional  and  professional  users  found  safety  related  information  the  most 
essential information on a fertilising product,  so that category of information should stay 
on the physical label. It was further found that non-professional users relied mostly on the 
physical labels only (i.e. they did not obtain product information from other sources then 
directly  from  the  product  label).  Professional  users,  on  the  other  hand,  often  had  past 
experience with products or training, or relied on technical advisors in determining the best 
product for their needs. On the other hand, some of the agronomic efficiency criteria was 
found  to  be  too  technical  for  non-professional  users.  Consequently,  this  category  of 
information  is  proposed  to  be  moved  to  the  digital  label  with  priority  (along  with 
information on content). This option takes most into account the digital divide. Removing 
all label  information, including safety information, under option 3 is  justified due to  the 
particular users concerned with the products in question. 

Secondly, this combined option will reduce labelling costs and will create a level playing 
field between economic operators. The labelling costs will be reduced both by including 
more languages on the label and by avoiding frequent changes. 

Lastly,  this  combined  option  is  easier  to  apply  and  enforce,  as  no  distinction  is  made 
between professional and non-professional users. Such a distinction does not exist in the 
FPR itself. Such a split would have implied both that the manufacturers will have to target 
their products to one or the other of the two categories and that the enforcement authorities 
would  have  had  to  check  that  the  products  for  professional  users  are  not  sold  to  non-
professional users. 

This option complies with the proportionality principle. It does not exceed what it is needed 
to  achieve  the  objectives  followed.  The  digitalisation  of  the  labels  will  remain  optional. 
Whenever it is used, it will be accompanied by the general principles of the digitalisation, 
to ensure the quality and the accessibility of the information provided digitally. In coherence 
with  the  approach  that  will  be  taken  on  digital  labelling  for  CLP  and  detergents,  as 
experience and confidence is gained in digital labelling, it could be possible to increase the 

58 

 
 
amount  of  information  available  digitally  in  the  future,  which  may  further  increase  the 
simplification potential for industry. 

The preferred option implies applying the same conditions both for products produced in 
the  EU  and  those  originating  from  third  countries.  Given  its  optional  nature  and  that  it 
basically implies more choices for the labelling of EU fertilising products, this option is not 
trade-restrictive.  

8.1. REFIT (simplification and improved efficiency) 

To make sure that the FPR remains fit for purpose, the Commission’s rolling regulatory 
fitness and performance programme (REFIT)143 identifies opportunities to simplify laws, 
streamline  procedures  and  eliminate  unnecessary  burdens  without  undermining  the 
objectives and benefits of the Regulation in question, e.g. by means of looking for digital 
solutions. This impact assessment accompanying the proposal for a legislative revision of 
the FPR has thus aimed to analyse the potential for simplification and burden reduction. 

This initiative directly contributes to the REFIT scoreboard (Areas 13. Chemicals legislation 
(other  than  REACH)),  in  the  area  identified  where  communication  of  hazard  and  safety 
information to consumers can be improved and simplified, including by using digital tools. 
Reaping the benefits of the digital age will result in potential burden reduction for SMEs, 
improved  enforcement  and  compliance,  reinforcing  cooperation  between  competent 
authorities, including customs and market surveillance authorities144. 

8.2.Application of the ‘one in, one out’ approach  

First of all, this initiative was driven by the request of industry as a simplification measure 
in response to the adoption of the FPR, and is in line with the trends of digitalisation. 

Given  the  voluntary  nature  of  the  preferred  option,  no  costs  would  be  imposed  on 
businesses. It is expected that businesses would only incur direct adjustment costs related 
to digital labelling (see Annex 4 for a full breakdown of costs) if they perceived the potential 
to enjoy reduced costs (or if they perceived sufficient other business benefits to justify any 
cost increase).  

On the other hand, given the optional nature of PO2a, the benefits would also not materialise 
if no enterprises opt for digital labelling, as it is not economically viable. In order to make 
PO2a as economically attractive as possible, frequently changing information on product 
labels have been moved to the digital label with priority. The data collected as part of the 
study did not go into the level of detail on particular cost savings per labelling requirement. 
However it must be noted that benefits are particularly associated with moving such fast 
changing information to a digital label, meaning that in the longer term it can be expected 
that labels would need to be (re)printed less frequently. 

Therefor  there  are  no  specific  costs  (only  cost  savings)  related  to  the  ‘one  in,  one  out’ 
approach since physical labelling rules would remain, but would only be revised to allow 
some of the labelling requirements to be provided digitally only. Any additional costs of 
digital labelling compared with the baseline should in principle be offset by the cost savings 

143 REFIT – making EU law simpler, less costly and future proof | European Commission (europa.eu)   
144 Internal market, industry, entrepreneurship, SMEs and statistics (europa.eu)   

59 

 
 
                                                 
associated  with  better  and  more  flexibly  managing  information  of  labels,  by  moving 
information to a digital label.  

The estimates for preferred policy option 2a suggest that a mid-range possible one-off net 
benefits would be negative accruing to all enterprises in EU27 (i.e. --119,984€, based on the 
assumption that all enterprises that export would gain from savings associated with reduced 
physical labelling requirements). Annual maximum recurring benefits for PO2a would be 
856,317€ accruing to all enterprises (EU27). Under option 3, maximum possible one-off net 
benefits  would  also  be  negative  (i.e.  --519,674-€,  based  on  the  same  assumptions  as  for 
PO2a).145 However, annual maximum recurring net benefits for PO3 would be €2,961,370 
accruing to all enterprises146 (EU27). 

This means that overall, the preferred policy package has a maximum possible recurring net 
benefit of €3,827,687. Net recurring benefits minus one-off costs would equal to €3,188,029 
net befits at the end of year one. 

Further, as experience and confidence in digital labelling is gained, increasing the amount 
of information allowed to be moved digitally may further increase, therefore increasing the 
simplification potential for industry in the future. 

9.  9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

As with any new regulatory initiative, if the preferred option is implemented, there will be 
periodic evaluation and monitoring. In particular, monitoring could be undertaken by the 
Commission  in  conjunction  with  EU  and  national  industry  associations,  and  consumer 
associations  to  get  feedback  from  their  members  regarding  how  well  (or  otherwise)  the 
digital labelling rules are working, and on whether the remaining information on physical 
labels is being communicated in a more effective manner or not, and if expected cost savings 
from the introduced flexibility are experienced.  

The importance of regular feedback loops between the Commission and key stakeholders 
in the industry and consumer associations and associations representing the interests of both 
professional  and  non-professional  users  can  be  highlighted.  This  would  provide  an 
opportunity  to  learn  any  initial  lessons  from  digital  labelling,  including  its  advantages, 
drawbacks and any practical challenges in its implementation.  

An evaluation of the FPR will be carried out by 16 July 2026147, and such an evaluation will 
gather  evidence  to  assess  how  this  specific  intervention  has  performed  (or  is  working), 
taking account of the expectations in the context of this impact assessment and ensuing from 
the adopted legislation and whether there were unintended or unexpected effects that were 
not anticipated and taken into account in the impact assessment. The evaluation will draw 
conclusions as to whether the EU intervention remains fit for its purpose, should be adjusted 
for greater effectiveness, relevance and coherence, and/or to eliminate unnecessary burdens 
or inconsistencies, or should simply be repealed. 

145 One-off costs are expected to remain the  same  under PO2 and PO3. Please refer to Annex 4  for a full 
breakdown of cost and benefit calculations. 
146 Relevant to PO3 14% of all enterprises are assumed to only provide products in bulk or products which are 
sold to industrial users (e.g. blenders). 
147 Article 49 FPR, Report. 

60 

 
 
                                                 
The following indicators could be used to evaluate the digital labelling aspects: 

Objectives  

Indicators  

Sources of information  

Improved readability of 
the labels of EU 
fertilising products 

Uptake of digital technologies 
within the sector 

Evaluation/ consultation of 
stakeholders /users  

Perceived satisfaction of users 
(professional and non-professional) 
with the digital labelling 

Facilitate the managing of 
labels by economic 
operators 

Costs savings realised due to 
digitalisation of labels 

Evaluation/ desk research / 
consultation of enterprises 

61 

 
 
 
 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

1.  LEAD DG, DECIDE PLANNING/CWP REFERENCES 

The lead DG for this initiative is the DG for Single market, Industry, Entrepreneurship and 
SMEs (DG GROW). The Directorate in charge is Directorate F – ‘Ecosystems I: Chemicals, 
food, retail’. 

The initiative is encoded in Decide Planning with the reference PLAN/2021/10559. 

ORGANISATION AND TIMING 

The inception impact assessment consultation period ran from 14 July 2021- 20 September 2021. 

The  public  consultation  period  ran  from  24  November  2021  –  17  February  2022.  A  factual 
summary of the findings has been published148. 

An inter-service steering group was convened on 10 May 2021 and chaired by DG GROW F2. 
The last meeting of the ISSG on the final draft impact assessment report was held on 17 June 
2022.  

The  following  Directorates-General  participated  to  the  inter-service  steering  group:  SG,  LS, 
AGRI,  JUST,  TRADE,  CNECT,  GROW,  JRC,  SANTE,  ENV,  and  the  European  Chemical 
Agency (ECHA). 

2.  CONSULTATION OF THE RSB 

The RSB was consulted in an upstream meeting on 12 January 2022. This impact assessment 
was submitted to the RSB on 22 June 2022.  

The RSB issued its opinion through written procedure on 22 July 2022 following which this 
Impact Assessment was revised as follows: 

RSB Recommendations 

Revisions introduced 

What to improve 

The  report  should  set  out  clearly  the 
coherence  of  the  initiative  with  other 
initiatives aimed at the digitalisation of the 
accompanying 
labels 
products  for  construction  products  and 
medical devices as well as for the initiatives 
under  preparation  concerning  batteries, 
and  hazardous 
detergents, 

documents 

cosmetics 

or 

In  point  1.1  in  the  SWD,  it  is  explained 
what  steps  have  already  been  taken  to 
ensure  coherence  among 
the  various 
initiatives on digital labelling of chemicals 
and  how  coherence  will  be  ensured  in 
future. 
ensured 
coherence  in  developing  all  the  proposals 
and  will  put  forward  similar  digital 

Commission 

The 

148  ‘Have  your  say’,  Chemicals  –  simplification  and  digitalisation  of 
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12992-Chemicals-simplification-
and-digitalisation-of-labelling-requirements_en 

labelling  requirements; 

62 

 
 
 
                                                 
chemicals.  It  should  provide  the  dynamic 
baseline  taking  into  account  likely  future 
developments. It should explain better what 
prevents  Member  States  from  voluntarily 
adopting the best practices in the near future 
under  a  dynamic  baseline  scenario  and 
explain  how  the  baseline  will  evolve  and 
what the uncertainties are. 

labelling  general  rules.  The  Commission 
will  ensure  further  ensure  coherence  in 
supplementing these general principles in a 
subsequent  step,  once  digital  labelling  is 
introduced  in  the  basic  Regulation.  More 
details on the dynamic baseline have been 
introduced  in  sections  5.1.5  and  5.1.6  as 
regards the tendency of companies to take 
up digital labelling and the impact of DPP.   

The report should better explain the risk that 
the  estimated  benefits  of  the  preferred 
labelling  of  certain 
option  on  digital 
information  will  not  fully,  or  not  at  all, 
materialise  given  that  the  analysis  shows 
that  the  benefits  for  this  option  will  not 
outweigh  the  costs  resulting  in  overall 
negative  net  benefits.  It  should  reiterate 
more  clearly  the  benefits  associated  with 
moving certain information to a digital label 
and  highlight 
that  economic 
the  fact 
operators will opt for digital labelling only 
if  is  economically  viable.  In  this  respect, 
also  accounting  for  the  dynamic  baseline, 
the  report  should  provide  a  range  (rather 
than a single point) for the estimate of the 
number  of  businesses  that  are  assumed  to 
choose  to  provide  digital  labelling  as  a 
result of this initiative. It should also present 
the level of stakeholder support 

The report should elaborate on the indirect 
and  possible  unintended  consequences 
associated  with 
certain 
information digitally instead of providing it 
on the physical label. It should clarify users’ 
attitude  to  access  effectively  and  to  use 
digital labelling. 

providing 

It  is  also  clearly  stated  that  none  of  the 
Member States adopted rules on the digital 
labelling  of  fertilising  products  and  that 
their  competence  in  this  field  is  limited 
given the existence of harmonisation rules. 

On  the  estimation  of  the  number  of 
companies  expected  to  opt  for  digital 
information  has  been 
labelling,  more 
included in the section dedicated to costs in 
6.3  of  the  SWD.  The  estimation  is  made 
depending on the size of the enterprise and 
statistical  data  available  as  regards  %  of 
enterprises involved in trade in two or more 
Member States.  

In section 8.2 of the SWD it is  explained 
that the benefits will occur if the economic 
operators  will  opt  for  digital  labelling  as 
they find it economically viable.  

In section 8 in the SWD, it is explained that 
as all safety information is maintained on 
the  physical  labels  for  packaged  products 
sold  to  end-users,  then  there  are  no  risks 
created associated to the introduction of the 
digital  labelling.  As  regards  products  for 
which  full  digitalisation  will  be  allowed, 
the situation is  not  drastically  different  to 
providing  the  information  on  a  document 
not linked in any way to the products itself 
(as it is sold in bulk). 

63 

 
 
The  report  should  clarify  what  success 
would look like and explain to what extent 
the  success  criteria  of  the  policy  initiative 
are measurable. 

This information is provided in section 9 in 
the SWD.  

3.  EVIDENCE SOURCES AND QUALITY 

This  Impact  Assessment  was  supported  by  an  outsourced  study149  (hereafter  the  ‘digital 
labelling study’) carried out by an external contractor. The study had a scope extending to 
all aspects related to digital labelling under Annex III of the Fertilising Product regulation 
(FPR)150.  

As part of the study, the consultants carried out a large number of consultation activities 
including  72  semi-structured  interviews  with  Public  authorities,  Conformity  assessment 
bodies  and  market  surveillance  authorities,  Industry  stakeholders,  Professional  users  and 
Non-professional  users  of  fertilising  product,  Academia  and  Non-Governmental 
Organisations.  

Further, the consultants carried out online surveys (a targeted ‘stakeholder survey’ and an 
specific survey on possible policy options (also referred to as the ‘policy options survey’)), 
a survey  experiment  (which  explored the effects  of labelling  changes on  key  behaviours 
among professional and non-professional users of fertilising products), focus groups (with 
product users) and usability testing exercise (which tested the popularity and potential use 
of various digital technologies that could be implemented on the fertilising product labels). 

The findings at various stages of the study (including the inception, interim and draft final 
reports) were discussed  with  an  Inter Service Steering Group, and were presented in  the 
Commission expert group on EU Fertilising Products. 

Evidence was also gathered during these consultations of the Commission expert group on 
EU Fertilising Products. Further, a workshop on digital labelling was held on 26 November 
2021, which was open to all interested stakeholders. Another targeted workshop with the 
members and observers of the Commission expert group on EU Fertilising Products was 
held on 15 March 2022 (also referred to as the ad-hoc expert group meeting). 

The  impact  assessment  provides  qualitative  and  where  possible  quantitative  information 
regarding the positive and negative impacts generated by each Policy Option (PO), reporting 
the main information on the sectors and economic operators mostly affected by the proposed 
changes. This analysis is based on the evidence gathered through all consultation activities. 

149 CSES (2022) Impact Assessment Support study on the use of digital labelling for EU Fertilising Products,, 
not yer published 
150 Regulation (EU) 2019/1009 of the European Parliament and of the Council of 5 June 2019 laying down 
rules on the making available on the market of EU fertilising products and amending Regulations (EC) No 
1069/2009  and  (EC)  No  1107/2009  and  repealing  Regulation  (EC)  No  2003/2003:  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32019R1009 

64 

 
 
 
                                                 
Sources have been chosen as reliable as possible. Whenever possible, economic, social and 
environmental  impacts  were  assessed  quantitatively,  and  is  otherwise  substantiated  by 
triangulated  qualitative  findings.  Similar  data  were  cross-checked  whenever  possible,  in 
particular with findings from another parallel digital labelling study on CLP and Detergents. 
It  is  acknowledged  that  some  data  are  estimates;  in  order  to  compensate  for  possible 
inaccuracies,  throughout  this  document  benefits  have  been  estimated  in  a  conservative 
manner.  

It has been consistently attempted to quantify impacts, but sometimes limitations of data 
have made possible only a qualitative analysis: 

Data needed for the analysis has been obtained from multiple sources, chosen as reliable as 
possible151. Relevant limitations of data generated important challenges in the quantification 
of costs and benefits. Challenges encountered: 

As it remains the free choice of manufacturers to apply the FPR or to rely on national rules. 
Therefore, it is difficult to estimate the number of economic operators who would make this 
choice as of 16 July 2022 or in the following years. 

The following assumptions are worked with: 

1.  Given that compliance with the FPR is more difficult to achieve and prove, there is no 
guarantee that all the manufacturers which rely now on EC Fertilisers Regulation will 
continue to reply on the FPR as of 16 July 2022. 

2.  As for the products which are not covered by EC Fertilisers Regulation, but could be 
covered by the FPR as of 16 July 2022, making an estimation on how many will opt for 
the FPR is even more difficult. 

Therefore, insufficient information and data are currently available on likely future trends 
for all product groups to translate these into a full quantitative analysis. Furthermore, data 
on the number of affected economic operators in the value chain is difficult to generate. 
More generally, there is a general lack of granular information on the economic and social 
impacts of the policy options, as it currently stands. Thus, the quantification of costs and 
benefits is as comprehensible as possible for both the baseline scenario and different policy 
options, but the limitations should be considered. 

151 See Annex 4  

65 

 
 
 
                                                 
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) 

1.  THE CONSULTATION ACTIVITIES 

The following consultation activities have been carried out: 

 

Interviews 

  An Open Public Consultation  

  A targeted survey of stakeholders 

  Focus groups 

  A survey experiment 

  Usability testing 

  An Expert Group workshop on options for digitalisation of labels  

  A survey on costs and benefits related to various digitalisation options   

These will now be dealt with in turn. 

1.1 

Interviews 

The  purpose  of  interviews  was  to  gather  in-depth  information  from  different  stakeholder 
groups, to obtain otherwise unobtainable observations, such as the nuanced perception of users 
and important details that are hard to register during quantitative exercises.  

In-depth interviewing comprised a scoping phase, which enabled the researcher to: 

  Become more familiar with the topic at hand, gather the relevant background data and 

start identifying important stakeholders in the field 

  Provide data for refining the interview questionnaire and the structure of further data 

collection exercises.  

The second stage of the interview programme gathered information with the use of an interview 
questionnaire,  focusing  on  tasks  as  outlined  in  the  table  above.  In  detail,  the  interview 
programme aimed to collect information about: 

  Perceptions  and  understanding  of  fertilising  product  labels  among  various  types  of 

users 

 

Identification of essential labelling information 

  Use patterns 

  Benefits and disadvantages of digital labelling 

  Analysis of potential IT solutions, IT literacy and readiness to shift to digital labelling 

 

Industry labelling practices, potential of digital labelling, cost categories associated to 
digitalisation 

66 

 
 
  Exploration of previously unidentified aspects 

Overall  72  semi-structured  interviews  were  conducted.  The  table  below  summarises  the 
completed interviews in terms of the different target groups.  

Table 9.1: Completed interviews by stakeholder groups 

Type of stakeholder 

Interviews completed 

Public administration, national and European authorities 

Conformity  assessment  bodies  and  market  surveillance 
authorities  

Industry stakeholders including manufacturers, importers, 
distribution intermediaries and suppliers  

Professional  users  of 
associations representing professional consumers) 

fertilising  products 

(including 

Non-professional  users  of  fertilising  product  (including 
gardening lecturers, consultants) 

Academia; Non-Governmental Organisations, civil society 
and citizens 

3 

7 

40 

12 

7 

3 

During  this  phase,  more  than  500  potential  interviewees  were  contacted.    With  regards  to 
stakeholder group responses to the survey, although responses from  public administration, 
national  and  European  authorities,  and  conformity  assessment  bodies  and  market 
surveillance authorities were disappointing, this was compensated for by their participation 
in the Expert Group and in particular with the written inputs to the Expert Group Workshop 
(see below). Representatives of the academia and NGOs were also sought in large numbers. 
They were however largely unresponsive, although some NGOs that declined interviews did 
submit inputs to the consultation and Expert Group Workshop. The large number of interviews 
with industry stakeholder and fertilising product users revealed that input from these groups 
was often divergent, varying, for example, according to the Product Function Categories (i.e. 
PFCs)  and  the  types  of  users  in  question.  The  large  number  of  interviews  with  industry 
stakeholders has been taken into account when evaluating qualitative results and the possible 
imbalance in the representation of interests. 

Interviews  were  carried  out  online  or  via  phone,  some  participants  also  provided  written 
answers to our interview questionnaire. Recordings were transcribed and, if needed, translated 
to  English. The  analysis  of  qualitative  data  from  interviews  was  conducted  with  the  use  of 
coding sheets.  

  The  interviews  provided  wide  ranging  and  very  valuable  inputs  that  were 
incorporated into the report findings. Interview responses reflected the diversity 
of the stakeholders involved, as well as varying views within stakeholder groups, 
the different types of farmers, farming practices, hobby gardeners, manufacturers, 
exporters, public authorities, etc.  

67 

 
 
 
1.1. 

1.2 

Open public consultation 

An  open  public  consultation  (OPC)  was  held  to  obtain  feedback  for  the  “Inception  Impact 
Assessment”  (on  the  ‘have  your  say’  webpage  on  the  ‘Proposal  for  a  Regulation  of  the 
European Parliament and of the Council laying down rules on the simplification and possible 
voluntary digitalisation of labels on chemicals and amending Regulations (EC) No 1272/2008, 
(EU) 2019/1009 and (EC) No 648/2004. Short title:  Simplification and digitalisation of labels 
on chemicals (CLP, Detergents, Fertilising Products).’  

The OPC was conducted by the European Commission with the aim to gather opinions on the 
possible digitalization of labelling of various chemical products, among them, fertilisers. The 
consultation  was  available  in  all  24  official  EU-languages.  Altogether,  205  stakeholders 
participated  in  the  open  public  consultation.  117  respondents  indicated  to  use  fertilising 
products at work or at home. 

The aim of the OPC was to provide data on the knowledge, preferences and opinions of various 
stakeholders regarding the digital labelling of fertilising products (as well and detergents and 
other chemicals). 

205  responses  were  collected,  most  of  which  come  from  the  industry  i.e.  companies  and 
business  associations.    Nearly  half  (48.7%)  of  the  responses  were  from  large  organisations 
(>250employes).  

Type of respondent 

Business association 
Company/business organisation 
Consumer organisation 
EU citizen 
Non-EU citizen 
Non-governmental organisation (NGO) 
Public authority 
Trade union 
Other 
Total 

Frequency  Percentage 
18% 
47% 
1% 
23% 
1% 
0% 
5% 
0% 
4% 
100% 

36 
96 
3 
47 
2 
1 
10 
1 
9 
205 

25.9% were from Germany, 10.2% from France, 9.8% from Belgium and 6.8 % from Spain.  

  Key findings 

  For the purposes of this study, it was possible to extract the answers specifically 
relevant to fertilising products. The consultation provided useful information on 
topics including the following. However, it should be kept in mind throughout that 
a sizeable proportion of the answers are form industry representatives. Also FPR 
labels are not in use at time of writing so it can be questioned if respondents have 
actual experience of such labels).  

68 

 
 
 
 
  54.5% of respondents (N=200) could usually understand the information printed 
on the label of a fertilising product, 12% to some extent and 5% some of it.  

  Most respondents can access products information via IT solution or digital tools 

(60.9%) and look at information online at least weekly (61.5%). 

  Reading  labels  before  purchase  was  the  most  frequently  chosen  option  among 
respondents, followed by reading before using the product. Thus, respondents use 
labels much less after usage, e.g. for storage, disposal or in case of accidents 

  Respondents think that label text simplification, presenting less information and 
using  more  pictograms  and  graphic  symbols  are  the  most  effective  way  of 
improving communication. 

  Over half of respondents (52.1%, N=198) would respond positively or moderately 
positively  if  some  information  was  removed  from  the  label  and  could  only  be 
obtained digitally (22.7% did not know/ could not answer – so among those that 
answered the percentage is higher -66.9%). 

  Respondents (N=201) would prefer to access labels through smartphones (30%), 

laptops (21%), tablets (20%) or desktop computers (17%)  

  The main benefits of presenting some label information via IT solutions (N=195) 
include: the possibility to provide more detailed information (14%), being able to 
provide all the relevant information where the package is too small (14%), ease 
of  access  of  information  (13%),  access  to  updated  information  (13%)  and 
information  in  additional languages (13%); more  relevant/targeted information, 
environmental benefits (19%) cost savings (8%). 

  The  main  challenges  of  presenting  some  label  information  via  digital  labels 
(N=200) include: difficulty to access information (24%), differences between on-
pack and digital information (22%), inequalities for different population groups 
(22%), and increased costs for industry.    

  The OPC also provided feedback on the possibility of removing specific items of 
information. This is highly detailed and readers are requested to refer to the OPC 
or the main report to access this information.   

  When non-professional users were asked about fertilisers in general, the largest 
share of them said that ‘Safety requirements’ is at least very important to them, 
while  21.9%  of  the  respondents  also  see  ‘Agronomic  efficiency’  as  of  average 
importance.  Non-professional  seem  to  be  mostly  in  an  agreement  regarding 
‘Agronomic efficiency’, as 73.9% of respondents would remove the information 
from  the  physical  label  to  digital  format  at  least  partially. At  the  other  end  of 
preferences, we find that 36.3% of respondents would keep all the information on 
‘Safety  requirements’  on  the  physical  label,  closely  followed  by  information 
relevant after purchase (35.9%). 

  Some 26% of respondents (N=136) indicated that they provide the information on 
the on-pack label online; and 48 % that they provide additional information to that 
on the on-pack label online (74%).  

  The  main  reasons  for  providing  information  online  (multiple  choice  possible) 
(N=130) were given as: improved customer service (25%), problems with fitting 

69 

 
 
information on the physical label (21%) and the possibility to update information 
more easily (20%) were the first three most popular answers. 

  Better  management  of  frequently  changing  label  information  is  the  most 
beneficial aspect of digitalisation according to respondents, closely followed by 
the increased easiness to comply with new labelling requirements, and then better 
targeted communication and cost savings. 

  With regards to potential challenges of labelling digitalisation (N=143), managing 
different data formats has been selected as extremely challenging in the largest 
percentage  (17%).  However,  implementing  IT  solutions  seems  to  be  the  most 
challenging  aspect,  if  ‘moderately’  and  ‘extremely  challenging’  answers  are 
grouped together (53%). 

  Most  respondents  (N=93,  72%)  would  implement  digital  labelling  if  it  was 

possible. 

  Most respondents (N=132, 56%) thought any label information presented via IT 
solutions  be  organised  through  a  decentralised  database  operated  by  individual 
manufacturers following standard templates or guidelines. 

1.2. 

1.3 

A targeted stakeholder survey 

The survey targeted users of fertilising products (professional, non-professional), the industry 
(manufacturers,  blenders,  importers,  distribution  intermediaries  and  suppliers,  retailer, 
stockists) as well as conformity assessment bodies and market surveillance authorities. 

The survey questionnaire contained questions targeted at each of the groups related to essential 
information on fertilising product labels and preferences about information removal from the 
physical  label,  the  usage  of  labels,  usage  and  accessibility  of  digital  tools,  preferred  IT 
solutions,  preferences  about  digital  labelling  (e.g.  layout),  industry  labelling  practices  and 
about costs and implementation of digital labelling. The questionnaire was translated into the 
languages of selected countries. In this study all EU countries are included, but the survey was 
translated and focused on eight selected countries: France, Germany, Italy, Lithuania, Poland, 
Romania, Denmark, and Spain.  

The stakeholder survey was open between the 23th of August and the 11th of October, 2021. 
Multiple dissemination channels were used to obtain as many responses as possible. CINT, an 
online insights exchange platform was utilised, which allows for the targeted recruitment of 
participants. Moreover, potential respondents were also targeted through an email campaign, 
with specific regard to industry representatives and state authorities. 

755  responses  were  received,  of  which  752  indicated  their  country  of  residence.  Most 
respondents  are  from  Germany  (141  or  18.8%  of  responses),  followed  by  France  (136  or 
18.1%), Spain (107 or 14.2%), Romania (89 or 11.8%), Lithuania (70 or 9.3%), Poland (68 or 
9%) and Italy (55 or 7.3%). 82 responses were received from other countries. The values are 
summarised in the table below. 

Non-professional users constituted the largest response group (43.6% of responses), followed 
by professional users (33.5%). Representatives of industry (manufacturers, blenders, importers, 
distributors,  suppliers,  retailers  and  stockists)  amounted  to  18.7%  of  the  responses,  while 
conformity assessment bodies and market surveillance authorities made up 4.2% of the survey 
responses. 

70 

 
 
 
Most of the survey respondents (28%) were between 35-44 years old. The age group is followed 
by respondents between 45-54 years old (24.3%), respondents of 25-34 years (23.2%) and 55-
64 years old (14.3%). 5.7% of the respondents were under 24 years old, most of whom were 
between 18-24. At the opposite end of the spectrum, 3.1% of the respondents were aged over 
64 years.  

Analysing  age  by  respondent  groups  reveals  that  respondents  from  conformity  assessment 
bodies and market surveillance authorities, non-professional and professional users were the 
youngest.  42.5%  of  the  respondents  work  in  agriculture  (farming),  20%  are  employed  in 
manufacturing, 13.7% in a gardening business,  7.7% are distributors, importers or retailers, 
and  6.3%  are  blenders. To  a  lesser  extent,  respondents  came  from  other  private  companies 
(2.2%), market surveillance authorities (1.4%), conformity assessment bodies (1.2%) and other 
government  or  public  institutions  (1.2%).  3.8%  of  respondents  indicated  that  they  are  from 
other types of organisations. 

  Key findings 

  When asked to rate the importance of four categories of information that appear 
on the labels: information on content (IC), relevance after purchase (AP), safety 
requirements (S) and agronomic efficiency (AE) in terms of level of importance, 
there  was  not  a  great  deal  of  difference  between  the  categories  in  the  case  of 
professional users and the case of non-professionals. 

  When compared to professional users, the listed information categories are all in 
all  more  important  to  non-professional  users.  More  respondents  considered 
information  about  safety  requirements  as  absolutely  essential  than  any  other 
categories (47.3%). 

  Manufacturers  indicated  that  information  on  content  is  the  least  important 
information category, while 46.2% of the manufacturers, a percentage larger than 
in  case  of  other  information  categories,  thought  that  agronomic  efficiency  is 
absolutely essential. 

  Blenders think that agronomic efficiency is the most important category (38.7% 
said  that  it  is  absolutely  essential,  N=31),  after  safety  requirements  (31.3%), 
information on content (29%) and information relevant after purchase (9.7%). 

  When asked to what extent information from each of the four categories might be 
removed from the physical label and transferred to a digital format (fully, partially, 
none), there was not  a great deal of difference between the categories either. A 
larger  percentage  of  the  professional  users  think  that  information  could  be 
removed from the labels (fully or partially) than compared to the opinions of non-
professional users. 

 

In  case  of  non-professional  users,  safety  requirements  proved  to  be  the  least 
moveable,  followed  by  information  after  purchase  and  information  on  content. 
About a third selected that none of the information should be removed from the 
physical label. Agronomic efficiency came across as most moveable.  

  Manufacturers  would  prefer  to  remove  information  relevant  after  purchase,  as 
would blenders. In contrast to manufacturers and professional users, conformity 
assessment bodies and market surveillance authorities are more against removing 

71 

 
 
information. Overall, non-professional users are more wary of digitalisation than 
professional users. 

  The overwhelming majority of professional users read or use labels of fertilising 
products  quite  frequently,  and  more  than  non-professional  users.  Professional 
users  mostly  (72%,  N=231)  read  labels  before  purchase,  followed  by  after 
purchase  but  before  use  (32%),  and  then  while  using  the  product  (25.5%). 
Professional users said that they read labels in the physical place of manufacture 
or sale. A sizeable group also read labels online (39.8%). (N=297) 86.9% of the 
non-professionals read the label before purchase - mostly at the place of purchase 

  The  overwhelming  majority  of  non-professional  users  purchase  fertilising 
products  in  retail  shops  (89.5%,  N=323),  while  some  also  buy  products  online 
(28.2%), through dealerships and purchasing co-operatives (both 9.9%) as well as 
from  catalogues  (5.6%).  Non-professional  users (N=297) use labels  to  find out 
about the purpose for the product (76.4%), ingredients (62.3%), storage conditions 
(60.3%), product safety (53.5%), quality and efficiency (51.5%) and disposal of 
the package and leftovers (27.6%). 

  The  various  stakeholders  have  sufficient  digital  skills  to  use  the  internet  and 
digital technologies, but there are also some exceptions. Most professional users 
said that they regularly connect to the internet (95.6%, N=227). Similarly, almost 
all non-professional users said that they regularly connect to the internet (97.6%, 
N=296),  just  as  CAS  and  MSA  stakeholders  do  (100%,  N=32).  It  is,  however, 
important to note that the survey was conducted online, possibly increasing the 
number of those who connect to the internet regularly if compared with the general 
population. 

  Most  stakeholders  use  at  least  some  digital  devices  and  similar  popularity  of 
various  devices  was  noted  across  different  stakeholder  groups.  Smartphones 
(77%)  are  used  most  often  by  professional  users  to  connect  to  the  internet, 
followed by laptop (67.3%) and desktop (52.5%) computers and tablets (39.4%). 
The majority of professional users (N=288, 75.8%) also use digital technologies 
to access label information on the products they use. Non-professional users even 
more often than professionals selected smartphones (90.7%) as devices they use 
to  connect  to  the  internet,  followed  by  laptop  computers  (77.9%),  desktop 
computers (54%), and tablets (46.4%). 

  When  asked  which  format  they  prefer  to  access  label  information,  most  of  the 

professional and non-professional users selected physical labels. 

  Websites and 2D codes are the most popular digital technologies among various 
stakeholder groups. Professional users were asked to select from a list of digital 
technologies on which they would choose to access information about fertilising 
products. Websites at 42.9% and 2D codes (e.g. QR codes, Datamatrix codes) at 
40.7% were most often selected. Non-professional users also most often selected 
websites  and  2D  codes.  However,  the  difference  between  the  two  options  was 
more evident for the non-professional group, where 64.6% selected websites and 
37.7% selected 2D  codes, 33.7% mobile applications  (see figure below, on the 
right). 

72 

 
 
  When asked where the digitalised information should be presented, most of the 
stakeholders  preferred  manufacturers’  platforms.  All  user  groups  were  agreed 
overall that that there should be a standardised template for all manufacturers 

  With regards to labelling practices, manufacturers indicated that it is somewhat 
harder  to  manage  the  frequently  changing  information  categories  on  fertilising 
labels  than  the  amount  of  labelling  information  in  itself.  39.4%  of  the 
manufacturers provide information about its products in a digital format, instead 
of or in addition to the physical label (N=69). Multi-language labels are used by 
73% or 19 of the respondents (N=26). 

  Manufacturers are divided on whether digitalisation in general would save them 
money. 48.4% think that it would provide financial savings (N=49). When asked 
about  the  costs  involved,  manufacturers  indicated  that  websites  and  QR  codes 
would be the least expensive solutions to implement (17 and 22% responded that 
it  would  be  expensive).  Thus,  the  cheapest  options  also  coincide  with  the 
preferences  of  all  kinds  of  stakeholders.  Other  industry  stakeholders  rank  IT 
solutions similarly. 

1.3. 

1.4 

The survey experiment 

The survey experiment implemented a three-group, one-way design that explored the effects 
of  labelling  changes  on  key  behaviours  among  professional  and  non-professional  users  of 
fertilising products. 

The exercise sought to understand the behaviours users actually exhibit when shown digitalised 
labels, instead of asking participants what they think about digitalisation. Furthermore, it also 
aimed to test how understanding of the labels is  affected by digitalisation. According to the 
design of the survey experiment, respondents were shown labels of fertilising products with 
varying degrees of information. Both professional and non-professional users received three 
different kinds of fertilising labels, one with all the information to be displayed on physical 
labels, a moderately simplified label and another, with radically simplified information. Labels 
were designed in consultation with DG GROW. 

The  survey  was  conducted  on Alchemer  and  online  panels  via  CINT  were  used  to  contact 
respondents.  The  survey  experiment  targeted  four  countries  (France,  Poland,  Romania  and 
Spain)  and  gathered  1200  responses  (800  professional  and  400  non-professional  equally 
distributed among the four countries). The questionnaires were translated into four languages. 

  Key findings 

  The  survey  experiment  shows  that  professional  users  are  mostly  unaffected  by 
changes  in  the  amount  of  information  on  the  physical  label  when  it  comes  to 
product  application  and  storage.  Non-professional  users  are  more  sensitive  to 
label simplification than their professional counterparts. 

  With  regards  to  factors  influencing  understanding  of  labels,  the  ease  of 
interpreting labels (self-reported) is significantly positively related to the age of 
professional  and  non-professional  users,  as  well  as  to  experience  of  using  the 
shown fertilising product. 

73 

 
 
  Less  information  on  labels  did  not  lead  to  a  significant  change  in  how  easily 
information  was  interpreted  on  the  label  in  question  by  either  of  the  two  user 
groups (see tables below).  

  Statistical testing  indicates that age has a significant impact on answering product 
application and storage questions correctly in case of both professional and non-
professional users. 

1.4. 

1.5 

Focus groups 

The objective of the focus groups was to collect more in-depth ideas on how fertilising product 
users think about labelling, information on labels, product use and digitalisation. It followed a 
semi-structured choreography with main question points to touch on. During the focus group, 
slides with fertilising product label information categories and subcategories were shown, to 
ensure a constant point of reference for participants. Similarly, the potential IT solutions were 
also displayed. 

Eight focus groups were organised with professional and non-professional users, four with each 
stakeholder group, from France, Poland, Romania and Spain In most cases discussions were 
conducted in respondents’ native languages and were carried out online. On average, discussion 
lasted  45  minutes.  Recordings  were  typed  up,  translated  into  English  and  coded  on  a 
predetermined sheet. 

Participants  of  professional  focus  groups  were  usually  farmers,  who  work  on  small  farms, 
growing  vegetables  both  indoor  and  outdoor.  A  smaller  group  of  participants  worked  as 
agronomic engineers at larger companies, working sizable lands or at companies developing 
hybrid plants. Professional users indicated that they use a wide variety of fertilising products, 
both in liquid, solid and powder form. Most often mentioned PFCs were mineral and organic 
fertilising products.  

Non-professional users were typically growing vegetables, fruits and herbs in their own garden 
or  were  owners  of  indoor  plants  and  flowers.  Some  users  also  apply  fertilising  products  to 
evergreen plants and trees. Generally, they reported using organic fertilising products or liquid, 
inorganic fertilising products. Often, non-professionals reported using one fertilising product 
for all their plants.  

  Key findings 

  Most focus group participants were knowledgeable only about the most important 
pieces of information such as nutrient values, or easy to grasp information such 
as storage conditions or target plants. They did not have strong views or opinions 
about information categories or subcategories. 

  Agro-economic  efficiency-related  information  was  considered  more  important 
than other types of informant by manufacturers and professional users – especially 
nutrient content. The view tended to be that after purchase information was not 
that  important  –  everybody  knew  what  to  do.  Non-professionals  found  AE 
information too technical (except in the case of avid hobbyists).     

  Most users thought  that  safety requirements had  to  be retained on the physical 
label, although professional users thought this less than non-professionals. Some 
professional users asked if it was really necessary - most of it was common sense. 
Manufacturers thought it important to keep the information on the label –in case 

74 

 
 
something happened to the user one could also go to the QR code to find out more 
details on what might be wrong and what to do. 

  Non-professional  users thought  after purchase information  was more important 
than professional users did, although professional users are quite divided on the 
matter. Professionals tend to know how to use the products, or have advisors to 
help them. Non-professionals came across as thinking this is more important than 
it appears from the quantitative data collection exercise. 

  Professionals  were  more  interested  in  information  on  content  than  non-
professionals, although less so than in agro-economic efficiency. They found the 
list of ingredients, production and expiry date to be useful. It is also important for 
organic farmers to be able to check it. Non-professionals find this less important.                

  Non-professionals tend to use labels before purchase and before use, but might 
find the information on the label hard to interpret. Professionals also look at labels 
but from a different perspective – they have done research beforehand and might 
just want to confirm that the information is correct. 

  Generally  participants  welcome  the  transition  to  digitalisation.  It  is  seen  as 
beneficial and a natural transition, although concerns were mentioned about the 
digitally derived.   

1.5. 

1.6 

Usability testing 

The unmoderated usability testing exercise tested the popularity and potential use of various 
digital technologies that could be implemented on the fertilising product labels. Participants 
were shown various labels with different IT solutions and asked about the IT solutions used to 
access the digital label (recognition of IT solutions, usage, preferences). The usability testing 
also gathered qualitative data on respondents’ attitudes on the shortlisted IT solutions. 

47 tests with professional and non-professional users of fertilising products were carried out 
(29  were  professional  and  18  non-professional)  with  the  help  of  Loop11  usability  testing 
platform and a TestingTime panel. Participants were mostly from Germany (25) and from other 
European countries. Moreover, participants were mostly from large cities or nearby suburbs. 

Table 9.2: Participants by settlement type 

Country 

Respondents 

Large city 

28 

Suburb  near  a  large 
city 

9 

Small city or town 

10 

Rural area 

1 

  Key findings: 

75 

 
 
 
  Usability testing was conducted on QR Codes, Datamatrix Codes, 1D barcodes as 
well as URLs. Respondents were shown five images of fertilising product labels, 
coupled  with  the  five  analysed  IT  solutions.  Before  that,  participants  were 
introduced to the different digital technologies shown on the labels and how to 
use them. 

  Of the 48 tested individuals, 33 scanned a QR and 26 accessed a URL, making 
these the most used options. When asked to rank IT solutions, the first two options 
were also QR codes and URL links. 

  Thus, the most easily usable and preferred technologies are QR codes and URL 
links, which also have the advantage of being complementary to each other, that 
is, when QR codes are not readable or the user cannot scan it, URL link provide a 
good second method. 

 

It  was  explained  that  accessing  information  is  the  easiest  with  QR  codes,  
especially because most smartphones already have built-in tools for this purpose, 
thus,  it  does  not  require  downloading  any  other  software.  Furthermore, 
respondents  frequently  mentioned  that  they  are  already  familiar  with  the 
technology and they frequently use it. According to respondents’ accounts, URLs 
have a complementary advantage of being able to search for them online in case 
someone cannot access QR codes. On the other hand, users also voiced that typing 
in URLs takes too much time and effort.  

  Most users used smartphones to access digital information via the label (42.7%). 
Laptops and desktop PCs were also popular. Ideal preferences reflect devices used 
to  read  digital  labels:  smartphones  (87.2%),  laptops  (53.2%)  were  the  most 
preferred options. 

1.6. 

1.7 

Ad-hoc expert group meeting on options for digitalisation of labels 

An on-line meeting (workshop) of the Commission Expert Group on Fertilising Products took 
place  on  the  15th  of  March  2022. At  the  workshop,  the  following  specific  questions  were 
addressed:  

  Feedback on the proposed ‘principles of digitalisation’ 

  Categorisation  of  labelling  requirements  (and  reallocation  of  information  between 

categories) 

 

Identification of frequently changing labelling information 

  The distinction between non-professional and professional users 

  Technical aspects of the policy options proposed 

  Feedback on proposed options – and the preferred option 

Very  useful  comments  were  made  by  range  of  stakeholders  during  the  workshop 
regarding  the  topics  discussed  and  several  organisations  provided  additional  valuable 
written feedback subsequently that was used to help frame the options and questions for 
the survey (2.8) and also provided guidance on how to assess the options. 

76 

 
 
 
1.7. 

1.8 
options  

Survey: focus on costs and benefits related to various digitalisation 

Following  the  ad-hoc  Expert  Group  meeting,  an  online  survey  to  collect  data  on  costs  and 
benefits  related  to  various  options  for  digitalisation  was  conducted.    The  survey  aimed  to 
consider costs and benefits of various alternative options for digital labelling as compared to 
the labelling under the FPR as it currently stands.  

The  target  audience  of  this  survey  included  economic  operators  (manufacturers,  authorised 
representatives, importers, distributors), users (professional and non-professional) and readers 
of labels of fertilising products (e.g. conformity assessment or market surveillance bodies), as 
well as other interested parties such as NGOs. 

The  survey  was  open  from  the  11th  to  the  22nd  of April  2022  and  had  93  valid  responses 
distributed among stakeholder groups as set out in the chart below.  

Figure 9.1: What type of organisation do you represent? 

Economic operator (e g  manufacturers, authorised
representatives, importers, distributors)

Reader of labels (e g  market surveillance authorities
and conformity assessment bodies, national or
provincial governments, etc )

Professional user (e g  farmer, horticulture)

35,5

19,4

18,3

Other (e g  NGO)

15,1

Non-professional user  (e g  hobby gardener)

11,8

  Key findings 

  The  results  in  terms  of  obtaining  data  on  costs  incurred  by  stakeholders  with 
digitalisation were disappointed and could not be used without strong caveats. 

  Some  56.3%  of  respondents  (manufacturers,  N=32)  indicated  that  they  already 
provide some labelling information digitally. Overall there was strong support for 
the proposed 10 principles of good practice in digitalisation of labels (N=84). 

  Feedback regarding the value of current FPR labelling (physical) did not suggest 
that there was a high contribution from the information on the labels to economic, 
social or environmental impacts. Some 56% found it readable or highly readable, 
58%  understandable  or  highly  understandable;  and  49%  that  it  communicated 
information well or very well to target customers. 

77 

 
 
 
 
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  When comparing the effects of labels under the different options on economic, 
environmental and social  impacts,  the general  response was that the higher the 
level of digitalisation (higher options), the greater the positive impacts. 

  There  was  no  clear  result  in  terms  of  ranking  the  options  by  PFC  for  all 
stakeholders  combined,  but  manufacturers  showed  a  stronger  preference  for 
higher levels of digitalisation – Option 6 was preferred. 95.7% of manufacturers 
indicated  that  that  they  were  either  likely  or  very  likely  to  implement  digital 
labelling if it was allowed. 

78 

 
 
 
 
 
 
 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

1.  PRACTICAL IMPLICATIONS OF THE INITIATIVE 

How are stakeholders affected by the preferred policy option (PO2a + PO3): 

Stakeholders  

Economic 
operators 
(manufacturers, 
importers, 
distributors) 

Users: 

Professional 

The  preferred  policy  package  provides  scope  for  economic  operators  to  avoid 
costs related to labelling, while providing the choice for those who do not want 
to digitalise to provide all information on the physical label.  

By reducing the frequency of disposing of and redesigning physical labels, there 
could be some ongoing costs savings for enterprises as digital labels are easier 
and less costly to update than physical labels. This relates to relabelling due to 
the (in)stability of product information over time (e.g. for organic fertilisers, the 
content of the various forms  of nutrients  may vary  from  one batch to  another, 
depending on the quality of the input materials used) changes to the product (e.g. 
different  ingredients),  changes  in  distribution  of  the  product  (i.e.  additional 
countries) or due to regulatory changes. Enterprises could also incur fewer costs 
in  purchasing  and  maintaining  the  machinery  or  equipment  required  to  make 
physical labels. 

PO2a further incentivises economic operators to improve the free movement of 
fertilising  products  across  the  EU-27.  By  reducing  the  amount  of  information 
required  on  the  physical  label  there  should  be  more  space  for  information  in 
different languages, which will make it easier for them to remain and to grow in 
the  internal  market.  Such  improved  free  movement  is  envisaged  to  a  greater 
extent  under  PO3,  where  all  label  information  can  be  provided  digitally  for 
certain types of products. 

Setting a legal framework (also in terms of the ‘principles for digital labelling’) 
for digital labelling will help in setting a level playing field and create certainty 
for  economic  operators,  while  at  the  same  time  avoiding  divergent  non-
harmonised  digital  labelling  schemes  (e.g.  at  Member  State  level  or  at  the 
initiative of industry).  

For professional  users, the principles  guiding the design of PO2a was that  the 
information  that  could  be  digitalised  often  reached  professional  users  through 
different  means  (for  example,  not  necessarily  through  the  physical  label,  but 
rather via technical advisory services) and so it could be readily be moved from 
the physical label to the digital label.  

Under  PO2a,  safety  related  information  is  retained  on  the  physical  label. 
Therefore  there  should  not  be  a  negative  impact  on  non-professional  users  in 
terms of impacts linked to health and safety. 

Industrial  users  of  EU  fertilising  products  (i.e.  blenders)  could  further  be 
impacted positively (particularly by PO3), as digital product information will be 
easier to collate and manage.  

It should be noted that all physical label information may be moved online under 
PO3, including safety information.  Particularly relevant  for professional  users, 

79 

 
 
are those products sold in bulk, without packages. However, if digitalisation of 
label information is implemented, it will require compliance with the ‘principles 
for  digital  labelling’,  which  set  out  to  protect  end-users  and  to  ensure  the 
accessibility, availability and quality of digital information. 

Further, setting up a legal framework for digital labelling (in terms of the ‘digital 
labelling principles’) would benefit all users, as the information online will be 
easy  to  navigate  and  searchable  (i.e.  useful  for  users  looking  for  specific 
information). 

Under  PO2a  the  information  moved  to  a  digital  label  is  less  relevant  for  non-
professional users. This includes highly technical information, which is often not 
understood by non-professional users. Under PO2a, safety related information is 
retained on the physical label. Therefore, there should not be a negative impact 
on non-professional users. For those without access to digital information of EU 
fertilising  products,  the  ‘principles  for  digital  labelling’  would  mean  that 
alternative ways of providing information would be necessary. 

Impacts of PO3 will not have any effects on non-professional users. 

Further, setting up a legal framework for digital labelling (in terms of the ‘digital 
labelling principles’) would benefit all users, as the information online will be 
easy  to  navigate  and  searchable  (i.e.  useful  for  users  looking  for  specific 
information).  

In  terms  of  direct  impacts  of  PO2a  and  PO3  on  public  authorities,  despite 
positive aspects related to the ease of managing and compiling online data, public 
authorities could require some investment in equipment and training to facilitate 
access to digital labels, although it should be noted that 74.2% of Member State 
Authorities  and  Conformity  Assessment  Bodies  replying  to  the  stakeholder 
survey152  indicated  they  currently  already  use  digital  tools  to  access  label 
information of products.  
Also relevant for public authorities is that setting up a legal framework for digital 
labelling (in terms of the ‘digital labelling principles’) would be beneficial, as the 
information online will be easy to navigate and searchable (i.e. useful for those 
looking for specific information). 

Users: Non-
professional 

Public authorities 
(Member State 
Authorities, 
Conformity 
Assessment 
bodies, and 
Market 
Surveillance 
Authorities)  

152 Total number of responses = 31. 

80 

 
 
 
 
 
                                                 
2.  SUMMARY OF COSTS AND BENEFITS 

81 

 
 
I. Overview of Benefits (total for all provisions) – Preferred Option  

Description 

Amount 

Comments 

Direct benefits 

Reduced 
administrative 
costs 
businesses 
(producers, 
distributors, etc.)  

for 

Maximum  estimated 
annual 
costs 
savings  under  PO2a 
for  SMEs 
is  €517, 
and  €4,583  for  large 
enterprises. 

Maximum  estimated 
annual 
costs 
savings  under  PO3 
for SMEs is € and  

for 

€ 
enterprises. 

large 

Non-monetary 
benefit 

Users 
enjoying 
greater ease of use 
and 
increased 
awareness  of  key 
information 
(e.g. 
ingredients,  safety 
information). 

Indirect benefits 

Given  the  voluntary  nature  of  the  preferred  option,  no  costs  would  be  imposed  on  businesses. 
Businesses  would  only  provide  digital  labelling  if  they  perceived  the  potential  to  enjoy  reduced 
costs  (or  if  they  perceived  sufficient  other  business  benefits  to  justify  any  cost  increase).  The 
figures provided show the maximum potential benefits. 

The figures are based on the baseline costs (except cost of redesigning physical labels, which are 
based  on  best  estimate  based  on  stakeholder  interviews)  are  mid-point  estimates  based  on  the 
range of cost estimates provided by enterprises responding to the stakeholder survey (total number 
for respondents 93).  

Cost savings would arise through reducing the frequency of disposing of and redesigning physical 
labels. There would also be economies of scale in that more languages could fit on physical labels. 

All types of firms (SMEs and large enterprises) would be able to benefit from digitalisation. However, 
large firms may derive more benefits in terms of economies of scale as they can more easily make 
the necessary one-off, upfront investments in digitalisation. 

Previous  research  has  found  that  digitalisation  of  labels  can  improve  hazard  communication  for 
consumers (e.g. chemicals used in inorganic fertilisers, storage instructions if any dangers) and 
workers by solving the problem of consumers being faced with overloaded and unattractive labels 
and text being too small  to read. Non-professional users  can also be empowered through better 
access to more relevant and comprehensible information, enabling more informed decision-making 
on the purchase and use of fertiliser products. 

Professional  users  may  also  benefit  as  they  would  get  access  to  a  wider  range  of  technical 
information digitally than it would be possible to fit onto a physical label under the FPR’s labelling 
requirements.  

82 

 
 
 
 
I. Overview of Benefits (total for all provisions) – Preferred Option  

Description 

Amount 

Comments 

Sectoral 
competitiveness 

Not 
possible 
quantify  given 
available data. 

to 
the 

Digital labelling and simplification of physical labels could help enterprises by allowing more space 
for essential information to be given more prominence on the label and for multiple languages on 
physical labels. This would allow more cost-effective labelling within the Single Market given the 
increased costs of producing multiple labels for different export markets.  

May also facilitate product distribution across the EU and beyond by allowing multilingual labels to 
be moved digitally. 

Reduced  risks  to 
health  and  safety 
of users 

possible 
Not 
quantify  given 
available data. 

to 
the 

Evidence from the consultations highlights that increased awareness about product information on 
labels and more informed decision-making is likely to reduce risks to health and safety. The number 
of survey respondents anticipating such benefits increased in line with increased digital labelling: 
from 19.5% in relation to the policy option 2a to 38.3% in relation to policy option 3. 

Administrative cost savings related to the ‘one in, one out’ approach*153 

153 see Tool #59 cost estimates and the one-in, one-out approach.  

83 

 
 
 
                                                 
annual 

Reduced 
administrative 
costs 
businesses 
(producers, 
distributors, etc.)  

for 

net 
Mid-range 
recurring 
benefits 
accruing  to  all  EU27 
enterprise 
is 
estimated at: 

The  benefits  would  stem  from  the  digitalisation  of  some  information  compared  with  the  current 
physical-only labelling requirements.  

Given  the  voluntary  nature  of  the  preferred  option,  no  costs  would  be  imposed  on  businesses. 
Businesses  would  only  provide  digital  labelling  if  they  perceived  the  potential  to  enjoy  reduced 
costs (or if they perceived sufficient other business benefits to justify any cost increase). 

 -€308,550 
PO2a 
1,069,500 
PO3. 

and; 

under 
€ 
under 

(For  both  options 
one  off  costs  are 
estimated 
at 
€300,844 and annual 
ongoing  costs  are 
estimated 
at 
€125,280). 

The  figures  provided  show  the  maximum  potential  benefits,  assuming  that  all  companies  will 
implement the voluntary digital labels of a total of 3595 enterprises , assuming the following: 

It is assumed that 44% of Large Enterprises already provide some form of digital labelling, all of 
which export. It is assumed that they export to other Member states and comply with the FPR. Such 
enterprises would not incur additional costs (as they already digitalise) but would enjoy savings 
from any reductions in physical labelling requirements. 

The  remaining  56%  of  Large  Enterprises  do  not  yet  provide  any  digital  labelling.  However,  it  is 
assumed  that  they  export  to  other  Member  States  and  would  therefore  choose  to  adopt  digital 
labelling  in  compliance  with  the  FPR.  Such  enterprises  would  incur  additional  costs  due  to 
digitalisation but would also enjoy savings from any reductions in physical labelling requirements. 

Of the 44% of SMEs that provide digital labelling, it is assumed that 30% export within the EU (equal 
to 13% of all SMEs). These firms would not incur additional costs but would enjoy savings from any 
reductions in physical labelling requirements. 

Of the 44% of SMEs that provide digital labelling, it is assumed that 70% do not export within the 
EU (equal to 31% of all SMEs). These firms would not incur additional costs and would not enjoy 
savings, as they would continue to comply with any national rules on labelling. 

Of the 56% of SMEs that do not provide digital labelling, it is assumed that 30% export within the 
EU (equal to 17% of all SMEs). These firms are assumed to adopt digital labelling for the first time. 
They  would  therefore  incur  additional  costs  but  would  enjoy  savings  from  any  reductions  in 
physical labelling requirements. 

Of the 56% of SMEs that do not provide digital labelling, it is assumed that 70% export within the 
EU (equal to 17% of all SMEs). These firms would not incur additional costs and would not enjoy 
savings, as they would continue to comply with any national rules on labelling. 

Cost savings would arise through reducing the frequency of disposing of and redesigning physical 
labels. There would also be economies of scale in that more languages could fit on physical labels. 

84 

 
 
 
  
I. Overview of Benefits (total for all provisions) – Preferred Option  

Description 

Amount 

Comments 

All types of firms (SMEs and large enterprises) would be able to benefit from digitalisation. However, 
large firms may derive more benefits in terms of economies of scale as they can more easily make 
the necessary one-off, upfront investments in digitalisation. 

Both SMEs and large firms would benefit. Arguably, medium and large firms proportionately would 
benefit more from digital labelling  as they are more likely to distribute to  5-10  Member States or 
more so would have cost savings relating to transferring multilingual information to a digital format. 

85 

 
 
 
II. Overview of costs – Preferred option 

Citizens/Consumers 

Businesses 

Administrations 

One-off  Recurrent 

One-off 

Recurrent  One-off  Recurrent 

Direct 
adjustment 
costs 

Not 
relevant 

Direct 
administrative 
costs 

Not 
relevant 

Direct 
regulatory fees 
and charges 

Not 
relevant 

Direct 
enforcement 
costs 

Not 
relevant 

Action 
(a)   

Not relevant  Not relevant  Not relevant 

Not relevant  *0  

*-€0   

Not relevant  Not relevant  Not relevant 

Not 
relevant 

Not 
relevant 

Not 
relevant 

Not 
relevant 

Not 
relevant 

Not 
relevant 

Not relevant  Not relevant  Not relevant 

Possibly 
purchase  of 
equipment- 
not 
quantifiable 

Not 
relevant 

Not 
relevant 

Indirect costs  Not 

relevant 

Not relevant 

Not relevant  Not relevant  Not 

relevant 

Costs related to the ‘one in, one out’ approach 

Total   

Direct 
adjustment 
costs  

Indirect 
adjustment 
costs 

Not 
relevant 

Not 
relevant 

Administrative 
costs 
(for 
offsetting) 

Not 
relevant 

Not relevant  Not relevant  Not relevant 

Not relevant  Not relevant  Not relevant 

Note relevant  €5.74M  

€3.58M154 

*NB: Given the limited evidence base for the costs, a full extrapolation of costs to EU level 
is problematic and risks providing a false picture. Nonetheless, a broad indication can be 
offered. 
Further, given the voluntary nature of the preferred option, no costs would be imposed on 
businesses. Businesses would only incur direct adjustment costs related to digital labelling 
if they perceived the potential to enjoy reduced costs (or if they perceived sufficient other 
business benefits to justify any cost increase). 

The  estimates  for  direct  administrative  costs  show  the  maximum  potential  costs  for 
enterprises  assuming  that  maximum  number  of  exporting  companies  that  might  provide 
digital labelling for the first time is equal to 610. Based on the following assumptions155: 

  That the fertilising products sector features 3595 enterprises.  

154 There are no administrative costs for offsetting as the costs will be offset by benefits. Although the one-off 
cost is €5.74M, the net recurring annual savings is €9.36M. 
155 For a full breakdown of assumptions, also on exporting enterprises please refer to section 5.3.1.4 of the 
Digital labelling study 

86 

 
 
 
 
 
 
 
 
 
 
                                                 
  This mid-range figure provides an estimate of net benefits based on the assumption 

that  all  enterprises  that  export  would  gain  from  savings  associated  with  reduced 
physical labelling requirements (because they already provide digital labelling or would 
newly introduce it). 

In practice, the actual costs would most likely be less than these maximum costs, as a certain 
proportion of firms would choose not to provide digital labelling. Indeed, given its voluntary 
nature, enterprises would provide digital labelling if they anticipated that the costs of such 
provision would be exceeded by the benefits. 

87 

 
 
 
3.  RELEVANT SUSTAINABLE DEVELOPMENT GOALS 

III. Overview of relevant Sustainable Development Goals – Preferred Option(s) 
Relevant SDG 

Expected progress towards the Goal 

Comments 

SDG  #3  Good  health 
and well-being 

SDG  #6  Clean  water 
and sanitation 

improve 

labelling  could 

Digital 
the 
communication  of  fertilising  product 
information  (including  use  instructions), 
by providing the information in a clearer 
manner.  

improve 

labelling  could 

Digital 
the 
communication  of  fertilising  product 
information  (including  use  instructions), 
by providing the information in a clearer 
manner.  Over  use  of  fertilisers  could 
result in eutrophication of water bodies. 

Specific  Target  3.9 
‘By  2030, 
substantially  reduce  the  number  of 
deaths  and  illnesses  from  hazardous 
chemicals  and  air,  water  and  soil 
pollution and contamination’ 

Specific  Target  6.3 
‘By  2030, 
improve  water  quality  by  reducing 
pollution,  eliminating  dumping  and 
minimising 
release  of  hazardous 
chemicals  and  materials,  halving  the 
proportion  of  untreated  wastewater 
and substantially increasing recycling 
and safe reuse globally’ 

#9 
SDG 
innovation 
infrastructure 

Industry, 
and 

Setting  up  a  framework  for  digital 
labelling and improving the management 
of otherwise overloaded labels will allow 
the  EU  fertilising  products  industry  to 
transition  to  increased  digital  practises 
and  future  proof  the  Fertilising  products 
regulation. 

increased 

‘By  2030, 
Specific  Target  9.4 
upgrade  infrastructure  and  retrofit 
industries  to  make  them  sustainable, 
resource-use 
with 
efficiency  and  greater  adoption  of 
clean  and  environmentally  sound 
technologies and industrial processes, 
with  all  countries  taking  action  in 
accordance  with 
respective 
capabilities’ 

their 

#12 

SDG 
sustainable 
consumption 
production patterns 

Ensure 

and 

improved 

Information  on  EU  fertilising  products 
will  be 
(through  clearer 
communication)  so  users  of  fertilising 
products can not only protect themselves 
by  accurate  use  of  a  product,  but  also 
make informed choices.  

Specific  Target  12.4  ‘By  2020, 
achieve  the  environmentally  sound 
management  of  chemicals  and  all 
wastes throughout their life cycle, in 
accordance with agreed international 
frameworks, and significantly reduce 
their release to  air, water and soil  in 
their  adverse 
order 
impacts  on  human  health  and  the 
environment’ 

to  minimise 

88 

 
 
 
 
ANNEX 4: ANALYTICAL METHODS 

This Annex provides a description of the approach to the prospective analysis whose results are 
described in the main body of the Impact Assessment Staff Working Document and the digital 
labelling study. The aim of the prospective analysis was to (1) assess the problems identified 
and its drivers, provide the reasons for the EU action, set general and specific objectives of the 
new initiative, develop  policy options tackling these objectives,  assess the developed policy 
options in terms of their economic, social, and environmental impacts and, finally, compare the 
policy options under effectiveness, efficiency, and coherence criteria. 

1.  OVERVIEW  

The prospective analysis was carried out between January 2021 and May 2022. The work was 
structured  around  seven  main  tasks,  each  of  them  containing  various  activities.  This  part 
summarises the work under the key evidence-gathering and analysis activities. 

Problem Tree Definition 

The  definition  of  the  problem  and  its  problem  tree  were  identified  and  refined  based  on 
information collected at the Inception Phase of the study and discussions with the Commission. 
The final version of the problem tree containing the key drivers behind the problems identified 
and the  consequences  of these problems  to  the environment,  consumers,  and the industry is 
presented in Chapter 2. 

Subsidiarity analysis 

The  problems  identified  as  part  of  the  problem  tree  definition  were  carefully  assessed  with 
respect to subsidiarity, more specifically, the necessity and added value of EU action.  

Policy Objectives Identification 

Following the definition of the problems, and the necessity and added value of EU action, the 
objectives of the policy action were defined, including the general objectives covered in this 
study, namely: the aim of Regulation 2019/1009 on fertilising products (the Fertilising Products 
Regulation – FPR) is to: 

1.  Create a level playing field for all fertilising products at EU level, thereby increasing the 
industry's opportunities to have access to the Internal Market while maintaining the national 
regulations in place for products limited to national markets, hence avoiding any market 
disruption. 

2.  Increase  the  level  of  protection  of  health  and  environmental  protection  by  limiting  the 

presence of contaminants in fertilising materials and additives throughout the EU. 

The specific objectives of this study were defined as:  

  SO1: to provide for cost savings for industry through voluntary digitalisation of labels. 

  SO2: to communicate more efficiently the information relevant to a label reader or user by 

use of digital labels for fertilising products.  

  SO3:  to  set  up  a  future  proof  regulatory  framework  allowing  the  use  of  digital  tools  to 

communicate product information 

89 

 
 
Definition of the policy options 

The definition of the policy options started with defining the baseline policy option based on a 
projection of the status quo. The definition of the baseline scenario involved understanding, 
qualifying, quantifying, and monetising (to the extent possible) the key elements of the current 
situation  concerning  the  critical  developments  in  the  EU  population  that  uses  fertilising 
products (professional and non-professional), technological uptake of enterprises and the size 
of the fertilising products industry in the EU. Subsequently, the data collected combined with 
the results of the problem definition and the opinions provided by stakeholders in the course of 
targeted stakeholder consultations contributed to defining and refining the six policy options 
developed  to  tackle  these  objectives.  Essentially  the  options  envisaged  increasing  levels  of 
digitalisation of labels, involving different mixes of categories of information as defined in the 
study. 

Assessment of the policy options 

In line with the Better Regulation Toolbox, the first step in the assessment of impacts was the 
identification of all relevant impacts under the different policy options. The identification of 
the  impacts  was  based  on  data  and  information  collected  during  the  previous  tasks  (i.e. 
interviews, behavioural experiment, surveys, analysis of OPC responses, workshops and focus 
groups).  The  research  collected  qualitative  information  and  quantitative  data  on  social, 
economic and environmental impacts related to the identified policy options. 

Socio-economic  and  environmental  impacts  identified  were  categorized  according  to  the 
following categories in the BRG: 

Impacts 

Economic 
(the conduct 
of business) 

Social 

Sectoral competitiveness ( #21) 
Research and Innovation ( #22) 
SMEs (#23) 
Competition (#24) 
Internal market (#25) 
Trade and investment flows (#27) 
Technological development & digital economy ( #28) 
Employment,  working  conditions,  income  distribution,  social  protection 
and inclusion ( #30) 
Health (#32) 
Consumers and households (#33) 

Environment  Environmental  (#36)  –  includes:  climate  change;  land  use;  quality  of 
natural  resources;  efficient  use  of  resources;  animal  welfare;  reduced 
environmental  risks;  sustainable  production  and  consumption;  and  waste 
production, generation and recycling  

The  impacts  that  were  taken  into  account  for  this  analysis  were  considered  to  be  the  most 
relevant  and  the  ones  for  which  desk  research,  consulted  stakeholders,  the  surveys  and 
workshops were able to provide insights. A dedicated survey targeting public authorities, users 
and user organisations, consumer organisations and industry representatives (associations and 
businesses)  presented  the  individual  policy  options  and  asked  participants  to  provide  direct 
feedback. The opinions of stakeholders were triangulated with other data sources used in the 
study.  The  quantitative  feedback  was  disappointing  making  it  difficult  to  model  impacts  in 

90 

 
 
 
 
quantitative/  monetary  terms.  Quantitative  data  were  not  sufficient  to  provide  meaningful 
modelling of differences between options. 

Comparison of the policy options 

After assessing the identified socio-economic and environmental impacts of each policy option, 
policy  options  were  compared  under  a  range  of  criteria  and  then  assessed  in  terms  of 
effectiveness and efficiency, and coherence criteria. 

In terms of efficiency, the analysis consisted of comparing the costs involved in digitalising 
labels with the potential benefits of digitalising as identified in this study.  

In terms of effectiveness, the extent to which the options would  meet stakeholder needs and 
could actually be implemented and the risks involved in implementation were assessed.    

With  regards  to  coherence,  options  were  considered  in  terms  of  the  extent  to  which  they 
promoted digitalisation in the context of ongoing digitalisation initiatives.  

Following the comparison of the options, the preferred policy option was selected, namely – 
Policy Option 2 - Measure 2: Certain information may be provided digitally (without distinction 
between professional and non-professional users) plus Measure 6: all information is provided 
digitally for certain categories of products. 

2.  LIMITATIONS ENCOUNTERED AND MITIGATION MEASURES 

Limited availability of updated, EU-level, comparable quantitative data 

The  ‘fertilising  products  ‘industry’  as  identified  in  the  FPR  does  not  exist  statistically  nor 
organisationally. No industry level data are collected that correspond to the scope of the FPR, 
nor are there indications as to which shares of production fall under EU or national regulations, 
how much is exported, employment, etc.       

In addition, whilst during the targeted stakeholder consultation, businesses identified a range of 
specific  benefits  of  transferring  information  from  physical  to  digital  labels,  these  potential 
benefits could not be estimated quantitatively due to the wide range of variables affecting labels 
(e.g. size of the label,  type and size of packaging or bags or bottles, number of ingredients, 
number of changes in ingredients constituting thousands of recipes, ways in which products are 
bagged  and  labelled  by  different  enterprises,  number  of  languages  on  packaging  and  space 
required  for the languages/  the labels,  warehouse storage space required for packaging  with 
labels,  etc.).  The  consulted  industry  stakeholders  mentioned  that  they  do  not  have  this 
information available and even if it was decided to set a work group up to collect it, the timeline 
to collect it at company level was too short. 

Similarly, although consulted public authority stakeholders provided input concerning the cost-
benefit ratio for national authorities for each policy option, during the course of the study, no 
concrete quantifiable data was found concerning, for example, additional FTEs needed from 
public authorities under each policy option to perform enforcement and monitoring activities. 
It  is  difficult  to  estimate  the  costs  each  policy  option  would  include  to  public  authorities, 
especially considering the current lack of clarity on the digital infrastructure that would be used 
to store the information on digital labels156.  

156 Possible options would include EU centralised database of e-labels held by EU wide public authority/provider; 
EU centralised database of e-labels held by third-party provider; Independent providers of e-label services (EU or 
national); Manufacturers' websites with e-labels of own products. 

91 

 
 
                                                 
The analysis of impacts on users focused mainly on assessing the impact on safety (i.e. safe use 
of  products),  label  readability  and  relevance  of  information  on  the  label  to  different 
stakeholders.  Some  attention  was  paid  to  issues  surrounding  digital  skills  and  access  to  the 
internet.  The  study  gathered  valuable  qualitative  input  from  the  targeted  stakeholder 
consultation.  However,  the  perception  on  these  issues  from  stakeholders  representing  non-
professional users (consumers) (i.e. consumer organisations) is not complete due to the lack of 
responses from such stakeholders to surveys and requests for interviews.  

Likewise,  the  assessment  of  the  environmental  impacts  also  was  essentially  qualitative  and 
focused on the impact of disposal of wasted label sand packaging on the environment. There 
was very little appreciation among stakeholders of the links between labelling information and 
wider environmental concerns and policies.  

In conclusion, the limitations on quantitative data constrained the strength of the argument on 
the scale of some identified problems and implications of future policy options. In some cases, 
estimations were corroborated by existing evidence underpinning the key assumptions through 
alternative  data  (i.e.  quantitative  findings  from  the  Evaluation  of  the  Detergents  Regulation 
regarding the operational costs related to the providing product information online). In addition, 
since the quantification of benefits was not feasible, a qualitative approach was chosen instead 
when assessing the benefits under each Policy Option. 

Reservations regarding the level of knowledge regarding FPR labels among interviewees 
and survey respondents  

In  the  course  of  the  research  we  had  occasion  at  several  instances  to  doubt  whether  the 
interviewees or survey respondents (e.g. at consumer associations or environmental NGOs, or 
survey  respondents  more  widely)  who  were  providing  us  with  inputs  really  knew  what  was 
involved in a FPR label as it was unlikely that they had ever seen or used them as the labels 
have not come into use yet. As a result we tended to give more weight to inputs from those who 
really were knowledgeable. These tended to come from industry (both individual enterprises 
and associations).  

The result may have been less robust and knowledgeable input than is desired on the one hand 
and an unconscious bias in our views on the other.  

3.  BASELINE COSTS: 

Having  considered  the  labelling  costs  associated  with  digital  labelling,  it  is  worth  briefly 
comparing and contrasting this with the current costs of printing physical labels. 

Consultation feedback was that there are certain costs associated with physical labelling and 
that in comparison with the predecessor Regulation 2003/2003, as more detailed information 
requirements  have  been  included  in  the  FPR,  there  are  likely  to  be  increased  costs.  It  is 
important to provide examples of feedback in this regard as this helps to  provide context in 
terms of the costs of digitalisation.  

For example, both the capital costs and human resource costs of producing physical labels were 
viewed  as  being  quite  high  by  several  fertiliser  producers  interviewed.  Moreover,  the  new 
labelling  requirements  were  seen  as  potentially  a  lot  more  costly  than  the  predecessor 
Regulation  2003/2003.  However,  this  is  based  on  producers’  expectations  before  the  new 
labelling  requirements  come  into  force  (July  2022)  given  that  the  research  was  undertaken 
between  early  2021  and April  2022.  Specific  examples  of  expected  business-as-usual  costs 
under the new FPR are now provided:  

92 

 
 
  One-off  costs  –  purchase  of  a  machine  printing  labels  was  estimated  to  cost  circa  EUR 
20,000/ factory by a medium-sized company in Ireland. Such capital investment was seen 
as necessary due to the increased labelling requirements in the FPR. However, there can be 
the possibility for businesses to outsource the printing of labels to specialist printing firms 
that provide labelling services for other products. In those cases, such one-off costs would 
not be incurred. 

  Recurring costs – examples are: printing the labels; with higher costs for fertilising product 
producers where there is a problem of label information having to change frequently, the 
plastic foil for labels with significant quantities of foil being needed which is both costly 
and environmentally damaging as requires large amounts of plastic.  

As set out in the problem definition, individual producers and industry associations expressed 
concerns that they would not be able to put the more detailed information required by the FPR 
onto a single physical label, therefore they would incur the extra costs of putting a leaflet into 
every bag. Also, there might not be space for all the languages of target countries products are 
being sold to, so there would have to be separate bags produced for different markets. These 
numbers  need  to  be  estimated  up  front  when  ordering  bags,  often  with  long  lead  times. 
However, it is not always possible to predict accurately quantities to be sold in different markets. 
As a result, there may be too few for some, too many for others. The inclination would be to 
order  too  many,  ‘just  in  case’,  which  could  result  in  wasted  bags  and  labels  having  to  be 
disposed of. In addition, there may be requirements for separate storage facilities for different 
languages which complicate logistics. All these factors have cost implications for enterprises 
and may produce environmental damage when disposing of redundant bags and labels.   

The cost of a physical label and leaflet combined for a 50 kg bag was seen as being potentially 
excessive if the labelling requirements are not digitalised, but no precise quantification could 
be provided. The study team has estimated the costs of putting a leaflet in each bag as being 
0.25 – 0.35 EUR on average.  

Consultation feedback on the costs of physical labelling was received from a major European 
fertilising  industry  association.  The  FPR  states  that  the  information  shall  appear  on  a  label 
which is affixed to that package. The industry association noted that:  

“Where the package is too small to contain all the information, the information that cannot be 
provided on the label shall be provided in a separate leaflet accompanying that package. This 
means that due to the size of big bags, it will be mandatory to label big bags without the option 
of an accompanying leaflet, while for smaller packages (25kg, 40kg, 50kg) an additional leaflet 
might be the only choice to provide all information. Without a proper digital solution, industry 
needs the option to provide excess information in a separate leaflet for both, big bags and small 
packages.  In  addition,  the  machinery  used  in  packaging  operations  goes  from  bag  filling, 
soldering to stacking on pallets and wrapping. Technical solutions to attach leaflets on each bag 
do  not  exist,  yet,  and  a  manual  job  would  neither  be  sustainable  for  safety  reasons,  nor  for 
manning cost reasons”. 

This example is provided as it highlights the fact that there are certain costs associated with 
physical labelling that might be reduced or eliminated under some of the measures relating to 
digital labelling. 

93 

 
 
4.  ASSUMPTIONS: COSTS AT THE LEVEL OF EU BUSINESSES: 

Evidence from the consultations of economic operators highlighted that the provision of any 
information in digital format requires a certain level of expenditure (in equipment, staff time, 
etc.) both on a one-off basis and an ongoing annual basis (e.g. to maintain equipment, retrain 
staff).  However,  once  that  investment  is  made,  the  incremental  cost  of  providing  more 
information  in  digital  format  is  negligible.  For  example,  there  is  little  cost  difference  in 
providing some/most/all information in digital format for any particular product. Similarly, the 
costs of providing digital labelling do not particularly vary according to the types of fertiliser 
products. On that basis, the evidence suggests that the costs of providing information in 
digital format for any specific business would be more or less identical across all policy 
measures. 

Evidence  from  the  consultations  of  businesses  (producers,  distributors,  importers,  etc.)  and 
industry associations highlights that costs can vary in line with the number of product lines a 
particular producer manufactures, or distributor distributes. Such incremental costs relate, for 
example, to the staff time required to transfer information into digital format, create additional 
web  pages,  etc.  The  frequency  of  changes  to  product  information  is  another  variable  that 
influences the costs of labelling, as some fertilisers use extensive ingredients and the labels may 
need  to  change  very  frequently,  which  some  fertiliser  producers  interviewed  noted  is  very 
costly.  

The evidence collected is not sufficiently granular to identify costs per product line. However, 
the consultations highlighted that large enterprises tend to  have  a higher  number of product 
lines compared to SMEs. There may be exceptions to this rule (e.g. SMEs with a high number 
of product lines or large enterprises with a low number of product lines). However, these appear 
to be sufficiently few to allow a general distinction to be made between the costs incurred by 
SMEs and the costs incurred by large enterprises. 

On that basis, the table ‘Enterprise-level one-off costs of digitalisation (policy measures 2-6)’ 
in Annex 3, presents estimates for the costs of providing information in digital format at the 
level of an individual enterprise (with a distinction between large enterprises and SMEs). As 
just  noted,  the  costs  of  digital  labelling  would  be  more  or  less  identical  across  all  policy 
measures. These costs also apply to the baseline scenario, since enterprises can already choose 
to  provide  information  in  digital  format,  if  they  wish  on  a  voluntary  basis  but  without  this 
counting towards regulatory compliance of the FPR’s labelling requirements. However, total 
costs  across  all  enterprises  will  need  to  take  account  of  those  enterprises  already  providing 
digital labelling and may vary if take-up varies by policy measure. This is considered in the 
next sub-section below.  

Table 4.1 Enterprise-level one-off costs of digitalisation (policy options 2 and 3) 

Required action 

Description 

Familiarisation 
costs 

Familiarisation 
with the 
information 
obligation 

No  requirement  for  familiarisation  with 
regarding 
obligations 
information 
content, but some familiarisation will be 
required  around  the  means/method  of 
providing  such  information  in  digital 
format. Familiarisation would be required 

94 

One-off cost 
estimates 

Large enterprises: €118 
SMEs: €118 

 
 
 
 
Required action 

Description 

One-off cost 
estimates 

across  all  policy  measures  Policy 
Measures 2 to 6. 

Previous research has estimated that up to 
4 person-hours are required per enterprise 
for 
information 
obligations.157 

familiarisation  with 

Eurostat  data  states  average  hourly 
earnings  for  a  technician  or  associate 
professional at €29.60 in 2021.158 

Costs related to providing and updating product information online 
Large 
€1,000 
SMEs: €1,000 

Training staff 

enterprises: 

Enterprises  of  different  sizes  provided 
flat-rate estimates of the staff training that 
would be required for them to  digitalise 
labelling  information  for  the  first  time. 
(Based  on  these  anecdotal  figures,  mid-
range estimates are provided here.) 
None of the enterprises expected to incur 
any such costs (other than those already 
to be incurred under the FPR). 

Enterprises  providing  data  reported  that 
they already had the necessary equipment 
(i.e.  computers,  laptops)  to  operate  a 
website  and  could  therefore  already  put 
product  information  onto  websites  for 
digital  labelling  purposes.  They  do  not 
need to purchase additional equipment.  

Enterprises  reported  the  need  to  incur 
costs on software and the development of 
web pages. These varied in line with the 
size of enterprise and number of product 
lines.  One  large  firm  with  nearly  300 
product lines quoted a figure of €15,000. 
SMEs  with  more  limited  product  lines 
quoted figures between €500–€7,000. 

However,  large  enterprises  (and  some 
to  already  have 
SMEs)  are 

likely 

Adjusting existing 
data or producing 
new data, filling 
forms and tables, 
holding meetings 

Purchase of 
equipment 

Purchase or 
development of 
software and 
development of 
web pages 

n/a 

n/a 

Enterprises: 

*Large 
€15,000 
*SMEs: €4,250 

(*only those lacking the 
required 
website 
capability) 

157 Impact assessment study on the making available and placing on the market of detergents. 
158 Eurostat: Structure of earnings survey and Labour Force Survey data for Non-Wage Labour Costs; last update: 
05/01/2021 

95 

 
 
 
 
 
 
                                                 
Required action 

Description 

One-off cost 
estimates 

sufficient  website  capability  even  in  the 
absence  of  digital  labelling.    (Eurostat 
data shows that 94% of large enterprises 
have  a  website,  compared  with  77%  of 
SMEs.159)  These  should  therefore  be 
considered  as  business-as-usual  costs, 
except  for  any  businesses  that  lack  the 
website capability. 

Providing product 
information online 
(collating/uploadin
g information, etc.) 

research 

previous 

Enterprises  did  not  provide  data. 
has 
However, 
identified  that  it  takes  one  hour  for  a 
technician  to  produce  and  upload  an 
ingredient datasheet to a website.160 This 
would therefore equate to 6 hours for an 
SME with 6 product lines or 300 hours for 
a large enterprise with 300 product lines. 
(Eurostat  data  states  average  hourly 
earnings  for  a  technician  or  associate 
professional at €29.60 in 2021.161 162 

Large: €8,880 
SMEs: €178 

Note – costs linked to the 
number  of  product  lines 
rather than to the size of 
enterprise.  

Cost of changing physical labels to include QR codes on the product 

Purchase of 
equipment (reading 
and generating QR 
codes) 

Large: €5,000 
SMEs: €500 

Note – costs linked to the 
number  of  product  lines  
rather than to the size of 
enterprise. 

Enterprises  reported  that  they  would 
incur equipment costs in providing digital 
information  via  QR  codes.  One  small 
enterprise  with  only  6  product  lines 
quoted  €500.  One  large  enterprise  with 
more  than  4,000  product  lines  quoted  a 
figure  of  up  to  €100,000.  However,  this 
may be an outlier, and a figure of €5,000 
is  more  realistic  for  a  large  enterprise 
with 50-300 product lines (i.e. about ten 
times the number of product lines that an 
SME might have). 
To  check  that  the  product  information 
being  provided  about  their  products  via 
QR code is correct, they would need the 
software 
necessary 

equipment 

and 

159 https://ec.europa.eu/eurostat/statistics-
explained/index.php?title=File:Enterprises_having_a_website,_by_functionality_and_size_class,_EU,_2021_(%
25_of_enterprises).png 
160 RPA (2018), Support to the Evaluation of Regulation (EC) No 648/2004 (Detergents Regulation) 
161 Eurostat: Structure of earnings survey and Labour Force Survey data for Non-Wage Labour Costs; last update: 
05/01/2021 
162 The 2019 Evaluation of the Detergent Regulation estimated that the one-off costs of collating and uploading 
information online varied from €222-371 per company. However, the study did not specify the number of products. 

96 

 
 
 
 
 
                                                 
Required action 

Description 

One-off cost 
estimates 

(including  QR  code 
generators).  

scanners  and 

Some  specialist  QR  code  technologies 
may be purchased  either as a one-off or 
on a subscription basis. However, a very 
basic  QR  code  scanner  and  generator 
could even be downloaded as an app for 
free. 

Redesigning labels 

n/a 

Enterprises would have to redesign labels 
to incorporate QR codes (or other means 
to  access  digital  information).  Previous 
research  has 
the  cost  of 
identified 
redesigning  a  physical  label  is  between 
€120  and  €200.163  This  would  therefore 
equate  to  €1,080  for  an  SME  with  6 
product  lines  or  €54,000  for  a  large 
lines. 
enterprise  with  300  product 
However, these should be considered as a 
business-as-usual  cost,  as  businesses 
report 
require 
redesign  every  few  years;  given  the 
voluntary  nature  of  digital  labelling, 
firms  typically  wait  until  labels  require 
in 
updating  before 
redesigning  them  to  incorporate  QR 
codes. 

incurring  costs 

typically 

labels 

that 

Copying 
(producing labels) 

No additional costs would be incurred, as 
printed labels with QR codes will merely 
replace  existing  labels  that  would  have 
been printed anyway. 

n/a 

Table 4.2 Enterprise-level annual costs of digitalisation (policy options 2 and 3) 

Required action 

Description 

Ongoing annual cost 
estimates 

Familiarisation 
costs 

Familiarisation 
with the 
information 
obligation 

Familiarisation  would  be  a  one-off  cost 
not an ongoing cost. 

n/a 

Costs related to providing and updating product information online 

163 RPA (2018), Support to the Evaluation of Regulation (EC) No 648/2004 (Detergents Regulation) 

97 

 
 
 
 
                                                 
Required action 

Description 

(Re-)training staff 

Equipment 
depreciation 

Enterprises of different sizes reported that 
ongoing staff training would be required, 
e.g.  in  response  to  staff  turnover  or 
updates to the software or equipment used 
for digital labelling. These were estimated 
at  €1,000  per  annum  regardless  of 
enterprise size. 
Enterprises  providing  data  reported  that 
they already had the necessary equipment 
to  operate a website and would therefore 
not need to purchase additional equipment 
to enable digital labelling via a website. 
Enterprises  offered  estimates  that  varied 
from  €200-€5,000  for  SMEs  and  were 
€5,000 for a large enterprise. 

Ongoing annual cost 
estimates 

enterprises: 

Large 
€1,000 
SMEs: €1,000 

n/a 

*LEs: €5,000 
*SMEs: €2,600 

Maintenance of 
software and web 
pages 

However, Eurostat data that 94% of large 
enterprises and 77% of SMEs (in all non-
financial  sectors)  already  operate  a 
website.  For 
the 
maintenance  and  of  software  and  web 
therefore  constitute  a 
pages  would 
business-as-usual cost. 
Cost of changing physical labels to include QR codes on the product 

these  enterprises, 

(*that  would 
not 
otherwise  maintain  the 
website 
required 
capability) 

Purchase of 
equipment (reading 
QR codes) 

Redesigning labels 

Copying 
(producing labels) 

Enterprises  did  not  specify  depreciation 
costs  separately  from  the  purchase  of 
equipment.  However,  enterprises 
in 
general  typically  work  on  the  basis  of  a 
lifetime  of  3  years  for  equipment  of  this 
type. Estimated annual costs are therefore 
one third of one-off costs. Such costs can 
be written off against tax.  
Redesigning  labels  to  incorporate  QR 
codes  would  be  a  one-off  cost.  As  and 
when  new  labels  require  to  be  designed 
(e.g.  due  to  changing  ingredients  or 
regulatory 
these  will 
requirements), 
include QR codes as a matter of course. 
No  additional  ongoing  costs  would  be 
incurred. As and when new labels require 
to  be  printed  (e.g.  due  to  changing 
ingredients), these will include QR codes 
as a matter of course. 

Large: €1,700 
SMEs: €170 

n/a 

n/a 

Based on the figures in the tables on enterprise-level costs, it is possible to estimate a figure for 
total costs for SMEs and large enterprises. These are presented as ranges. At the lower end of 

98 

 
 
 
 
 
the range are enterprises that already have sufficient website capability to host digital labelling 
information. At the upper end are enterprises that lack such capability. 

It is likely that the majority of SMEs and large enterprises will be at the lower end of the cost 
estimates: 

First, most enterprises already operate a website providing a description of goods or services. 
Eurostat data shows a figure of 94% of large enterprises (in all non-financial sectors) having a 
website  compared  with  77%  of  SMEs.164  Large  enterprises  (and  even  some  SMEs)  are  also 
likely to have a website with high functionality. It may therefore be unnecessary for most large 
enterprises to incur significant additional costs beyond the business-as-usual scenario in relation 
to the purchase or development of software and development of web pages. 

Second,  the  percentage  of  enterprises  with  a  website  is  likely  to  increase  year-on-year  even 
under the baseline scenario. For example, there has been a steady increase since 2012 when the 
comparable figures were 93% of large enterprises and 69% of SMEs with a website. In this 
context, it is perhaps likely that many enterprises will introduce digital labelling as part of a 
broader strategy to digitalise their operations or at least provide a website. To the extent that 
this  occurs,  the  costs  of  developing  a  website  and  maintaining  webpages  will  represent 
business-as-usual costs. 

Estimates for total one-off costs and ongoing annual costs are provided in the table below. 

Table 4.3 Total enterprise-level costs of optional digitalisation (policy option 2 and 3) 

Size of enterprise 

One-off 

Ongoing (annual) 

Large enterprises) 
SMEs  

€14,998 – €29,998 
€1,796 - €6,046 

€2,700 - €7,700 
€1,170 - €3,770 

Regarding  SMEs  with  sufficient  website  capability  already,  it  can  be  noted  that  there  are 
examples  of fertiliser producers that already make product  information  available about  their 
fertilising products in the form of a website or catalogue and for such firms, there would be 
very high business as usual costs.  

PO2e: There is a practical difficulty for PO2e in that the survey asked the economic operators 
to estimate future cost savings by measure but not by policy options (the policy options were 
not defined when the survey was launched). It’s therefore impossible to know what % of cost 
savings they would anticipate once the measures are combined into policy options. 

However, an intelligent estimate for PO2e can be calculated if we make one assumption based 
on the qualitative evidence (e.g. interviews): there was a consensus that the distinction between 
professional and non-professional users could be problematic; different approaches for different 
types of users would therefore tend to limit cost savings, as firms might have to assume that 
any  product  might  end  up  being  used  by  non-professionals.  On  that  basis,  we  assume  that 
combining measures 3a+5b (or 3b+5a) generates no additional cost savings compared to 3a+3b. 

164 https://ec.europa.eu/eurostat/statistics-
explained/index.php?title=File:Enterprises_having_a_website,_by_functionality_and_size_class,_EU,_2021_(%
25_of_enterprises).png  

99 

 
 
 
 
 
 
 
                                                 
5.  ASSUMPTIONS: ENTERPRISE COSTS AT EU LEVEL 

Given  the  limited  evidence  base  for  the  costs,  a  full  extrapolation  of  costs  to  EU  level  is 
problematic and risks providing a false picture. Nonetheless, a broad indication can be offered, 
to the extent that the total costs in the tables above represent a “normal efficient entity” involved 
in the manufacture, import or distribution of relevant fertilising products. 

The fertilising products sector features 3595 enterprises. Given that 99.8% of enterprises are 
SMEs, this means that approximately 14 are large enterprises, whilst 3581 are SMEs.  

The survey and the public consultation (OPC) provided different data on the percentage of firms 
that do not as yet provide any information about their products in a digital format: 

  According  to  the  stakeholder  survey,  56%  of  enterprises  do  not  as  yet  provide  any 
information  about  their  products  in  a  digital  format  (44%  are  digitalised  in  some  form 
already). If the entirety of these enterprises chose to provide information in digital format, 
this would amount to 1,392 enterprises. 

  According to the OPC, only 26% of enterprises do not as yet provide any information about 
their products in a digital format (74% are digitalised in some form already). If the entirety 
of these enterprises chose to provide information in digital format, this would amount to 
935 enterprises. 

The OPC and stakeholder survey results differed quite significantly in terms of the proportion 
of firms that said they already produced information in a digital format. A reason for the big 
difference may be that in the stakeholder survey, which was more technical compared with the 
OPC, that stakeholders were specifically responding about digital labelling whereas in the OPC 
they interpreted the question as being about digitalisation more broadly. For this reason, the 
figure from the stakeholder survey will be used in the calculation of costs and benefits (56% of 
enterprises not yet providing digital labelling). 

The percentage of enterprises that operate in compliance with the FPR is not known, given that 
they can choose instead to comply with relevant national legislation and rules. Thus, identifying 
the percentage that would move from physical labelling in line with the FPR to digital labelling 
in line with the FPR cannot be determined. To address this, a best estimate is made taking the 
percentage of SMEs that export to other EU Member States as a proxy for compliance with the 
FPR rather than with  national  rules.165 According to a  Flash Eurobarometer survey, 30% of 
SMEs (in all sectors) had exported to another EU Member State in the previous three years.166 
It is also assumed that all large enterprises comply with the FPR, since they are very likely to 
export to multiple EU Member States. 

Based on this, large enterprises and SMEs are divided into different categories, as shown in the 
table below. 

 

It is assumed that 44% of LEs already provide some form of digital labelling, all of which 
export. It is assumed that they export to other Member states and comply with the FPR. 
Such  enterprises  would  not  incur  additional  costs  (as  they  already  digitalise)  but  would 
enjoy savings from any reductions in physical labelling requirements. 

165 It is possible that some exporting enterprises will comply with national rules rather than the FPR where this is 
possible via mutual recognition between Member States. However, the research covered no data on the proportion 
of firms that take this approach. 
166 Flash Eurobarometer 421: Internationalisation of Small and Medium-Sized Enterprises 

100 

 
 
                                                 
  The remaining 56% of LEs do not yet provide any digital labelling. However, it is assumed 
that  they  export  to  other  Member  States  and  would  therefore  choose  to  adopt  digital 
labelling in compliance with the FPR. Such enterprises would incur additional costs due to 
digitalisation  but  would  also  enjoy  savings  from  any  reductions  in  physical  labelling 
requirements. 

  Of the 44% of SMEs that provide digital labelling, it is assumed that 30% export within the 
EU (= 13% of all SMEs). These firms  would not incur additional costs but would enjoy 
savings from any reductions in physical labelling requirements. 

  Of the 44% of SMEs that provide digital labelling, it is assumed that 70% do not export 
within the EU (= 31% of all SMEs). These firms would not incur additional costs and would 
not enjoy savings, as they would continue to comply with any national rules on labelling. 

  Of the 56% of SMEs that do not provide digital labelling, it is assumed that 30% export 
within the EU (= 17% of all SMEs). These firms are assumed to adopt digital labelling for 
the first time. They would therefore incur additional costs but would enjoy savings from 
any reductions in physical labelling requirements. 

  Of the 56% of SMEs that do not provide digital labelling, it is assumed that 70% export 
within the EU (= 17% of all SMEs). These firms would not incur additional costs and would 
not enjoy savings, as they would continue to comply with any national rules on labelling. 

Table 4.5 Categorisation of firms for the analysis of costs data 

101 

 
 
Already 
provides some 
digital 
labelling 
Yes 

Size 

Large 

Yes 

Exports (in 
compliance 
with FPR) 

% of 
enterprises of 
size group 

Number 

Would incur 
costs for newly-
digitalising 

No 

Would enjoy 
savings from 
reduced physical 
labelling 
Yes 

Yes 

Yes 

44% 

56% 

6 

8 

Large 

N 

Yes 

Yes 

Yes 

N 

N 

SME 

SME 

SME 

SME 

TOTAL 

Yes 

N 

Yes 

N 

13% 

473 

31% 

1,103 

No 

No 

17% 

602 

Yes 

39% 

1,404 

No 

Yes 

No 

Yes 

No 

3,595 

102 

Notes 

labelling, 

44%  of  LEs  provide 
digital  labelling,  all  of 
which  are  assumed  to 
export. 
56%  of  LEs  do  not 
provide  digital  labelling, 
all of which are assumed 
to export. 
44%  of  SMEs  provide 
digital 
of 
which 30% also export. 
44%  of  SMEs  provide 
digital 
of 
which 70% do not export. 
56%  of  SMEs  do  not 
provide  digital  labelling, 
of which 30% export. 
56%  of  SMEs  do  not 
provide  digital  labelling, 
of  which  70%  do  not 
export.. 
of 
Total 
enterprises  in  the  sector 
(see above). 

labelling, 

number 

 
 
 
 
 
 
 
The table below presents  a summary of  costs that might  be incurred at  EU level,  i.e. all 
exporting firms  not  yet  providing digital  labelling  would choose to  introduce it (56% of 
large enterprises and 17% of SMEs, in line with the previous table). 

In practice, the actual costs would most likely be less than these costs, as a certain proportion 
of exporting firms would choose not to provide digital labelling. Indeed, given its voluntary 
nature, enterprises would only provide digital labelling if they anticipated that the costs of 
such provision would be exceeded by the benefits. 

As noted earlier, these cost estimates would apply across all policy measures, since evidence 
from  the  consultations  highlighted  that  there  is  little  cost  difference  in  providing 
some/most/all information in digital format for any particular product. Similarly, the costs 
of providing digital labelling do not particularly vary according to the types of products. 

Table 4.6 EU-level costs for enterprises (all policy measures): based on survey data 

Size 

Large 
(56% of LEs) 
SMEs 
(17% of 
SMEs) 
Totals 

Exporting firms 
that might 
provide digital 
labelling 
for the first time 
8 

One-off 
costs 
per 
enterprise 

One-off 
costs 
all 
enterprises 

€ 14,998 

€ 119,984 

Ongoing 
(annual) 
costs 
per 
enterprise 
€ 2,700 

Ongoing 
(annual) 
costs 
all 
enterprises 
€ 21,600 

602 

€ 1,796  € 1,081,192 

€ 1,170 

€ 704,340 

610  

  € 1,201,176 

€ 725,940 

Given that the available data is not sufficient to determine the percentage of firms that would 
introduce digital labelling for the first time, the two tables below provide the results of a 
sensitivity analysis: 

  Lower range costs: the first table assumes that only half of exporting firms that do not 

yet offer digital labelling would choose to introduce it for the first time. 

  Upper range costs: the second table assumes that all firms that do not yet offer digital 
labelling (exporters and non-exporters) would choose to introduce it for the first time. 

Table 4.7 Lowest EU-level costs for enterprises (all policy measures) 

Size 

Large 
(28% of LEs) 
SMEs 
(8.4% of 
SMEs) 
Totals 

Exporting firms 
that might 
provide digital 
labelling 
for the first time 
4 

One-off 
costs 
per 
enterprise 

One-off 
costs 
all 
enterprises 

€ 14,998 

€ 59,992 

Ongoing 
(annual) 
costs 
per 
enterprise 
€ 2,700 

Ongoing 
(annual) 
costs 
all 
enterprises 
€ 10,800 

301 

€ 1,796 

€ 540,596 

€ 1,170 

€ 352,170 

305  

€ 600,588 

€ 362,970 

103 

 
 
 
 
 
 
Table 4.8 Highest EU-level costs for enterprises (all policy measures) 

Size 

Large 
(56% of LEs) 
SMEs 
(56% of 
SMEs) 
Totals 

Exporting firms 
that might 
provide digital 
labelling 
for the first time 
8 

One-off 
costs 
per 
enterprise 

One-off 
costs 
all 
enterprises 

€ 14,998 

€ 119,984 

Ongoing 
(annual) 
costs 
per 
enterprise 
€ 2,700 

Ongoing 
(annual) 
costs 
all 
enterprises 
€ 21,600 

2,005 

€ 1,796  € 3,600,980 

€ 1,170  € 2,345,850 

2,013  

  € 3,720,964 

  € 2,367,450 

Bringing  together  the  data  from  the  preceding  tables,  as  shown  in  the  table  below,  the 
estimates of costs to enterprises across the EU are: 

  One-off costs of €1.2m (ranging from €0.6m to €3.7m); 

  Ongoing annual costs of €0.7m (ranging from €0.4m to €2.4m). 

Table 4.9 EU-level costs for enterprises (all policy measures) 

Size 
Large 
SME 

Totals 

Upper 

One-off 
Low 
Mid 
€ 59,992  € 119,984  € 119,984 
€ 
€ 540,596 
3,600,980 
€ 
3,720,964 

€ 
1,081,192 
€ 
1,201,176 

€ 600,588 

Ongoing (annual) 
Mid 
Low 
€ 21,600 
€ 10,800 
€ 352,170  € 704,340 

€ 362,970  € 725,940 

Upper 
€ 21,600 
€ 
2,345,850 
€ 
2,367,450 

6.  ASSUMPTIONS: BENEFITS FOR ENTERPRISES (PRODUCERS, SUPPLIERS, ETC.) 

Evidence gathered during the study suggests a number of benefits for enterprises. 

Reduced costs: evidence from the consultations suggests that businesses will be more likely 
to provide digital labelling to the extent that they can remove information from physical 
labels, since this will reduce costs. Under the baseline scenario, there are no cost savings to 
be made from digital labelling, since full physical labelling is still required. In contrast, the 
policy measures offer the potential for cost savings. When asked whether digitalisation in 
general  would  save  them  money  (N=64),  48.4%  responded  that  they  think  that  it  would 
provide financial savings, while 51.6% had the opposite view. However, the responses vary 
by fertilising product as illustrated in the chart below.  

104 

 
 
 
 
 
 
 
 
 
Figure  4.1:  (Manufacturers)  Would  your  organisation  save  money  if  some  of  the 
information  in  the  physical  label  were  to  move  to  a  digital  format?  Breakdown  of 
responses (yes/ no) by FPC (N=64) 

Growing medium

Inhibitor

Fertilising product blend

Fertiliser – inorganic

Plant biostimulant

Fertiliser – organic

Fertiliser – organo-mineral

Liming material

Soil improver

61,1%

60,0%

58,1%

53,6%

50,0%

50,0%

47,6%

44,4%

44,0%

Yes

No

38,9%

40,0%

41,9%

46,4%

50,0%

50,0%

52,4%

55,6%

56,0%

Furthermore, the responses to this question reflect the numbers of respondents, not the size 
of the responding enterprises. When one considers that, for example, in the case of inorganic 
fertilisers,  39%  of  respondents  that  said  that  they  expect  savings  were  large  enterprises, 
given that the industry is dominated by a handful of large enterprises, and that the inorganic 
sector  makes  up  some  80%  of  the  total  EU  fertilisers  product  market,  one  is  potentially 
talking about a large share of the industry. Similarly, in the case of inhibitors, of the 60% 
who said  that they expected savings, all were large enterprises, while those who did  not 
were all small enterprises (see chart below). 

SMEs and cost savings: The data underlying these responses suggest that economic cost 
savings from digitalisation might be more likely to be realised by the larger enterprises that 
constitute the bulk of the industry. This does not mean that SMEs would not digitalise in the 
normal course of affairs (‘business as usual’) because they might still consider it useful to 
do so due to competitive pressures (following the market leaders) or responding to wider 
social trends where customers increasingly expect digital information on products. And as 
indicated in stakeholder survey and the OPC, a good share (44% and 74% of respondents 
respectively) already provide product information digitally.       

The two following charts suggest that while some fertilising products are more predisposed 
than others to associating digitalisation to cost advantages, SMEs are more likely to think 
that there will not be any savings if information were moved from the physical to the digital 
format. It is also worth pointing out that generally SMEs tend to be more cautious regarding 
digitalisation initiatives.167   

Figure  4.2:  (Manufacturers)  Would  your  organisation  save  money  if  some  of  the 
information in the physical label were to move to a digital format? Breakdown of the 

167 See Smit, S.J. SME focus – Long- term strategy for the European industrial future, European Parliament, 
ITRE , section 4.2.3; and, De Lemos, B. (2019) ; The Dark Side of Digital Transformation: 8 Emerging Digital 
Risks, RSA 

105 

 
 
 
                                                 
of respondents who said they would save money - by PFC (N=64) and size of enterprise

Fertilising product blend

3,2%

12,9%

12,9%

29,0%

Plant biostimulant

10,0%

15,0%

25,0%

Inhibitor

60,0%

Growing medium

5,9%

11,8%

11,8%

29,4%

Soil improver

4,2%

8,3%

12,5%

16,7%

Liming material

33,3%

11,1%

Fertiliser – inorganic

3,6%

10,7%

39,3%

Fertiliser – organo-mineral

15,0%

10,0%

20,0%

Fertiliser – organic

19,0%

14,3%

19,0%

0,0%

10,0%

20,0%

30,0%

40,0%

50,0%

60,0%

70,0%

1-9 employee

10-50 employees

51-250 employees

>251 employees

Figure  4.3:  (Manufacturers)  Would  your  organisation  save  money  if  some  of  the 
information in the physical label were to move to a digital format? Breakdown of the 
of respondents who said  they would not save money - by FPC and size of enterprise 
(N=64) 

Fertilising product blend

22,6%

6,5%

12,9%

Plant biostimulant

5,0%

20,0%

25,0%

Inhibitor

40,0%

Growing medium

23,5%

11,8%

5,9%

Soil improver

29,2%

12,5%

16,7%

Liming material

11,1%

0,0%

22,2%

22,2%

Fertiliser – inorganic

14,3%

10,7%

21,4%

Fertiliser – organo-mineral

25,0%

15,0%

15,0%

Fertiliser – organic

28,6%

9,5%

9,5%

0,0%

10,0%

20,0%

30,0%

40,0%

50,0%

60,0%

70,0%

1-9 employee

10-50 employees

51-250 employees

>251 employees

Cost savings and digitalisation: Moreover, the survey evidence show that the cost savings 
are of increasing magnitude in line with increased digitalisation: 

  Limited savings arise when information has to be physical and digital in parallel (i.e. 
Policy Measure 1 as this is a non-regulatory measure and a firm could not use the digital 

106 

 
 
 
 
label as a replacement for the physical information labelling requirements in the FPR); 

  Cost savings arise where some information remains physical and other information is 

digital (i.e. Policy Measures 2, 3, 4 and 5); 

  The greatest cost savings arise when all information is digital (i.e. Policy Measure 6). 

Cost savings can be expected in various ways. 

First, by reducing the frequency of disposing of and redesigning physical labels, as digital 
labels are easier and less costly to update than physical labels. This relates to relabelling due 
to changes to the product (e.g. different ingredients), changes in distribution of the product 
(i.e.  additional  countries)  or  due  to  regulatory  changes.  Evidence  from  the  consultations 
suggests that the need for redesigns will reduce as the extent of digitalisation increases (i.e. 
moving through the Policy Measures from 2 to 6). The data available is not sufficient to 
specify  the  level  of  cost  savings  that  would  be  achieved  by  allowing  digital  labelling  to 
replace some/most/all information on physical labels. However, an indicative benchmark 
for the cost of updating a product label is available from a previous study, which found that 
it costs between €120 and €200 to redesign the physical label for a single detergent product, 
whereas it take only one hour to revise and upload an online information sheet.168  

Second, enterprises will incur fewer costs in purchasing and maintaining the machinery or 
equipment required to make physical labels. Evidence from the stakeholder survey suggests 
that these will reduce as the extent of digitalisation increases. 

Third,  enterprises  will  incur  fewer  costs  in  printing  physical  labels  and  fixing  them  to 
products. Again, the evidence from the stakeholder survey suggests that these will reduce 
as the extent of digitalisation increases. 

The  table  below  provides  a  summary  of  estimated  annual  benefits  that  might  accrue  to 
individual enterprises under each of the options. The benefits are calculated as follows: 

  Baseline costs (except cost of redesigning physical labels) are mid-point estimates based 
on the range of cost estimates provided by enterprises responding to the survey on costs 
and benefits related to various digitalisation options. 

  Costs of machinery/equipment to make physical labels varied widely in line with the 
size  of  the  enterprise,  number  of  product  lines,  country,  etc.  For  that  reason,  an 
intelligent mid-point estimate is taken. For SMEs, this is €5,000 and for large enterprises 
it is €25,000. 

  Cost of redesigning physical labels is based on the mid-point (€160) of the cost range 
identified for the redesign of a physical label for a single detergent product (as identified 
by the previous study, see above).This unit cost is multiplied by estimates for the number 
of product lines per company (based on the stakeholder survey): 6 for SMEs and 300 
for large enterprises. Based on information provided by the stakeholder interviews, it is 
assumed  that  each  label  requires  to  be  redesigned  on  average  every  two  years.  This 
timescale  represents  a  cautious  estimate  in  order  to  avoid  overstating  savings,  but  in 
practice, many enterprises are likely to redesign labels more often. Thus the costs are as 
follows: 

-  SMEs annual cost = €160 x 6 x 0.5 = €480 

168 RPA (2018), Support to the Evaluation of Regulation (EC) No 648/2004 (Detergents Regulation) 

107 

 
 
                                                 
-  Large enterprises annual cost = €160 x 300 x 0.5 = €24,000 

  Costs  of  Fixing  labels  to  packaging  also  varied  widely  in  line  with  the  size  of  the 
enterprise,  number  of  product  lines,  country,  etc.  Again,  an  intelligent  mid-point 
estimate is taken. For SMEs, this is €2,000 and for large enterprises it is €25,000. 

It should be noted that enterprises are unlikely to enjoy significant one-off cost savings as a 
result  of  digital  labelling.  Enterprises  currently  incur  all  necessary  costs  associated  with 
physical labelling (including, from July 2022, all costs arising from the new FPR). There 
may be some limited scope to recover “sunk” costs, for example, by selling equipment that 
is no longer needed. Aside from this, savings will be realised only on an ongoing annual 
basis. 

6.1 Enterprise benefits at EU level (policy options) 

Based on the data above, it is possible to estimate the savings to enterprises at EU level for 
the different policy options described in section 6. The previous sub-section has presented 
the estimated benefits for each measure under the assumption that each measure would be 
implemented  in  isolation.  However,  the  policy  options  in  Section  6  combine  different 
measures. Given that there is some overlap between the measures, it is not possible simply 
to aggregate the costs and benefits for the measures within each policy option. Instead, some 
assumptions have to be made about the proportion of firms that would benefit from each 
measure within any particular policy option. 

The following assumptions are made: 

  PO2  to  PO6  combine  M6  with  different  measures.  Again,  it  is  assumed  that  14%  of 
enterprises  that  reduce  physical  labelling  would  benefit  from  the  higher  savings 
associated with M6 (i.e. those enterprises that only provide products in bulk or products 
which are sold to industrial users (e.g. blenders), whilst the remaining 86% benefit from 
the lower savings associated with other measures. 

  Within PO6, it is assumed that 14% of enterprises that reduce physical labelling would 
benefit from M6, whilst the remaining 86% only gain the savings associated with M3b. 
This is on the basis that most firms would struggle to differentiate between professional 
and non-professional users and would therefore gain only the lower benefits associated 
with M3 rather than M5. 

On this basis, the enterprises covered by each policy option are as follows. 

Table 4.10 Enterprises covered by each policy option (mid-range estimate of benefits)  

Includes 

Enterprises included 
in policy option 

Policy 
optio
n 
All exporting enterprises 
PO1 
PO2  M2 + M6  All exporting enterprises 

M1 

PO3  M3 + M6  All exporting enterprises 

PO4  M4 + M6  All exporting enterprises 

108 

Enterprises covered by 
each policy measure 

 M1: 100% of exporting enterprises 
 M2: 86% of exporting enterprises 
 M6: 14% of exporting enterprises 
 M3: 86% of exporting enterprises 
 M6: 14% of exporting enterprises 
 M2: 86% of exporting enterprises 
 M6: 14% exporting enterprises 

 
 
 
PO5  M5 + M6  All exporting enterprises 

PO6  M3b + M5a 

All exporting enterprises 

+ M6 

 M2: 86% of exporting enterprises  
 M6: 14% of exporting enterprises 
 M3b: 86% of exporting enterprises 
 M6: 14% of exporting enterprises 

Table 4.11 Enterprises covered by each policy option (lower range estimate of 
benefits 

Includes 

Enterprises included 
in policy option 

Policy 
optio
n 
PO1 

M1 

Percentage of enterprises 
covered by each policy 
measure 

 M1: 100% of all enterprises 

 M2: 86% of all enterprises 
 M6: 14% of all enterprises 

 M3: 86% of all enterprises 
 M6: 14% of all enterprises 

 M2: 86% of all enterprises 
 M6: 14% all enterprises 

 M2: 86% of all enterprises  
 M6: 14% of all enterprises 

 Exporting  enterprises 
providing 

already 
digital labelling 

 50% 

of 
enterprises 
providing 
labelling 

exporting 
yet 
not 
digital 

 Exporting  enterprises 
providing 

already 
digital labelling 

 50% 

of 
enterprises 
providing 
labelling 

exporting 
yet 
not 
digital 

 Exporting  enterprises 
providing 

already 
digital labelling 

 50% 

of 
enterprises 
providing 
labelling 

exporting 
yet 
not 
digital 

 Exporting  enterprises 
providing 

already 
digital labelling 

 50% 

of 
enterprises 
providing 
labelling 

exporting 
yet 
not 
digital 

 Exporting  enterprises 
providing 

already 
digital labelling 

 50% 

of 
enterprises 
providing 
labelling 

exporting 
yet 
not 
digital 

PO2 

M2 + M6 

PO3 

M3 + M6 

PO4 

M4 + M6 

PO5 

M5 + M6 

PO6  M3b + M5a+ 

M6 

 Exporting  enterprises 
providing 

already 

 M3b: 86% of all enterprises 
 M6: 14% of all enterprises 

109 

 
 
 
digital labelling 

 50% 

of 
enterprises 
providing 
labelling 

exporting 
yet 
not 
digital 

Table 4.12 Enterprises covered by each policy option (upper range estimate of 
benefits 

Policy 
optio
n 
PO1 
PO2 

Includes 

Enterprises included 
in policy option 

M1 
M2 + M6 

All enterprises 
All enterprises 

PO3 

M3 + M6 

All enterprises 

PO4 

M4 + M6 

All enterprises 

PO5 

M5 + M6 

All enterprises 

PO6  M3b + M5a+ 

All enterprises 

M6 

Percentage of enterprises 
covered by each policy 
measure 

 M1: 100% of all enterprises 
 M2: 86% of all enterprises 
 M6: 14% of all enterprises 
 M3: 86% of all enterprises 
 M6: 14% of all enterprises 
 M2: 86% of all enterprises 
 M6: 14% all enterprises 
 M2: 86% of all enterprises  
 M6: 14% of all enterprises 
 M3b: 86% of all enterprises 
 M6: 14% of all enterprises 

The tables provide the estimated savings under each policy option: 

  Mid-range: the first table provides an estimate of benefits based on the assumption that 
all  enterprises  that  export  would  make  savings  associated  with  reduced  physical 
labelling requirements (because they already provide digital labelling or would newly 
introduce it). 

  Lower range: the second table provides estimated benefits for a scenario in which only 
half of exporting enterprises that do not  yet provide digital labelling choose to do so 
(and therefore make savings associated with reduced physical labelling requirements, 
alongside those that already provide digital labelling). 

  Upper  range:  the  third  table  provides  estimated  benefits  for  a  scenario  in  which  all 
enterprises provide digital labelling and therefore make savings associated with reduced 
physical labelling requirements. 

110 

 
 
 
 
 
 
Table 4.13 Benefits (savings) accruing to enterprises (EU27) under each policy option 

PO1 

PO2a 

POb 

PO2c 

PO2d 

PO2e 

PO3 

Base
line 

M1 

M2 

M3 

M4 

M56 

0 

0 

244,383 

394,167  4,321,50
0 

4,966,500 

M3b+M5a
+M6 
394,167 

M6 

951,000 

0 

0 

64,167 

93,333 

504,000 

556,500 

93,333 

116,500 

0 

0 

308,550 

487,500  4,825,50
0 

5,523,000 

487,500  1,067,50
0 

Total 
annual 
savings 
all 
SMEs 
(€) 
Total 
annual 
savings 
all large 
enterpri
ses (€) 
Total 
annual 
savings 
all  
enterp
rises 
(€) 

Table  4.14  Lower  range  benefits  (savings)  accruing  to  enterprises  (EU27)  under  each 
policy option 

Baseline  PO1  PO2a 
M1  M2 

POb 
M3 

PO2c 
M4 

PO2d 
M5 

PO2e 

PO2a 
M3b+M5a+M6  M2 

0 

0  244,383  394,167  3,111,480  3,575,880 

394,167  684,720 

0 

0 

45,833 

66,667 

360,000 

397,500 

66,667 

58,250 

0 

0  290,217  460,833  3,471,480  3,973,380 

460,833  742,970 

Total 
annual 
savings  all 
SMEs (€) 
Total 
annual 
savings  all 
large 
enterprises 
(€) 
Total 
annual 
savings  all  
enterprises 
(€) 

111 

 
 
 
  
 
 
 
  
 
 
Table  4.15  Upper  range  benefits  (savings)  accruing  to  enterprises  (EU27)  under  each 
policy option 

PO1 

PO2a 

POb 

PO2c 

PO2d 

PO2e 

PO2a 

Base
line 

M1 

M2 

M3 

M4 

M5 

M3b+M5a
+M6 

M2 

Total 
annual 
savings 
all 
SMEs 
(€) 
Total 
annual 
savings 
all large 
enterpri
ses (€) 
Total 
annual 
savings 
all  
enterpr
ises (€) 

0 

0 

813,750 

1,312,500 

14,395,620  16,544,220 

1,312,500 

3,176,340 

0 

0 

64,167 

93,333 

504,000 

556,500 

93,333 

116,500 

0 

0 

877,917 

1,405,833 

14,899,620  17,100,720 

1,405,833 

3,292,840 

7.  ASSUMPTIONS: COMPARISON OF COSTS AND BENEFITS AT EU LEVEL 

Bringing together the cost and benefit data presented above, it is possible to offer an estimate 
of net benefits to enterprises at EU level. Three scenarios are presented in the tables below. 

  Mid-range: the first table provides an estimate of net benefits based on the assumption that 
all  enterprises  that  export  would  gain  from  savings  associated  with  reduced  physical 
labelling  requirements  (because  they  already  provide  digital  labelling  or  would  newly 
introduce it). 

  Lower range: the second table provides an estimate of net benefits for a scenario in which 
only half of exporting enterprises that do not yet provide digital labelling choose to do so. 
Savings  associated  with  reduced  physical  labelling  requirements  would  accrue  to  those 
enterprises,  as  well  as  exporting  enterprises  that  already  provide  digital  labelling  in 
compliance with the FPR. 

  Upper  range:  the  third  table  provides  estimated  benefits  for  a  scenario  in  which  all 
enterprises provide digital labelling and therefore gain from savings associated with reduced 
physical labelling requirements. 

Under all scenarios: 

  Net one-off benefits are negative for all policy options, since there are no one-off savings 

to be made (only the one-off costs of digitalisation). 

  Net  recurring  benefits  are  positive  for  all  policy  options,  since  recurring  savings  from 

reduced physical labelling exceed recurring costs of digitalisation. 

112 

 
 
 
  
 
  Net  recurring  benefits  for  enterprises  are  lower  under  PO2  than  under  PO3  to  PO6. 
However,  this  does  not  take  into  account  the  costs  and  benefits  for  users  (which  are 
discussed in the next sub-section). 

  Net benefits in the first year (i.e. one-off plus recurring) would be positive for all policy 
options under all scenarios, except for PO2 within the mid-range and upper range estimates. 
However, they would be positive by the end of the second year. 

Table 9.3 Mid-range net benefits accruing to all enterprises (EU27) 

PO1  PO2a  POb 

PO2c 

PO2d  PO2e 

PO2a 

Base
line 

All 
enterprises 
(EU27) 

One-off  costs 
and  benefits 
(€) 

One-off 
benefits 

One-off costs 

one-off 

Net 
benefits 

Recurring 
annual  costs 
and  benefits 
(€) 

Recurring 
annual benefits 
(savings) 

Recurring 
annual costs 

Net  recurring 
benefits 

0 

0 

0 

0 

0 

0 

M1  M2  M3 

M4 

M5  M3b+
M5a+
M6 

M2 

0 

0 

0 

0 

0 

0 

0 

0 

0 

119,984 

119,984 

1,201,176 

1,201,176 

119,984 

165,862 

-119,984 

-119,984 

-1,201,176 

-1,201,176 

-119,984 

-165,862 

0 

308,550 

487,500 

4,825,500 

5,523,000 

487,500 

1,067,500 

0 

0 

21,600 

21,600 

725,940 

725,940 

21,600 

100,980 

286,950 

465,900 

4,099,560 

4,797,060 

465,900 

966,520 

113 

 
 
 
 
 
  
  
  
  
  
  
  
 
 
 
  
  
  
  
  
 
 
 
 
Table 9.4 Lower range net benefits accruing to all enterprises (EU27) 

All enterprises (EU27) 

One-off  costs  and  benefits 
(€) 

One-off benefits 

One-off costs 

Net one-off benefits 

Recurring  annual  costs  and 
benefits (€) 

Recurring 
(savings) 

annual  benefits 

Recurring annual costs 

Net recurring benefits 

Baseli
ne 

0 

0 

0 

0 

0 

0 

P
O1 

M
1 
0 

0 

0 

0 

0 

0 

PO
2a 

PO
b 

PO2
c 

PO2
d 

PO2e 

PO
2a 

M2  M3  M4  M5  M3b+M5a

M2 

+M6 

0 

0 

0 

0 

0 

0 

59,99
2 

-
59,99
2 

59,99
2 

-
59,99
2 

600,58
8 

600,58
8 

-
600,58
8 

-
600,58
8 

59,992 

-59,992 

75,43
2 

-
75,43
2 

290,2
17 

460,8
33 

3,471,
480 

3,973,
380 

10,80
0 

279,4
17 

10,80
0 

450,0
33 

362,97
0 

362,97
0 

3,108,
510 

3,610,
410 

460,833 

10,800 

450,033 

742,9
70 

49,14
0 

693,8
30 

114 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
 
 
 
 
 
ANNEX 5: THE FPR AND ITS LABELLING PROVISIONS 

1. 

INTRODUCTION OF THE FERTILISING PRODUCT REGULATION: 

Why was there a need new rules on fertilising products? 

The  reuse  of  raw  materials  that  are  disposed  as  waste  was  one  of  the  key  principles  of  the 
Circular  Economy  Package  adopted  in  December  2015.  At  that  time  more  and  more 
manufacturers in the EU were developing innovative fertilising products including nutrients or 
organic matter recycled from bio-waste. However, diverging national rules and standards made 
it difficult for producers of organic fertilisers to sell and use them across the EU single market. 
The 2003 Fertilisers Regulation ensured free movement for traditional fertilisers typically made 
of  mined  or  synthetic  raw  materials  but  it  did  not  include  a  clearing  procedure  for  organic 
fertilisers. As a result, around half of all fertilisers produced were marketed in the country where 
they  were  produced.  That  was  the  case  for  virtually  all  fertilisers  produced  from  organic 
materials,  such  as  derived  products  from  animal  by-products  or  other  agricultural  residual 
products,  or  recycled  bio-waste.  Traditional  fertilisers  had  a  competitive  advantage,  which 
hampered innovation and investment in the circular economy. Considering that processes for 
producing  traditional  fertilisers  are  often  both  energy  consuming  and  CO2-intensive,  easier 
market access for organic fertilisers could additionally bring environmental benefits.  

What are the main elements of the FPR? 

The FPR will be fully applicable as of 16 July 2022. It contains several elements that help create 
a level playing field for all fertilising products, while at the same time ensure high safety and 
environmental protection standards. The FPR: 

• 

• 

• 
• 

• 

• 

provides rules for free movement of all EU fertilising products (CE-marked) across 
the EU; It allows all EU fertilising products, from chemically synthesised substances 
or from recycled bio-waste and recovered nutrients, to benefit of CE-marking that 
ensures free movement in the single market.   
maintains optional harmonisation – a manufacturer who does not wish to CE-mark 
the product and have unrestricted access to the entire EU single market can opt for 
compliance with national rules instead and rely on mutual recognition for selling in 
other EU countries.  
introduces new harmonised requirements for all EU fertilising products regarding 
quality  –  such  as  minimum  nutrient  content,  organic  matter  content,  neutralizing 
values that are specific to each category of fertilising products; 
safety – such as maximum limits for heavy metals, including cadmium, for organic 
contaminants,  for  microbial  contaminants  and  for  impurities  specific  to  each 
category of fertilising products or component materials;  
labelling – such as the actual nutrients content and their forms which will allow the 
farmers to modulate the use of the fertilisers depending on the plant needs and the 
characteristics of their soil; 

115 

 
 
 
• 

• 

• 

• 

modernises the declaration  of conformity and conformity assessment  procedures; 
manufacturers of fertilising products have to comply with if they want to trade their 
products in the EU single market;  
delineates  the  borderlines  between  fertilising  products  and  Plant  Protection 
Products, to avoid overlap between plant bio-stimulants and plant growth regulators; 
enables  derived  animal-by-products  to  move  freely  on  the  single  market  as 
fertilising  products  after  the  end  point  in  the  manufacturing  chain  would  be  laid 
down in the Animal by-products Regulation ; 
includes harmonised recovery rules for waste transformed into composts, digestates, 
struvite, biochar, ashes or high purity materials. If these materials are incorporated 
in  EU  fertilising  products,  they  are  no  longer  considered  to  be  waste  within  the 
meaning of the Wastes Framework Directive . This allows waste-derived products 
to circulate freely in the EU. 

What fertilising products are covered by the FPR? 

The FPR applies  to  the  entire catalogue of fertilising products: organic, organo-mineral  and 
inorganic  fertilisers,  liming  materials,  soil  improvers,  growing  media,  inhibitors,  plant 
biostimulants and fertilising product blends. The FPR does not apply to raw waste products, to 
unprocessed animal by-products (such as raw manure) nor to plant protection products.  

Will producers be forced to CE-mark their products? Can the producers continue to sell 
fertilisers according to national rules?  

As some fertilising products are not produced or traded in large quantities across the EU, the 
FPR allows for optional harmonisation. A dual approach prevents market disruption and at the 
same time creates new opportunities for producers EU fertilising products – both organic and 
inorganic. In practice, manufacturers will have two options.  

1. 
They can comply with the new harmonised safety, quality and labelling requirements, 
then affix the CE mark to their EU fertilising product and benefit from free access to the EU 
internal market.  

2. 
Equally, they could decide to trade their product on the national market according to the 
national rules. In case they want to sell their products in other EU countries but do not want to 
CE mark their products, they may be able to do so, however depending on mutual recognition 
between the Member States.  

How will the FRP rules improve the protection of health and the environment?  

The Fertilisers Regulation 2003 does not address possible contamination of soil, inland waters, 
sea  waters,  and  ultimately  food,  by  EC  marked  fertilisers.  Some  fertilisers  may  contain 
substances  that  are  considered  dangerous  to  human  health  and  environment.  In  particular, 
phosphate fertilisers can contain heavy metals, such as cadmium. To avoid contamination of 
the food chain and limit environmental damage, the FPR sets out harmonised limits for heavy 
metals (cadmium, chromium, mercury, nickel, lead, arsenic) in EU fertilising products. Given 
that  fertilising  products  derived  from  treated  bio-waste  and  biomass  are  in  general  less 

116 

 
 
 
contaminated with heavy metals, but may contain other types of pollutants, the FPR sets out 
limits for several organic pollutants, such as polycyclic aromatic hydrocarbons (PAHs).  

How will resource efficiency be improved? 

The  production  of  inorganic  nitrogen  fertilisers  is  very  energy  intensive.  About  2%  of  the 
world's energy is used to produce synthetic nitrogen fertilisers. The EU is also highly dependent 
on  imports  of  phosphates.  Around  90%  of  the  phosphate  rock  used  to  produce  fertilisers  is 
imported, making the EU vulnerable to high prices of raw materials. Considering the expected 
global  population  growth  and  the  related  increase  of  food  demand,  we  can  expect  that  the 
demand for nitrogen and phosphate fertilisers – and consequently for resources – will increase 
in  coming  years. Disrupted nutrient  recycling is  also  a problem  worldwide. Phosphorus and 
nitrogen cycles are subject to losses in the environment, and phosphorus is a limited resource. 
The leaching of nutrients into the environment has led to deterioration of surface water through 
eutrophication.  Other  valuable  nutrients  are  wasted  and  end  up  in  landfills  instead  of  being 
recycled for plant nutrition.  

The FPR lays down rules for alternative resources such as recycled nutrients. In a more circular 
economy,  the  value  of  raw  materials  and  energy  used  in  products  could  be  maintained  in 
recycled  products  and  contribute  to  a  more  resource  efficient  Europe.  The  FPR  also 
encompasses products to enhance plant nutrition efficiency. As a result, there is lower and more 
efficient use of fertilisers. 

117 

 
 
 
 
 
 
 
ANNEX 6 – GUIDANCE DOCUMENT ON THE LABELLING OF EU 
FERTILISING PRODUCTS 

118 

 
 
 
 
119 

   EUROPEAN COMMISSION  Brussels, 18.2.2021  C(2021) 726 final  COMMUNICATION FROM THE COMMISSION concerning the visual appearance of the label on EU fertilising products referred to in Annex III to Regulation (EU) 2019/1009 of the European Parliament and of the Council  
 
 
COMMUNICATION FROM THE COMMISSION 

concerning the visual appearance of the label on EU fertilising products referred to 
in Annex III to Regulation (EU) 2019/1009 of the European Parliament and of the 
Council 

•  INTRODUCTION 

Pursuant to Article 4(3) of Regulation (EU) No 2019/1009 of the European Parliament and 
of the Council of 5 June 2019 laying down rules on the making available on the market of 
EU  fertilising  products  and  amending  Regulations  (EC)  No  1069/2009  and  (EC)  No 
1107/2009  and  repealing  Regulation  (EC)  No  2003/2003169  (the  ‘Fertilising  Products 
Regulation’  or  the  ‘FPR’),  the  Commission  shall  publish  a  guidance  document  for 
manufacturers  and  market  surveillance  authorities  with  clear  information  and  examples 
concerning the visual appearance of labels referred to in Annex III to that Regulation.  

A task force of representatives of EU Member States and industry stakeholders, representing 
all the Product Function Categories (PFCs) falling under the scope of the FPR, was created 
by the Commission in July 2019 in order to support its services (DG GROW/D2) in fulfilling 
this task. The mandate of this task force was to write a first draft of this document.  

This document was shared and discussed with members and observers of the Commission 
Expert Group on Fertilising Products in 2019 and 2020.  

This  document  is  not  legally  binding  and  seeks  only  to  provide  useful  guidance  to 
stakeholders including manufacturers and market surveillance authorities. Only the Court 
of Justice of the European Union is competent to authoritatively interpret Union law. 

This  guidance  document  provides  explanations  on  the  practical  implementation  of  the 
labelling requirements set in Annex III to the FPR. It includes examples of labels for the 
different  PFCs  of  EU  fertilising  products.  These  examples  are  purely  indicative.  The 
position  of  each  part,  as  well  as  the  colours  used  in  this  guidance  document  are  not 
mandatory.  It  is  up  to  the  manufacturer  to  decide  where  to  place  and  how  to  format  the 
information on the label, while respecting the requirements in the FPR.  

Unless  otherwise  provided  in  this  guidance  document  or  no  colours  are  used  at  all,  the 
following colour codes are used in the label examples: 

• 
• 
• 
• 

In blue: general requirements; 
In orange: specific requirements for each PFC;  
In black: other information that has to be provided on the label; 
In green: indicated nutrients. 

169 OJ L 170, 25.6.2019, p. 1–114. 

120 

 
 
 
 
                                                 
Contents 

1. 

INTRODUCTION ................................................................................................................................ 1 

1.1.  Political Context ................................................................................................ 1 
1.2.  Legal context ..................................................................................................... 4 
1.3.  Market context ................................................................................................... 5 
  The fertilising products industry .................................................................... 5 

 ............................................................................................................................. 6 

  The EU agriculture ......................................................................................... 7 

2. 

PROBLEM DEFINITION .................................................................................................................... 7 

2.1.  Preliminary remarks .......................................................................................... 7 
2.2.  What are the problems? ..................................................................................... 8 
2.2.1.  Problem 1- Labels are difficult to read for users ............................................ 9 

2.2.2.  Problem 2- Labels are difficult to manage for economic operators ............. 10 

2.3.  What are the problem drivers? ........................................................................ 11 
  Driver 1: extensive labelling requirements .................................................. 11 

  Driver 2: there are no rules regarding the voluntary digitalisation of the labels

12 

  Driver 3: some labelling information changes frequently ............................ 12 

  Driver 4: Some EU fertilising products change their labels before reaching the 
end-users ..................................................................................................................... 13 

  Driver 5: products sold in bulk need personalised leaflets ........................... 14 

2.4.  How likely are the problems to persist? .......................................................... 15 

3.  WHY SHOULD THE EU ACT? .........................................................................................................15 

3.1.  Legal basis ....................................................................................................... 15 
3.2.  Subsidiarity: Necessity of EU action ............................................................... 16 
3.3.  Subsidiarity: Added value of EU action .......................................................... 16 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................................17 

The links between the problems identified and the objectives of this initiative 

are presented in Table 4.1. ............................................................................... 17 
4.1.  General objectives ........................................................................................... 17 
4.2.  Specific objectives ........................................................................................... 18 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? .....................................................................18 

5.1.  What is the baseline from which options are assessed? .................................. 18 
The socioeconomic context .......................................................................... 18 
5.1.1 

5.1.2  Agriculture .................................................................................................... 19 

5.1.3  Hobby market ............................................................................................... 19 

5.1.4  Digital divide ................................................................................................ 19 

5.1.5 

Share of companies already embracing digitalising product information .... 20 

121 

 
 
 
5.1.6  Continuation of the existing legal framework .............................................. 21 

5.1.7  Digital product passport ............................................................................... 21 

5.2.  Description of the policy options .................................................................... 22 
5.2.1.  Differences between professional and non-professional users ..................... 24 

5.2.2.  The stability of the information provided over time .................................... 25 

5.3.  Presentation of the policy measures: ............................................................... 25 
Information which could be moved from the physical label to digital label 28 
5.3.1. 

5.3.2.  Principles for digital labelling ...................................................................... 30 

5.4.  Presentation of policy options: ........................................................................ 31 
5.5.  Options discarded at an early stage ................................................................. 32 
5.5.1.  Replacing the physical labels with digital labels for all EU fertilising products

33 

5.5.2.  Mandatory digital labelling .......................................................................... 34 

5.5.3.  Centralised database for providing information digitally ............................. 34 

5.5.4.  Digitalisation of incremental information requirements. ............................. 35 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................................35 

6.2.  Policy Option 1: Development of a Guidance Document only ....................... 36 
6.2.1.  Economic impacts ........................................................................................ 36 

6.2.2. 

Impact on the environment ........................................................................... 36 

6.2.3.  Social impact and on human health .............................................................. 36 

6.2.4.  Stakeholders view on PO1 ........................................................................... 37 

6.3.  Policy  Option  2:  Information  may  be  provided  digitally  for  EU 

Fertilising Products .......................................................................................... 37 
6.3.1.  Economic impacts ........................................................................................ 38 

6.3.2. 

Impact on the environment ........................................................................... 45 

6.3.3.  Social impact and on human health .............................................................. 46 

6.3.4.  Stakeholders view on PO2a- PO2e .............................................................. 47 

6.4.  Policy  Option  3:  All  information  is  provided  digitally  for  certain 

categories of products ...................................................................................... 48 
6.4.1.  Economic impacts ........................................................................................ 48 

6.4.2. 

Impact on the environment ........................................................................... 50 

6.4.3.  Social impact and on human health .............................................................. 51 

6.4.4.  Stakeholders view on policy option 3 .......................................................... 51 

7.  HOW DO THE OPTIONS COMPARE? .............................................................................................51 

8. 

PREFERRED OPTION .......................................................................................................................57 

8.1.  REFIT (simplification and improved efficiency) ............................................ 58 
8.2.  Application of the ‘one in, one out’ approach ................................................. 58 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?...................................59 

122 

 
 
 
ANNEX 1: PROCEDURAL INFORMATION .............................................................................................61 

1. 

LEAD DG, DECIDE PLANNING/CWP REFERENCES ...................................................................61 

ORGANISATION AND TIMING ................................................................................................................61 

2. 

3. 

CONSULTATION OF THE RSB .......................................................................................................61 

EVIDENCE SOURCES AND QUALITY...........................................................................................63 

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) .................................................65 

1. 

THE CONSULTATION ACTIVITIES ...............................................................................................65 

1.1 
Interviews ........................................................................................................ 65 
1.2  Open public consultation ................................................................................. 67 
1.3  A targeted stakeholder survey ......................................................................... 69 
1.4  The survey experiment .................................................................................... 72 
1.5  Focus groups .................................................................................................... 73 
1.6  Usability testing ............................................................................................... 74 
1.7  Ad-hoc expert group meeting on options for digitalisation of labels .............. 75 
1.8  Survey:  focus  on  costs  and  benefits  related  to  various  digitalisation 

options ............................................................................................................. 76 

ANNEX 3: WHO IS AFFECTED AND HOW? ...........................................................................................78 

1. 

2. 

3. 

PRACTICAL IMPLICATIONS OF THE INITIATIVE .....................................................................78 

SUMMARY OF COSTS AND BENEFITS ........................................................................................79 

RELEVANT SUSTAINABLE DEVELOPMENT GOALS ................................................................85 

ANNEX 4: ANALYTICAL METHODS ......................................................................................................86 

1.  OVERVIEW ........................................................................................................................................86 

2. 

3. 

LIMITATIONS ENCOUNTERED AND MITIGATION MEASURES .............................................88 

BASELINE COSTS: ............................................................................................................................89 

4.  ASSUMPTIONS: COSTS AT THE LEVEL OF EU BUSINESSES: .................................................91 

5.  ASSUMPTIONS: ENTERPRISE COSTS AT EU LEVEL .................................................................97 

6.  ASSUMPTIONS: BENEFITS FOR ENTERPRISES (PRODUCERS, SUPPLIERS, ETC.) ............101 

7.  ASSUMPTIONS: COMPARISON OF COSTS AND BENEFITS AT EU LEVEL .........................110 

ANNEX 5: THE FPR AND ITS LABELLING PROVISIONS ..................................................................114 

1. 

INTRODUCTION OF THE FERTILISING PRODUCT REGULATION: ......................................114 

ANNEX  6  –  GUIDANCE  DOCUMENT  ON  THE  LABELLING  OF  EU  FERTILISING 

PRODUCTS .......................................................................................................................................117 

• 

INTRODUCTION ............................................................................................................................119 

  OVERALL RULES ON LABELLING IN THE CORE TEXT OF THE FPR ..........................127 

  What does mandatory labelling information cover? ................................ 127 
Is it possible to provide voluntary information on the label? Where 
 
could this voluntary information appear? ................................................ 127 
Is it possible to put information on the packaging, outside the label 
(i.e. batch n°, CE mark, notified body’s number, quantity)? .................. 127 

 

123 

 
 
 

 

Is  there  a  minimal/maximal  size  for  the  label/the  font?  Is  there  a 
proportional size to respect?....................................................................... 128 
In what language(s) should a label be written? ........................................ 128 

  GENERAL LABELLING REQUIREMENTS IN ANNEX III OF THE FPR ...........................128 

How to write the designation of the claimed function? ............................ 128 
How to express the quantity of the EU fertilising product? .................... 129 
How to provide information on the general application rates? .............. 129 
How to provide information on storage conditions? ................................ 130 

 
 
 
 
  What does the functionality period of products containing a polymer 

belonging to CMC 9 mean? ........................................................................ 130 
 
How to provide the information on risk management? ........................... 131 
  What does ‘ingredients’ mean and how to label them? ........................... 132 
How to label the function of products with two or more functions? ...... 133 
 
Is it possible to use different wording for the requirements in points 
 
4, 5, 6 and 9 in Part I of Annex III? ........................................................... 134 
Is  it  possible  to  use  pictograms  based  on  good  practices?  How  to 
manage the interaction with the CLP Regulation? .................................. 134 
In which cases can the manufacturer express the nutrient content in 
elemental form? ........................................................................................... 134 
How to refer to the organic matter instead of organic carbon? .............. 135 
Example for general labelling requirements and visual appearance ..... 136 

 
 

 

 

SPECIFIC LABELLING REQUIREMENTS FOR PFC 1 FERTILISER .................................136 

 

Is  it  necessary  to  label  the  content  of  all  nutrients  present  in  a 
fertiliser? ...................................................................................................... 136 

  When the regulation does not define minimum content for secondary 
nutrients (PFC 1 (A) and PFC 1 (B)), how to label the content of these 
nutrients?...................................................................................................... 137 

 

  When the content of nitrogen (N) or phosphorus pentoxide (P2O5) 
has  to  be  indicated  as  it  is  above  0,5  %  by  mass,  how  should  this 
information be provided? ........................................................................... 137 
Can the term ‘mineral’ be used instead of or in addition to the term 
‘inorganic’ in the designation of the product? Where should the term 
‘mineral’ be labelled? .................................................................................. 137 
Does  ammoniacal  nitrogen  (NH3)  refer  to  ammonium  nitrogen 
(NH4

+) for PFC 1? ........................................................................................ 137 

 

SPECIFIC LABELLING REQUIREMENTS FOR PFC 1(A) ORGANIC FERTILISER .......137 

 
 
 

Example of a label ....................................................................................... 137 
How to declare organic nitrogen and the origin of organic matter? ...... 139 
At  which  precision  level  should  mandatory  information  for  PFC 
1(A) be declared? ......................................................................................... 139 

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 

Should ammoniacal nitrogen be declared even if it is not present in 
the product? ................................................................................................. 139 
Is it possible to declare organic matter instead of organic carbon? ....... 139 
 
  Where to include the information related to the date of production? .... 139 

SPECIFIC  LABELLING  REQUIREMENTS  FOR  PFC  1(B)  ORGANO-MINERAL 
FERTILISER ...................................................................................................................................140 

 
 
 

 

 
 

Example of a label ....................................................................................... 140 
How to declare organic nitrogen and the origin of organic matter? ...... 141 
Should a specific form of nitrogen (N), phosphorus (P) or potassium 
(K) be declared even if it is not present in the product? .......................... 141 
How to provide pertinent information about the possible air quality 
impacts  of  the  release  of  ammonia  from  the  fertiliser  use,  and  an 
invitation to users to apply appropriate remediation measures when 
urea (CH4N2O) is present in the product? ................................................ 141 
How to declare the ‘low cadmium content’? ............................................. 142 
At what precision can micronutrients be declared? ................................. 142 

SPECIFIC  LABELLING  REQUIREMENTS  FOR  PFC  1(C) 
FERTILISER ...................................................................................................................................143 

INORGANIC 

 
 

PFC 1 (C)(I): Inorganic Macronutrient Fertiliser ................................... 143 
Example of a label ........................................................................................ 143 

  What is the minimum number of decimals that should be indicated on the 
label? ........................................................................................................................ 144 

 
How to provide pertinent information about the possible air quality impacts 
of  the  release  of  ammonia  from  the  fertiliser  use,  and  an  invitation  to  users  to 
apply appropriate remediation measures when urea (CH4N2O) is present in the 
product? .................................................................................................................. 144 

 

 
 

 

How to declare the “low cadmium content”? ............................................ 145 

PFC 1(C)(I)(a): Solid Inorganic Macronutrient Fertiliser ...................... 145 
Example of a label ........................................................................................ 145 

Example for granulometry .......................................................................... 145 

 
In what way can granulometry and physical unit be indicated on the label? 
Is it allowed to reference more than one sieve when indicating the granulometry 
of a product? ........................................................................................................... 145 

 

 

 

 

 
 
 

How is a “coating” defined? ........................................................................ 146 

How to declare the functionality period of the coated fertiliser? ............. 146 

How to declare the type of coating agent?.................................................. 146 

How to draw the label for mined fertilisers? ............................................. 146 

PFC 1(C)(I)(b): Liquid Inorganic Macronutrient Fertiliser ................... 147 
PFC 1(C)(II): Inorganic Micronutrient Fertiliser .................................... 148 
PFC 1(C)(II)(a): Straight Inorganic Micronutrient Fertiliser ................. 148 

125 

 
 
 
 
 

 

PFC 1(C)(II)(b): Compound Inorganic Micronutrient Fertiliser ............ 148 

PFC 1(C) complete label example .............................................................. 149 

SPECIFIC LABELLING REQUIREMENTS FOR PFC 2 LIMING MATERIAL ..................152 

 
 

Examples of a label ...................................................................................... 152 
Regulatory reference, explanation and voluntary additions ................... 154 

SPECIFIC LABELLING REQUIREMENT FOR PFC 3 SOIL IMPROVER ..........................155 

 
 

 

 
 

 

PFC 3(A) Organic Soil Improver ............................................................... 155 
Examples of a label ....................................................................................... 155 

Regulatory reference, explanation and voluntary additions .................... 159 

PFC 3(B) Inorganic Soil Improver ............................................................ 160 
Example of a label ........................................................................................ 160 

Regulatory reference, explanation and voluntary additions .................... 160 

SPECIFIC LABELLING REQUIREMENTS FOR PFC 4 GROWING MEDIUM ..................161 

 
 

Examples of a label ...................................................................................... 161 
Regulatory reference, explanation and voluntary additions ................... 164 

  SPECIFIC LABELLING REQUIREMENTS FOR PFC 5 INHIBITORS .................................164 

 
 
 

PFC 5(A) Nitrification Inhibitor ................................................................ 164 
PFC 5(B) Denitrification Inhibitor ............................................................ 165 
PFC 5(C) Urease Inhibitor ......................................................................... 165 

  SPECIFIC LABELLING REQUIREMENTS FOR PFC 6 PLANT BIOSTIMULANT ...........167 

 
 

 

 
 

 

 

 

Examples of a label ...................................................................................... 167 
PFC 6(A) Microbial Plant Biostimulant ..................................................... 167 

PFC 6(B) Non-Microbial Plant Biostimulant............................................. 169 

How to label the physical form of the product?........................................ 170 
How to provide the relevant instructions related to the efficacy of the 
product, including soil management practices, chemical fertilisation, 
incompatibility  with  plant  protection  products,  recommended 
spraying  nozzles  size,  sprayer  pressure  and  other  anti-drift 
measures? ..................................................................................................... 170 
How to include a statement regarding the fact that micro-organisms 
may have the potential to provoke sensitizing reactions? ........................ 170 
How to provide the production and expiry date and where to place 
it on the label? .............................................................................................. 170 
Specific instructions for Microbial Biostimulants .................................... 170 

12.  SPECIFIC  LABELLING  REQUIREMENTS  FOR  PFC  7  FERTILISING  PRODUCT 

BLEND ..............................................................................................................................................171 

 
 

Examples of a label ...................................................................................... 171 
How to express labelling requirements for PFC 7? .................................. 179 

ANNEX 7: POLICY OPTIONS ..................................................................................................................181 

126 

 
 
 
 
 
1. 

2. 

3. 

4. 

5. 

6. 

PFC 1 (FERTILISER) ........................................................................................................................181 

PFC 2 (LIMING MATERIAL) ..........................................................................................................197 

PFC 3 (SOIL IMPROVER) ...............................................................................................................202 

PFC 4 (GROWING MEDIUM) .........................................................................................................208 

PFC 5 (INHIBITOR) .........................................................................................................................213 

PFC 6 (PLANT BIOSTIMULANT) ..................................................................................................215 

ANNEX 8: EXAMPLE OF POLICY OPTIONS (PHYICAL LABELS) ...................................................221 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

POLICY OPTION 1 – FULL PHYSICAL LABEL...........................................................................221 

POLICY  OPTION  2A  –  CERTAIN  INFORMATION  MOVES  DIGITALLY  (TEXT  IN 
GREEN MAY BE PROVIDED DIGITALLY) .................................................................................223 

POLICY OPTION2C – MOST OF THE INFORMATION MOVED DIGITALLY (TEXT IN 
GREEN IS ALLOWED TO GO DIGITAL) ......................................................................................224 

POLICY OPTION 2B - PROFESSIONAL USERS - MEASURE 3A (TEXT IN GREEN IS 
ALLOWED TO GO DIGITAL) ........................................................................................................225 

POLICY OPTION 2E  - PROFESSIONAL USERS - MEASURE 5A (TEXT IN GREEN IS 
ALLOWED TO GO DIGITAL) ........................................................................................................226 

POLICY OPTION 2B – NON-PROFESSIONAL USERS - MEASURE 3B (TEXT IN GREEN 
IS ALLOWED TO GO DIGITAL) ....................................................................................................227 

POLICY OPTION 2D – NON-PROFESSIONAL USERS - MEASURE 5B (TEXT IN GREEN 
IS ALLOWED TO GO DIGITAL) ....................................................................................................228 

ANNEX 9: CASE STUDIES .......................................................................................................................231 

1. 

2. 

3. 

CASE STUDY 1: LARGE MANUFACTURER ...............................................................................231 

CASE STUDY 2: MID-SIZE FIRM ..................................................................................................232 

CASE STUDY 3: A MID-SIZE DISTRIBUTOR, IBERIAN BRANCH ..........................................233 

ANNEX 10: TRENDS IN DIGITALISATION...........................................................................................236 

1.  DIGITAL LITERACY AND SKILLS AND INTERNET ACCESS .................................................236 

2.  DIGITAL DIVIDE – DIGITAL SKILLS ..........................................................................................237 

3.  DIGITAL DIVIDE – ACCESS TO THE INTERNET ......................................................................238 

127 

 
 
 
 
 
 
  OVERALL RULES ON LABELLING IN THE CORE TEXT OF THE FPR  

  What does mandatory labelling information cover?  

Labelling requirements 

Articles 6 and 8:  name, registered trade 
name  or  registered  trademark  and  the 
postal address of manufacturer/ importer, 
as well as a type number, batch number 
or 
the 
other 
fertilising 
identification  of 
product 

the  EU 

allowing 

element 

Annex III 
General 
requirements 

and 

specific 

labelling 

Article  11:  “repackaged  by”/”packaged 
by”  +  name,  registered  trade  name  or 
registered 
the  postal 
trademark  and 
address 

Articles  17  and  18:  CE  marking  and 
identification number of the notified body 
(if applicable) 
  These are mandatory requirements. 
  For  manufacturers,  the  words  ‘produced  by’  can  be  applied  on  a  voluntary  basis 

before the requirement of Article 6(6).  

  For packers, it is possible to add the “id code” provided by the national authority in 
addition to the requirements of Article 11. The number of the notified body has to 
be put  on the labels  only  for EU  fertilising  products  having  had their conformity 
assessed through Module A1 and Module D1 as provided in Annex IV to the FPR. 

 

Is it possible to provide voluntary information on the label? Where could this 
voluntary information appear? 

Yes, it is possible to provide voluntary information other than that defined in the Regulation 
(for  example,  the  FPR  lays  down  rules  to  label  “poor  in  chloride”  as  a  voluntary 
information).  In  accordance  with  point  8  in  Part  I  of  Annex  III  to  the  FPR,  voluntary 
information shall, among other things, not mislead the end user and shall relate to verifiable 
factors. 

 

Is it possible to put information on the packaging, outside the label (i.e. batch n°, 
CE mark, notified body’s number, quantity)?  

The label should not be interpreted as a strict physical unit. What needs to be covered by a 
label is all the mandatory information that has to be affixed on or to accompany the EU 
fertilising product.  

 

In  case  of  a  product  with  packaging,  the  labelling  information  can  appear  on  the 
package itself and/or a document affixed to the package. 

  For  a  bulk  product,  the  labelling  information  is  included  in  an  accompanying 

document or a leaflet.  

128 

 
 
 
 
Therefore,  if  the  practice  of  the  economic  operators  is  to  affix  the  batch  number,  the 
quantity,  the  CE  mark  or  any  other  mandatory  information  on  the  package,  it  fulfils  the 
requirements of the FPR.  

 

Is there a minimal/maximal size for the label/the font? Is there a proportional 
size to respect?  

The regulation does not establish any rules related to the size for the label/the font. It is up 
to the manufacturer to decide which size of the label to use, and ensure that information is 
clear, understandable, legible and intelligible. 

 

In what language(s) should a label be written? 

Each Member State decides what language has to be applied for its national market.   

Some Member States accept a written and signed agreement from a customer dealing with 
products for professional use which would accept to receive a product labelled in another 
language  than  the  official  one(s)  for  that  Member  State  (for  example,  in  English).  The 
economic operator is advised to verify with the Member State in which a product is placed 
on the market whether such an agreement is acceptable. The national authorities competent 
for fertilising products are listed at: 

https://ec.europa.eu/docsroom/documents/35205  

  GENERAL LABELLING REQUIREMENTS IN ANNEX III OF THE FPR  

 

How to write the designation of the claimed function?  

The designation of the claimed function has to be written with the objective of supplying 
end users and market surveillance authorities with a sufficient level of information, without 
misleading them. A manufacturer can reduce the length of the designation of a product to 
the minimum necessary of the respective sub-category as long as the above is fulfilled. If 
this  approach  is  applied,  the  PFC  index  corresponding  to  the  respective  sub-category  as 
listed in Part I of Annex I to the FPR must be indicated. 

Therefore, taking into consideration the above, the following examples could be used:  

First option: it is possible to use the full name designation related to the product function 
as written in Part I of Annex I for PFCs 1 to 6.   

For example:  
  Compound inorganic micronutrient fertiliser 
  Compound  solid  inorganic  macronutrient  ammonium  nitrate  fertiliser  of  high 

nitrogen content 

  Liquid organo-mineral fertiliser 

Second option: it is possible to use the PFC index (with the letters in upper or lower case 
as applicable) + a shortened designation.  

129 

 
 
 
The following table shows some examples:  

Full name designation 

index  + 

PFC 
designation 

shortened 

Condition 

Compound 
micronutrient fertiliser 

Inorganic 

PFC  1(C)(II)(b)  –  Mineral 
micronutrient fertiliser 

Compound  solid  inorganic 
macronutrient 
ammonium 
nitrate 
fertiliser  of  high 
nitrogen content 

1(C)(I)(a)(ii)(A) 
fertiliser 

– 
PFC 
Mineral 
with 
ammonium  nitrate  of  high 
nitrogen content 

Shortened  designation 
is only applicable if the 
conditions in point 4 in 
PFC  1  in  Part  II  of 
Annex III are fulfilled 

Shortened  designation 
is only applicable if the 
conditions in point 4 in 
PFC  1  in  Part  II  of 
Annex III are fulfilled 

Liquid 
fertiliser 

organo-mineral 

PFC  1(B)(II)  –  Organo-
mineral fertiliser 

N.a. 

Any  function  of  a  fertilising  product  can  be  claimed  only  when  a  successful  conformity 
assessment  has  proven  such  function,  including  for  products  for  which  more  than  one 
function is claimed (see point 2 in Part I of Annex III). More details are given under sub-
section 2.8.  

 

How to express the quantity of the EU fertilising product? 

Except  for  growing  medium,  the  regulation  does  not  lay  down  specific  rules  on  the 
expression of the quantity. Thus, the quantity can be expressed in mass (t, kg or g) or volume 
(m3, L or mL). It is recommended to only use units from the ‘International System of Units’.  

It is recommended to express the quantity by net mass for a solid fertilising product, and by 
net mass and/or volume for a liquid fertilising product.  

For  growing  medium,  special  requirements  are  set  in  PFC  4  in  Part  II  of  Annex  III.  On 
voluntary basis the quantity can be indicated by additional measurements to those required. 

 

How to provide information on the general application rates?  

As  fertilisation  recommendations  may  be  crop,  site,  soil  or  climate  specific,  it  may  be 
justified  for  manufacturers  and  other  economic  operators  to  use  a  relatively  general 
recommendation for the application rate, including maximum levels of application.  

A  manufacturer  can  choose  to  adapt  the  information  regarding  the  application  rate 
depending on the end user. A distinction could be made between the following categories:  

  Consumer use (i.e. private households, week-end gardeners),  
  Professional use (i.e. public domain, farmers),  
 

Industrial use (i.e. use of substances as such or in preparation at industrial 
site, Business-to-Business).  

130 

 
 
 
Following  the  above-mentioned  distinction,  it  is  recommended  for  economic  operators 
wanting  to  follow  this  approach  to  adapt  the  information  regarding  application  rates  as 
follows:  

  Consumer use market: detailed information  concerning the  application rates per 

crop should be shown.  

  Professional  use  market:  the  label  should  show  general  application  rates  and  a 
reference sentence such as ‘Contact Company X or company’s X distributor for 
more specific recommendations’. 
Industrial market: the label should state a reference sentence (for example): ‘This 
product is not intended for direct application/use without further processing.’   

 

In addition, it is suggested to add a sentence inviting farmers to follow good fertilisation 
practices:  

‘These product application rates are recommendations.  We recommend to the farmers to 
seek counsel from their adviser to adjust the recommendations to their particular situation 
and to avoid over-fertilisation.’ 

Or  

‘Farmers are encouraged to avoid nutrient losses and to take official recommendations into 
account while drawing fertilisation plans.’ 

Note:  it  is  possible  to  provide  voluntary  information  in  addition  to  the  mandatory 
requirements. For example, it is possible for an economic operator to sell a product to an 
industrial customer with the label prepared for a professional customer. 

 

How to provide information on storage conditions? 

It is under the responsibility of the manufacturers to define the storage conditions according 
to their knowledge of the product and based on good practices. The key objective should be 
to store the product without losing the quality and guaranteed content of the product under 
safe conditions. Pictograms reflecting good practices can be used as long as they are clear 
and not misleading.  

Information about storage conditions may cover among others the following aspects: 

• 
• 
• 
• 
• 
• 

Storage period 
Storage environment (open/roof/closed; covered; dry etc.) 
Storage temperature/moisture 
Stacking 
Incompatibility with other materials 
“Please  also  refer  to  information  provided  in  Material  Safety  Data  Sheet 
(MSDS)” (if it is provided).  

  What does the functionality period of products containing a polymer belonging 

to CMC 9 mean?  

The functionality period of a polymer belonging to ‘Component Material Category (CMC) 
9: Polymers other than nutrient polymers’ may be decided by the manufacturer. It defines 
both  how  rapidly  the  polymer  must  degrade  and  how  frequent  applications  the  use 

131 

 
 
instructions may provide for. If the claimed functionality period is short, the use instructions 
may provide for frequent application, but then the actual biodegradation should also be fast. 
By contrast, if the claimed functionality period is longer, the biodegradation may be slower, 
but then the application frequency in the use instructions must also be longer, since point 
1(f) of Part I of Annex III stipulates that the period between two applications must be at 
least as long as the claimed functionality period i.e. re-application during the functionality 
period is not allowed. 

A general sentence can be added on the label. If considered useful, a pictogram identifying 
the maximum duration of the functionality period can be added, as suggested below. The 
pictogram should be completed by a text such as the below recommendations. In the second 
example, where the functionality period is expressed as a range, it is important that the user 
instructions preventing re-application refers to the longest possible period covered by the 
range. 

 “Re-application  during  the  functionality  period  is  not  allowed.  Contact  company  or 
company’s distributor for more specific recommendations. 

www.website.com .” 

“Re-application  after  less  than  8  weeks  is  not  allowed.  Contact  company  or  company’s 
distributor for more specific recommendations. 

www.website.com .” 

In  addition,  if  the  product  contains  a  polymer  with  the  purpose  of  binding  material,  a 
sentence informing the user that the product cannot be in contact with the soil is required.  

 

How to provide the information on risk management? 

In  case  of  products  classified  under  Regulation  (EC)  No  1272/2008  of  the  European 
Parliament  and  of  the  Council  of  16  December  2008  on  classification,  labelling  and 
packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 
1999/45/EC,  and  amending  Regulation  (EC)  No  1907/2006170  (the  “CLP  Regulation”), 
additional  labelling  requirements  must  be  respected.  For  more  information,  refer  to 
subsection 2.10.  

170 OJ L 353, 31.12.2008, p. 1–1355.  

132 

 
 
 
 
                                                 
In other cases, it is the responsibility of the manufacturer to supply pertinent information 
enabling to manage risks. Pictograms (except CLP hazard pictograms if the product is not 
classified) can be used as long as they are clear and not misleading. 

A generic sentence such as ‘To avoid risks to human health and the environment, please 
comply with the recommended use instructions of this fertilising product’ can be used. 

According to points 4, 5 and 6 in Part I of Annex III to FPR, in the following specific cases, 
add the sentences mentioned below: 

 

 

 

Where the EU fertilising product contains derived products in the meaning of the 
animal by-products regulation, except manure,  
‘Farmed animals shall not be fed, either directly or by grazing, with herbage from 
land  to  which  the  product  has  been  applied  unless  the  cutting  or  grazing  takes 
place after the expiry of a waiting period of at least 21 days’. 
Where the EU fertilising product contains ricin,  
‘Hazardous to animals in case of ingestion’. 
Where the EU fertilising product contains unprocessed or processed cocoa shells,  
‘Toxic to dogs and cats’. 

  What does ‘ingredients’ mean and how to label them?  

Ingredients  should  be  considered  as  any  kind  of  material(s)  (such  as  raw  materials, 
substances, mixtures, bulky volume-building components, etc.) intentionally used for/added 
to  the  fertilising  product  during  manufacturing,  or  substances  intentionally  obtained  by 
chemical reaction within the production process of the product. In some cases, ingredients 
may contain impurities, which should be excluded from the list of ingredients. 

For materials obtained by chemical reaction, only the reaction product must be declared (for 
example, ammonium nitrate, urea) and not the precursors.  

In accordance with the FPR, all ingredients above 5 % by product weight shall be provided 
in descending order by the percentage of the dry weight. 

Further to the obligation of declaring all ingredients above 5 % by product weight, economic 
operators may decide to label ingredients that are below 5 % by product weight. When doing 
so, and in order to  avoid confusing mandatory  and voluntary labelling, these ingredients 
should be listed as additional information and not in the section of “ingredients”, where only 
ingredients above 5 % by product weight are expected to be referenced.   

According to the FPR, there is no labelling obligation to declare the actual percentage of 
each ingredient in the final formulation of the fertilising product. 

For  substances  and  mixtures  covered  by  the  CLP  Regulation,  the  identification  has  to 
comply with all the requirements of this Regulation. Hence, for a mixture, its trade name 
and the identity of the substances contributing to the classification according to Article 18(3) 
of the CLP Regulation have to be given in the list of ingredients.    

For  natural  materials,  it  is  possible  to  use  mineral  names  (for  example,  Sylvinite, 
Langbeinite)  in  addition  to  the  names  used  in  accordance  with  Article  18  of  the  CLP 

133 

 
 
Regulation, and the corresponding identification number of the material (CAS number or 
EC number) if available. 

To avoid very long lists on the label itself, it is recommended to describe the CMCs of the 
ingredients by using a footnote or a shortened CMC reference.  

→  Example for an organo-mineral fertiliser:  

  CMC by footnote  

Cocoa  shell1,  Feather  meal2,  Superphosphate  concd.3  CAS  n°  65996-95-4,  Potassium 
chloride3  CAS  n°7447-40-7,  Magnesium  oxide3  CAS  n°1309-48-4,  Castor  cake1,  Bone 
meal2, Urea3 CAS n° 57-13-6 

With:  1  Plants,  plant  parts  or  plant  extracts;  2  Derived  products  within  the  meaning  of 
Regulation (EC) No 1069/2009; 3 Virgin material substances and mixtures. 

  Shorten CMC reference 

Cocoa shell (CMC 2: Plants, plant parts or plant extracts), Feather meal (CMC 10: Derived 
products within the meaning of Regulation (EC) No 1069/2009), Superphosphate concd. 
CAS n° 65996-95-4 (CMC1: Virgin material substances and mixtures), Potassium chloride 
CAS n°7447-40-7 (CMC 1), Magnesium oxide CAS n°1309-48-4 (CMC 1), Castor cake 
(CMC 2), Bone meal (CMC 10), Urea CAS n° 57-13-6 (CMC 1) 

In  the  specific  case  of  fertilising  products  containing  composts  and/or  digestate,  it  is 
recommended to complete the list of ingredients with the raw materials used.  

→  Example:  

  Compost CMC 3 (Green-Compost) 

  Digestate CMC 5 (Dried digestate from manure, energy crops and bio-waste) 
or  Digestate  CMC  5  (Solid  fraction  digestate  from  energy  crops  and  bio-
waste from plant origin) 

 

How to label the function of products with two or more functions? 

The label must bear the designations as indicated in Annex I to the FPR corresponding to 
the  product’s  claimed  functions.  Only  the  designations  of  PFC  for  which  there  is  a 
successful conformity assessment shall be claimed. In that case, the manufacturer is free to 
choose the order of appearance of the different (2 or more) designations on the label. These 
functions can be separated by a dash or a word such as “and” or “with”. 

→  Examples:  

  Straight solid inorganic macronutrient fertiliser – Liming material 

  Straight solid inorganic macronutrient fertiliser with Liming material 

  Straight solid inorganic macronutrient fertiliser and Liming material 

134 

 
 
If  the  product  is  a  PFC  7,  and  a  combination  of  a  PFC  6(A)  and  PFC  6(B),  the  general 
recommendations described above apply. 

The mentioning of PFCs index numbers is not mandatory, see for more details sub-section 
2.1. 

 

Is it possible to use different wording for the requirements in points 4, 5, 6 and 
9 in Part I of Annex III? 

Rewording the requirements in points 4, 5 and 6 in Part I of Annex III is not allowed by the 
FPR.  

For point 9 in Part I of Annex III, a similar wording to ‘low in chloride’ may be used. . 

 

Is  it  possible  to  use  pictograms  based  on  good  practices?  How  to  manage  the 
interaction with the CLP Regulation?  

It  is  possible,  on  a  voluntary  basis,  to  inform  the  user  on  storage  conditions  or 
management  of  effects  on  health  and  environment  with  pictograms  based  on  good 
practices, even if the product is not under the scope of the CLP Regulation.  

If  the  CLP  Regulation  applies,  the  label  of  the  product  must  bear  all  the  labelling 
requirements  set  by  it  (hazard  pictograms,  signal  words,  hazard  and  precautionary 
statements,  Unique  Formula  Identifier  when  applicable,  additional  requirements  for 
consumer  use  and  so  on),  including  storage  conditions  and  managements  of  risks. 
Additional information (ex.: pictograms on good practices) could be labelled in accordance 
with  Article  25  of  the  CLP  Regulation.  They  must  not  replace,  deflect  or  contradict  the 
mandatory labelling elements requested by the CLP Regulation. 

In case of use of pictograms, it is important to avoid double labelling in accordance with 
Article 25 of the CLP Regulation.  

→ Example:  

 

In which cases can the manufacturer express the nutrient content in elemental 
form? 

The manufacturer can express the nutrient content requested by the FPR in elemental form 
instead or in addition to the oxidised form in accordance with the conversion factors defined 
in  point  10  in  Part  I  of  Annex  III.  For  more  information,  see  section  3  of  this  guidance 
document. 

135 

     
 
 
 

How to refer to the organic matter instead of organic carbon? 

The information requested by the FPR may refer to organic matter instead of, or in addition 
to organic carbon (Corg), in accordance with the following conversion factor:  

organic carbon (Corg) = organic matter × 0, 56 

If both are used, the organic matter can be put beside to organic carbon (Corg) into brackets, 
or in the voluntary information section. 

136 

 
 
 
 
 

Example for general labelling requirements and visual appearance 

A detailed label frame including all PFCs and references to the FPR labelling requirements 
is provided in the Annex to this guidance document.  

  SPECIFIC LABELLING REQUIREMENTS FOR PFC 1 FERTILISER  

 

Is it necessary to label the content of all nutrients present in a fertiliser?  

In  accordance  with  point  1  in  PFC  1:  Fertiliser  in  Part  II  of  Annex  III,  the  nutrients 
declaration is  a voluntary  declaration and the manufacturers decide which nutrients  they 
want to declare – as long as the requirements in relation to the minimum quantity specified 
in Annex I are met, except for:  

-  Nitrogen (N) or phosphorus pentoxide (P2O5) which have to be indicated as soon as 

they are above 0,5% by mass (for more details see sub-section 3.3), 

137 

 CE marking + identification-no of notified body PFC designation  Declaration of content / parameters to be adapted according to the specificities of the product (Nutrients for PFC 1, content for each PFC, physical data for PFC 1, Plant biostimulant specifications for PFC 6, Complementary Statements…)  Content of N & P2O5 if above 0,5 % for Fertiliser (Separate from nutrient declaration)  List of ingredients Instructions for use  Recommended storage conditions  Information on Safety and Environment  Other information (Optional information, under conditions)  Production date / expiry date  Type number / Batch number  Quantity  Contact details   
 
 
 
-  Micronutrients present in the minimum content specified in Annex I, which shall be 
declared  if  they  are  intentionally  added  to  an  inorganic  or  an  organo-mineral 
fertiliser. 

If a nutrient is declared, all the FPR requirements in relation to the nutrient declaration have 
to be met. 

  When the regulation does not define minimum content for secondary nutrients 
(PFC 1 (A) and PFC 1 (B)), how to label the content of these nutrients?  

It is under the responsibility of the manufacturer to declare content of secondary nutrients, 
taking into account the tolerances which must be applied to them. 

  When  the  content  of  nitrogen  (N)  or  phosphorus  pentoxide  (P2O5)  has  to  be 
indicated as it is above 0,5 % by mass, how should this information be provided? 

The indication of the content of nitrogen (N) or phosphorus pentoxide (P2O5) can be a range 
of values and is shown as part of the label just below the nutrient declaration, and clearly 
separated by a line or by another labelling information. See the label frame provided as an 
example  sub-section  2.13  of  this  guidance  document.  A  generic  sentence  such  as  “the 
product contains…” can be used to provide this indication. 

 

Can the term ‘mineral’ be used instead of or in addition to the term ‘inorganic’ 
in the designation of the product? Where should the term ‘mineral’ be labelled?  

Yes, it is possible to replace the term ‘inorganic’ with ‘mineral’ for the fertiliser that belongs 
to  PFC 1(C) as  long  as the conditions  stated in  point 4 in  PFC 1:  Fertiliser in  Part  II of 
Annex III to the FPR are fulfilled. If so, in order to comply with point 1(a) of Part I in Annex 
III, the manufacturer has to add the PFC index of the respective sub-category to which the 
product belongs (i.e. PFC 1 (C) (I) (a) (ii)).  

→  Example:  

  Mineral Macronutrient Fertiliser (PFC 1 (C)(I)(a)(i)) 
  Mineral Macronutrient Fertiliser - PFC 1 (C)(I)(a)(i) 
  PFC 1 (C)(I)(a)(i): Mineral Macronutrient Fertiliser 

 

Does ammoniacal nitrogen (NH3) refer to ammonium nitrogen (NH4
1?  

+) for PFC 

Yes. 

138 

 
 
 
 
  SPECIFIC LABELLING REQUIREMENTS FOR PFC 1(A) ORGANIC FERTILISER 

 

Example of a label  

NAME OF THE PRODUCT 

SOLID ORGANIC FERTILISER NPK Ca-Mg 4,5-5-1,5 (1.5-2) 

Declared nutrient contents by mass: 
4,5 % Total Nitrogen (N) 

4,0 % Organic nitrogen (Norg) from animal and vegetal origin, of which 2 % from 

manure0,5 % Ammoniacal nitrogen   
5,0 % Total phosphorus pentoxide (P2O5) 
1,5 % Total potassium oxide (K2O) 
1,5 % Water soluble calcium oxide (CaO) 
2,0 % Water soluble magnesium oxide (MgO) 

29 % Organic carbon (Corg) 
75 % Dry matter 
6,4 Corg/Ntot 

Ingredients: feather meal (CMC 10: Derived products within the meaning of Regulation 
(EC) No 1069/2009), castor cake (CMC 2: Plant, plant parts and plant extracts), bone meal 
(CMC 10), cocoa shells (CMC 2) 
Instruction of use  
Target plant 1:  
Target plant 2:  
Target plant 3:  
… 
Contact  company  or  company’s  distributor  for  more  specific  recommendations. 
www.website.com 
Recommended storage conditions: 
Store in a dry and aired place.  

Rate – application time – frequency  
Rate – application time – frequency  
Rate – application time – frequency  

Information on safety and environment: 
Wash the hands after use. Do not breathe dusts. 
Farmed animals shall not be fed, either directly or by grazing, with herbage from land to 
which the product has been applied unless the cutting or grazing takes place after the expiry 
of a waiting period of at least 21 days  
Hazardous to animals in case of ingestion - Toxic to dogs and cats 
Additional information:  
Can be used in organic farming according to the current European legislation.  
Poor 
Organic matter: 51,7 % 

chloride 

in 

139 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
  
Net weight: 25 kg.           PELLETS               Production date: 12/03/2019

Notified body n°: XX XX XX XX 
ENTREPRISE S.A.S – Address. 
Tel: XX XX XX XX XX – Fax: XX XX XX XX XX 
Email – website. 

Type number, batch number or other element allowing product identification 

 

How to declare organic nitrogen and the origin of organic matter?  

It is under the responsibility of the manufacturer to provide pertinent information on the 
origin  of  the  organic  matter  in  an  organic  fertiliser.  He  or  she  is  also  responsible  for 
providing any relevant information necessary to manage risks to the environment. For the 
sake of the user’s compliance with the Nitrates Directive, the declaration of organic nitrogen 
should therefore at least mention: 

- 

- 

- 

‘X % organic nitrogen from animal origin, of which Y % from manure’ if the product 
contains only animal raw material providing organic nitrogen; 
‘X % organic nitrogen from vegetal origin’ if the product contains only vegetal raw 
material providing organic nitrogen; 
‘X % organic nitrogen from animal and vegetal origin, of which Y % from manure’ 
if the product is a mix of animal and vegetal raw material providing organic nitrogen. 

 

At  which  precision  level  should  mandatory  information  for  PFC  1(A)  be 
declared? 

This sub-section is particularly relevant for information elements such as the organic carbon 
and the dry matter content.  
The manufacturer is free to define the precision level for the above-mentioned information 
which is most pertinent for the user. For organic carbon content and dry matter content, it 
is recommended not to go beyond one decimal, as going beyond would not be in accordance 
with the precision of current analytical methods. 

 

Should ammoniacal nitrogen be declared even if it is not present in the product? 

Ammoniacal nitrogen has to be declared only if it is present in the final product.  

 

Is it possible to declare organic matter instead of organic carbon? 

In accordance with point 11 in Part I of Annex III, it is possible to refer to the organic matter 
instead of or in addition to the organic carbon (Corg). It is important to respect the following 
conversion factor:  

Corg = organic matter × 0,56 

140 

 
 
 
 
 
 
If both are used, the organic matter can be put next to organic carbon (Corg) into brackets, 
or in the voluntary information section. 

  Where to include the information related to the date of production? 

The production date is the date on which the product manufacturing process is completed. 
It is up to the manufacturer to determine the date on which the manufacturing of the product 
is completed. In case, because of the manufacturing or storage system, the exact production 
date is not known to the manufacturer, the date of production can be understood as the date 
when the product is packed. The exact location of the production date on the label/packaging 
can vary depending on what suits best the product concerned, as long as all the information 
appears on the label. Thus, it is possible to use so called tracing, i.e. a reference to one single 
place on the label where the date is indicated. It is up to the economic operator to use the 
format of his/her choice to indicate the date (letters or numbers) as long as it is a full date 
(day/month/year). This information has been put in black colour on the label example.  

  SPECIFIC LABELLING REQUIREMENTS FOR PFC 1(B) ORGANO-MINERAL FERTILISER 

 

Example of a label  

NAME OF THE PRODUCT 
SOLID ORGANO-MINERAL FERTILISER NPK Ca-Mg 6-5-6 (1.5-2) 

Declared nutrient contents by mass: 
6,0 % Total Nitrogen (N) 

2,0% Organic nitrogen (Norg) of animal and vegetal origin, of which 2 % from manure 

3,0% Ammoniacal nitrogen 
1,0% Urea nitrogen 

5,0 % Total phosphorus pentoxide (P2O5) 
4,0 % Water soluble phosphorus pentoxide (P2O5) 
1,0 % Phosphorus pentoxide (P2O5) soluble in neutral ammonium citrate 
1,5 % Total potassium oxide (K2O) 
1,5 % Water soluble potassium oxide (K2O)   
1,5 % Water soluble calcium oxide (CaO) 
2,0 % Water soluble  magnesium oxide (MgO) 
0,05 % Water soluble Copper (Cu) from sulphate  
0,50 % Water soluble Iron (Fe) chelated by EDTA 
22,4 % Organic carbon (Corg)  
92 % Dry matter 
Ingredients : cocoa shells (CMC 2: Plants, plant parts or plant extracts), castor cake (CMC 2), meat 
meal (CMC 10: Derived products within the meaning of Regulation (EC) No 1069/2009), natural 
phosphate (CMC 1: Virgin material substances and mixtures), mono-ammonic phosphate CAS n° 
7722-76-1 (CMC 1), potassium sulphate CAS n° 778-80-5 (CMC 1) 
Instructions of use  
Target plant 1:  
Target plant 2:  

Rate – application time – frequency  
Rate – application time – frequency  

141 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
Target plant 3:  

Rate – application time – frequency 

To be used only where there is a recognized need. Do not exceed the application rate. 
Contact company or company’s distributor for more specific recommendations. www.website.com 
Recommended storage conditions: 
Store in a dry and aired place.  
Information on safety and environment: 
CLP pictograms, UFI codes and transport classification pictograms must be added when applicable. 
Farmed animals shall not be fed, either directly or by grazing, with herbage from land to which the product has been applied unless 
the cutting or grazing takes place after the expiry of a waiting period of at least 21 days  
Hazardous to animals in case of ingestion - Toxic to dogs and cats 
This  fertiliser  contains  urea,  which  can  release  ammonia  and  have  an  impact  on  air  quality. 
Depending on local conditions, appropriate remediation measures must be taken. 
Additional information:  
Organic matter: 40%  
Low Cadmium content – Poor in Chloride 
Net weight 25 kg.           PELLETS         

Notified body n°: XX XX XX XX 
ENTREPRISE S.A.S – Address. 
Tel: XX XX XX XX XX – Fax: XX XX XX XX XX 
Email – website 
Batch n°: XX XX XX XX 

 

How to declare organic nitrogen and the origin of organic matter? 

It is under the responsibility of the manufacturer to provide pertinent information on the 
origin of organic matter in the Organo-mineral Fertiliser. He or she is also responsible for 
providing any relevant information necessary to manage risks to the environment. For the 
sake of the user’s compliance with the Nitrates Directive, the declaration of organic nitrogen 
should therefore at least mention: 

- 

- 

- 

‘X % organic nitrogen, from animal origin, of which Y % from manure’ if the product 
contains only animal raw material providing organic nitrogen; 
‘X % organic nitrogen, from vegetal origin’ if the product contains only vegetal raw 
material providing organic nitrogen; 
‘X % organic nitrogen, from animal and vegetal origin, of which Y % from manure’ 
if the product is a mix of animal and vegetal raw material providing organic nitrogen. 

 

Should  a  specific  form  of  nitrogen  (N),  phosphorus  (P)  or  potassium  (K)  be 
declared even if it is not present in the product? 

Specific  forms  or  solubility  of  nutrients  have  to  be  declared  only  if  present  in  the  final 
product.  

 

How to provide pertinent information about the possible air quality impacts of 
the release of ammonia from the fertiliser use, and an invitation to users to apply 

142 

 
 
 
  
 
 
 
 
appropriate  remediation  measures  when  urea  (CH4N2O)  is  present  in  the 
product? 

The label  of all fertilising products   marketed according to  the  FPR and containing urea 
must refer to the potential air quality impact due to the release of ammonia from the fertiliser 
use  and  invite  users  to  take  appropriate  remediation  measures.  This  statement  should  be 
preferably close to or underneath the nutrient declaration, or in the section concerning safety 
and environment.  

The statement may be of general nature, for example, along the following lines: 

‘This fertiliser contains urea, which can release ammonia and have an impact on air quality. 
Depending on local conditions, appropriate remediation measures must be taken.’ 

Or ‘This fertiliser contains urea, which can release ammonia and have an impact on air 
quality. Depending on local conditions, appropriate remediation measures must be taken. 
The  manufacturer  of  this  fertiliser  has  already  taken  the  remediation  measure  of 
incorporating a urease inhibitor.’ 

 

How to declare the ‘low cadmium content’? 

When the product displays a cadmium content equal to or lower than 20 mg/kg phosphorus 
pentoxide (P2O5), it is possible to declare that the product is low in cadmium content. It is 
recommended to put this statement in ‘the Additional information’ part of the label. There 
are various ways to declare this statement, either by text and/or using a pictogram. Should 
a pictogram be used, it should contain the chemical symbol Cd, but no symbols representing 
other product features. 

Figure: Example of Low Cadmium pictogram 

 

At what precision can micronutrients be declared? 

The manufacturer should respect the decimals as referred in the FPR for micronutrients. For 
more details, see sub-section 6.1.2. 

143 

 
 
 
  
 
 
 
 
  SPECIFIC LABELLING REQUIREMENTS FOR PFC 1(C) INORGANIC FERTILISER  

 

 

PFC 1 (C)(I): Inorganic Macronutrient Fertiliser 

Example of a label 

Proposal  for  nutrient  declaration  for  an 
micronutrients including link to mineral fertiliser statement:  

inorganic  macronutrient  fertiliser  with 

SOLID INORGANIC MACRONUTRIENT FERTILISER 
NPK (Ca, Mg, S) mineral fertiliser with micro-nutrients, 16-9-12 (+3 +2 +15) / 16-3,9-
10 (+2,1 +1,2 +6) 
Or  
MINERAL FERTILISER (PFC 1(C)(I)(a)) 
NPK (Ca, Mg, S) fertiliser with micro-nutrients, 16-9-12 (+3 +2 +15) / 16-3,9-10 (+2,1 
+1,2 +6) 
Or  
MINERAL FERTILISER (PFC 1(C)(I)(a)) 
NPK (Ca, Mg, S) complex171 fertiliser with micro-nutrients, 16-9-12 (+3 +2 +15) / 16-
3,9-10 (+2,1 +1,2 +6) 
Or  
MINERAL FERTILISER (PFC 1(C)(I)(a))  
NPK (Ca, Mg, S) complex fertiliser 16-9-12 (+3 +2 +15) / 16-3,9-10 (+2,1 +1,2 +6) 
with micro-nutrients 
16 %       TOTAL NITROGEN (N) 
                7,0 % Nitric Nitrogen 
                9,0 % ammoniacal nitrogen 
  9 %       TOTAL PHOSPHORUS PENTOXIDE (P2O5) (= 3,9 % P)  
                6,7 % water soluble phosphorus pentoxide (P2O5) (= 2,9 % P). 
                9,0 % phosphorus pentoxide (P2O5) soluble in neutral ammonium citrate (= 3,9 

% P). 

12 %       POTASSIUM OXIDE (K2O) (= 10 % K) Water soluble. 
  3 %       TOTAL CALCIUM OXIDE (CaO) (= 2,1 % Ca) 
                1,0 % CaO (= 0,7 % Ca) water soluble 
  2 %       TOTAL MAGNESIUM OXIDE (MgO) (= 1,2 % Mg) 
15 %       SULPHUR TRIOXIDE (SO3) (= 6 % S) Water soluble. 

0,01   % Boron (B), as sodium salt, water soluble  

171  Only applicable for those fertilisers that fit the definition of complex (each physical unit contains all the 
declared nutrients in their declared content). 

144 

 
 
 
                                                 
 
0,020 % Total Copper (Cu), complexed by HGA, 0,015% water soluble  
0,30   % Total Iron (Fe) 
                0,26 % as sulphate, soluble in water; 0,04 % chelated by EDTA 
0,05   % Manganese (Mn), as sulphate, water soluble  
0,006 % Total Molybdenum (Mo), as sodium salt 
                0,003 % water soluble  
0,008 % Total Zinc (Zn), as oxide 

To be used only where there is a recognised need. Do not exceed the application rate. 

Remark: this label example is only showing part of the mandatory labelling (applicable to 
this  category  of  fertiliser).  For  an  example  in  full  detail,  please  see  the  example  in  sub-
section 6.5.  

 

What  is  the  minimum  number  of  decimals  that  should  be  indicated  on  the 
label? 

The FPR is not providing guidance on the number of decimals to be used. The author of the 
label should keep it legible for the user and therefore it is suggested: 

• 

• 

To limit it to zero or one decimal for the declaration of macronutrients (N-P-K-
Ca-Mg-Na-S), except for those for which minimum declarable quantity values 
are already defined with one or more decimals in Annex I to the FPR.  
To respect,  as much as  possible, the number of decimals  as referred to  in  the 
Regulation for the declaration of micronutrients. If needed (for example, to meet 
tolerance  limits)  one  additional  decimal,  as  referred  to  in  the  FPR  for 
micronutrients can be used.   

 

How to provide pertinent information about the possible air quality impacts of 
the  release  of  ammonia  from  the  fertiliser  use,  and  an  invitation  to  users  to 
apply appropriate remediation measures when urea (CH4N2O) is present in the 
product? 

The label of all fertilising products marketed according to the FPR and containing urea must 
refer to the potential air quality impact due to the release of ammonia from the fertiliser use 
and  invite  users  to  take  appropriate  remediation  measures.  This  statement  should  be 
preferably close to or underneath the nutrient declaration, or in the section concerning safety 
and environment.  

The statement may be of general nature, for example, along the following lines: 

‘This fertiliser contains urea, which can release ammonia and have an impact on air quality. 
Depending on local conditions, appropriate remediation measures must be taken.’ 

 or  

145 

 
 
 
 
 
‘This fertiliser contains urea, which can release ammonia and have an impact on air quality. 
Depending  on  local  conditions,  appropriate  remediation  measures  must  be  taken.  The 
manufacturer of this fertiliser has already taken the remediation measure of incorporating 
a urease inhibitor.’ 

 

How to declare the “low cadmium content”?  

When the product displays a cadmium content equal to or lower than 20 mg/kg phosphorus 
pentoxide (P2O5), it is possible to declare that the product is low in cadmium content. It is 
recommended to put this statement in the ’Additional information’ part of the label. There 
are various ways to declare this statement, either by text and/or using a pictogram. Should 
a pictogram be used, it should contain the chemical symbol Cd, but no symbols representing 
other product features. 

Figure: Example of Low Cadmium pictogram 

 

 

PFC 1(C)(I)(a): Solid Inorganic Macronutrient Fertiliser 

Example of a label 

Please refer to example provided under sub-section 7.1. 

 

Example for granulometry 

See below in sub-section in paragraph 6.2.3. 

 

In what way can granulometry and physical unit be indicated on the label? Is 
it allowed to reference more than one sieve when indicating the granulometry 
of a product?  

The determined sieve(s) is(are) to be defined by the manufacturer depending on the product. 

The  information  in  relation  to  granulometry  and  physical  unit  should  be  provided, 
preferably grouped on the label. Additional information concerning granulometry can be 
voluntarily given by the manufacturer, as long as it is compliant with the FPR.  

Moreover, it should be allowed to indicate more than one form of the physical unit, as for 
stability reasons, for example, a combination of more than one physical unit can be present.  

Example:  Mandatory  granulometry  and  physical  unit  label  descriptions  for  an  inorganic 
solid macronutrient fertiliser:  

Granulometry: Powder. 90 % of the product passes through sieve of 1mm. 

Granulometry: Granules. X % of the product passes through sieve of Y mm. 

146 

 
 
 
  
 
 
 
 
Example:  Alternative  granulometry  and  physical  unit  label  descriptions  for  an  inorganic 
solid macronutrient fertiliser to be compliant to requirements in point 2 of PFC 1(C)(I)(a) 
in Part II of Annex III: 

Granulometry: Combination of powder and prills. X % of the product passes through sieve of 1 mm and the 
remaining Y % through sieve of Z mm. Granulometry: Granules. 95 % of the product has a granular size 
between 2,0 – 4,5 mm. 

 

How is a “coating” defined?  

The specific information concerning coated fertilisers should preferably be grouped as much 
as  possible  on  the  label.  Information  concerning  coated  fertilisers  that  must  be  provided 
refers to: 

  The functionality period of the coated fertilizer; 
  The type of coating agent as referred to in point 4 of PFC 1(C)(I)(a) in Part II of 

Annex III.  

 

How to declare the functionality period of the coated fertiliser?  

See recommendations above under Section 2.5 

 

How to declare the type of coating agent?  

With respect to the coated solid inorganic fertilisers the brand name of the coating agent(s) 
and the percentage of fertiliser coated by each agent should be indicated. Within the FPR, 
coating agent is a polymer or sulphur controlling water penetration into nutrient particles 
and thus the release of nutrients. This information should be followed by the markings: ‘The 
rate  of  nutrient  releases  can  vary  according  to  the  temperature  of  the  substrate.  An 
adjustment  of  fertilisation  may  be  necessary.’  In  case  the  fertiliser  is  coated  or  partially 
coated with sulphur as a coating agent the first marking should be rephrased as: ‘The rate 
of nutrient release can vary according to the temperature of the substrate and the biological 
activity’.   

→  Example covering all mandatory information as regards coated fertilisers:  

An X-Y months product. 100 % of the product is coated with BRANDNAME® coating. 
The rate of nutrient release can vary according to the temperature of the substrate. An 
adjustment of fertilisation may be necessary. Re-application after less than Y months is 
not allowed.  

 

How to draw the label for mined fertilisers?  

Mining is the extraction of valuable minerals or other geological materials from the earth, 
usually from an orebody, lode, vein, seam, reef or placer deposit. These deposits are natural 
sources  of  the  minerals,  which  are  used  as  inorganic  fertilisers  themselves  or  as  raw 
materials to produce (some) inorganic fertilisers.  

Due  to  the  natural  origin  of  those  mined  fertilisers  the  content  of  naturally  occurring 
impurities (minerals not important for the product) can vary in the product during the mining 
process. However, as impurities should not be included in the list of ingredients (see sub-
section 2.7 of this guidance document for more information), only the mined product (mined 

147 

 
 
 
mineral) itself should be seen as an ingredient and thus indicated in the ingredient section 
on the label. 

Some mined fertilisers have been known by their mineralogical name for years. Therefore, 
when listing them in the ingredients section on the label, it is possible to use mineral names 
(for  example,    Sylvinite,  Langbeinite)  in  addition  to  the  names  used  in  accordance  with 
Article  18  of  the  CLP  Regulation,  and  the  corresponding  identification  number  of  the 
material (CAS number or EC number) if available. 

Example:  List  of  ingredients  on  the  label  for  mined  fertiliser  (naturally  occurring 
langbeinite):Ingredients: Langbeinite (Potassium magnesium sulphate) CAS 14977-37-
8 (Virgin material substances and mixtures) 

 

PFC 1(C)(I)(b): Liquid Inorganic Macronutrient Fertiliser 

Proposal  for  nutrient  declaration  for  a  liquid  inorganic  macronutrient  fertiliser  with 
micronutrients including link to mineral fertiliser statement: 

LIQUID INORGANIC MACRONUTRIENT FERTILISER 
NPK (Ca, Mg, S) fertiliser with micronutrients, 16-9-12 (+3 +2 +15) / 16-3,9-10 (+2,1 +1,2 +6) 
Or  
LIQUID MINERAL FERTILISER (PFC 1(C)(I)(b)) 
NPK (Ca, Mg, S) fertiliser with micronutrients, 16-9-12 (+3 +2 +15) / 16-3,9-10 (+2,1 +1,2 +6) 
Or  
LIQUID MINERAL FERTILISER (PFC 1(C)(I)(b))  
NPK (Ca, Mg, S) fertiliser 16-9-12 (+3 +2 +15) / 16-3,9-10 (+2,1 +1,2 +6) with micronutrients 

16 %       TOTAL NITROGEN (N) 
                7,0 % nitric nitrogen 
                9,0 % ammoniacal nitrogen 
  9 %       TOTAL PHOSPHORUS PENTOXIDE (P2O5) (=3,9% P)  
                9,0 % water soluble phosphorus pentoxide (P2O5) (=3,9% P). 
12 %       POTASSIUM OXIDE (K2O) (=10 % K) water soluble. 
  3 %       CALCIUM OXIDE (CaO) (=2,1 % Ca) Water soluble. 
  2 %       MAGNESIUM OXIDE (MgO) (=1,2 % Mg) Water soluble 
15 %       SULPHUR TRIOXIDE (SO3) (=6 % S) Water soluble. 

Micronutrients are completely water soluble : 0,01 % Boron (B), as sodium salt ; 0,020 % Copper 
(Cu), complexed by HGA ;  0,30 %  Iron (Fe), 0,26 % as sulphate, 0,04 % chelated by EDTA ; 
0,05 % Manganese (Mn), as sulphate ; 0,006 % Molybdenum (Mo), as sodium salt; 0,008 % Zinc 
(Zn), as sulphate 

To be used only where there is a recognised need. Do not exceed the application rate. 

148 

 
 
 
 
 
Remark: this label example is only showing part of the mandatory labelling (applicable to 
this  category  of  fertiliser).  For  an  example  in  full  detail,  please  see  the  example  in  sub-
section 6.5.  

 

 

 PFC 1(C)(II): Inorganic Micronutrient Fertiliser 

PFC 1(C)(II)(a): Straight Inorganic Micronutrient Fertiliser 

Proposal for nutrient declaration for a straight inorganic micronutrient fertiliser including 
link to mineral fertiliser statement: 

STRAIGHT INORGANIC MICRONUTRIENT FERTILISER 
mineral micronutrient fertiliser 
Or 
STRAIGHT INORGANIC MICRONUTRIENT FERTILISER 
mineral micronutrient fertiliser, 5.3 % Fe 
Or  
MINERAL MICRONUTRIENT FERTILISER (PFC 1(C)(II)(a) 

5,3 % Total Iron (Fe)   
                2,2 % as sulphate, water soluble  
                3,1 % chelated by EDTA, 1,5 % water soluble  

To be used only where there is a recognised need. Do not exceed the application rate. 

Remark: this label example is only showing part of the mandatory labelling (applicable to 
this  category  of  fertiliser).  For  an  example  in  full  detail,  please  see  the  example  in  sub-
section 6.5.  

 

PFC 1(C)(II)(b): Compound Inorganic Micronutrient Fertiliser 

Proposal for nutrient declaration for a compound inorganic micronutrient fertiliser including 
link to mineral fertiliser statement:  

COMPOUND INORGANIC MICRONUTRIENT FERTILISER 
mineral micronutrient fertiliser in solution 
Or 
COMPOUND INORGANIC MICRONUTRIENT FERTILISER 
mineral micronutrient fertiliser in solution, 0,2 % B, 0,52 % Cu, 2,3 % Fe, 0,5 % Mn, 
0,06 % Mo, 0,8 % Zn 
Or  
MINERAL MICRONUTRIENT FERTILISER IN SOLUTION (PFC 1(C)(II)(b) 

149 

 
 
 
 
 
 
 
Micronutrients are completely water soluble: 
0,2 % Boron (B), as sodium salt ; 0,52 % Copper (Cu), as sulphate, complexed by HGA 
; 2,30 % Iron (Fe), 1,04 % chelated by EDTA ; 0,5 % Manganese (Mn), as sulphate ; 0,06 
% Molybdenum (Mo), as sodium salt; 0,8 % Zinc (Zn), as sulphate. 
or 
0,2   % Boron (B), as sodium salt, water soluble  
0,52 % Copper (Cu), complexed by HGA, water soluble  
2,30 % Iron (Fe) as sulphate; 1,04 % chelated by EDTA water soluble  
0,5   % Manganese (Mn), as sulphate, water soluble  
0,06 % Molybdenum (Mo) as sodium salt, water soluble  
0,8 % Zinc (Zn), as sulphate, water soluble  

To be used only where there is a recognised need. Do not exceed the application rate. 

Remark: this label example is only showing part of the mandatory labelling (applicable to 
this  category  of  fertiliser).  For  an  example  in  full  detail,  please  see  the  example  in  sub-
section 6.5.  

 

PFC 1(C) complete label example  

Notified body n° if applicable  

                                  NAME 

OF 

THE 

PRODUCT                          

MINERAL FERTILISER - PFC 1(C)(I)(a) 

NPK (Ca, Mg, S) fertiliser with micro-nutrients, 16-9-12 (+3 +2 +15) / 16-3,9-10 (+2,1 +1,2 +6) 

16 %       TOTAL NITROGEN (N) 

                7,0 % nitric nitrogen 

                7,0 % ammoniacal nitrogen 

                2,0 % urea nitrogen 

150 

 
 
 
 
 
 
 
 
  9 %       TOTAL PHOSPHORUS PENTOXIDE (P2O5) (= 3,9 % P)  

                6,7 % water soluble phosphorus pentoxide (P2O5) (= 2,9 % P). 

                9,0 % phosphorus pentoxide (P2O5) soluble in neutral ammonium citrate (= 3,9 % P). 

12 %       POTASSIUM OXIDE (K2O) (= 10 % K) Water soluble. 

  3 %       TOTAL CALCIUM OXIDE (CaO) (= 2,1 % Ca) 

                1,0 % CaO (= 0,7 % Ca) water soluble. 

  2 %       TOTAL MAGNESIUM OXIDE (MgO) (= 1,2 % Mg) 

15 %       SULPHUR TRIOXIDE (SO3) (= 6 % S) Water soluble. 

Poor in Chloride 

0,01   % Boron (B), as sodium salt, water soluble  

0,020 % Total Copper (Cu), complexed by HGA 

                0,015% water soluble  

0,30   % Total Iron (Fe), 0,26 % as sulphate, water soluble ; 0,04 % chelated by EDTA 

0,05   % Manganese (Mn), as sulphate, water soluble  

0,006 % Total Molybdenum (Mo), as sodium salt 

                0,003 % water soluble  

0,008 % Total Zinc (Zn), as oxide 

Granulometry:          Granules. 95% of the product passes through sieve of 4,5 mm.  

Ingredients:     Ammonium Nitrate1 (CAS n° 6484-52-2), Potassium Nitrate1 (CAS n° 7757-79-1), 

                          Ammonium Phosphate1 (CAS n° 7722-76-1), Magnesium Sulphate1 (CAS n° 7487-

88-9),    Coating X9  

                                1Virgin material substances and mixtures; 9 Polymers other than nutrient polymers.  

Instructions and application rates: 

Light feeding  Normal feeding  Heavy feeding  This  product  with  a 

regular  and 
continuous release pattern is ideal for fast 
growing conifers and Evergreens. 

Container nursery stock   1 – 2 g/l 

1,5 – 2,5 g/l 

2,5 – 3,5 g/l 

Pot Plants 

1 – 2 g/l 

2 – 3 g/l 

3 – 4 g/l 

Bedding plants / annuals  1 – 2 g/l 

2 – 3 g/l 

3 – 4 g/l 

To be used only where there is a recognized need. Do not exceed the application rate 

Attention: The above-mentioned recommended rates are based on unfertilised substrates. Please be 
aware that these are general  recommendations. Specific situations such as use in  tunnels, green-

151 

 
 
 
houses,  or  specific  climate  conditions  require  adjustments.  This  product  is  not  recommended  for 
dibbling and/or autumn/winter potting. 100 % of the product is coated with coating X®. The rate of 
nutrient release can vary according to the temperature of the substrate. An adjustment of fertilisation 
may be necessary. Re-application after less than 4 months is not allowed.  

Contact company or company’s distributor for more specific recommendations. www.website.com 

Storage conditions: Store the product in a dry and well-ventilated space out of direct sunlight.  

Storage temperature 0-40 °C. Partly used or damaged bags should be closed well. 

Information on safety and environment: 

Product classified under the Regulation EC n°1272/2008. Please refer to the corresponding labelling on the packaging. 

CLP  pictograms,  UFI  codes  and  transport  classification  pictograms  must  be  added  when 
applicable.     

This  fertiliser  contains  urea,  which  can  release  ammonia  and  have  an  impact  on  air  quality. 
Depending on local conditions, appropriate remediation measures must be taken.                                                  

General information:  

FOR PROFESSIONAL USE ONLY. 

Company details 

Product n°: ………..                                                        Batch n°: ………..   

152 

 
 
 
                                                                                                                                                 
  
 
 
 
 
  SPECIFIC LABELLING REQUIREMENTS FOR PFC 2 LIMING MATERIAL  

 

Examples of a label 

Example 1 

153 

 
 
 
[NAME OF THE PRODUCT] 

LIMING MATERIAL 

Product specific labelling requirements: 

Neutralising value:  54 (equivalent CaO) 
Granulometry:         90 % by mass passing through a sieve of 1,0 mm 
Total CaO:                 51 % by mass 
Total MgO:                  2 % by mass 
Reactivity:                 73% (hydrochloric acid test) 
Ingredients: 

Limestone a CAS no  471-34-1 

With a virgin material substances and mixtures 

Instructions of use:  

1500 to 4000 kg/ha to increase pH from 6 to 6,5 in clay silty soils - Refer to soil analysis to calculate 
quantity and frequency to apply. Apply uniformly and incorporate in the soil. 

Contact company or company’s distributor for more specific recommendations. www.website.com 

Storage conditions: 

Keep in a dry place. Avoid exposure to air or moisture over prolonged periods. 

Information on safety and environment: 

No special requirements 

Additional information:  

-  2003/2003 labelling: G.1.(a) Natural limestone – standard quality 

- Authorized to be used in organic farming according to the current EU legislation 

25 kg net     

Notified body n° : xxxx (if applicable) 

Manufacturer’s name 

Manufacturer’s registered trade name or trade mark 

Postal address                                         

Type number, batch number or other element allowing product identification 

 Example 2: 

154 

 
 
 
 
 
 
 

Regulatory reference, explanation and voluntary additions 

LIMING MATERIAL 

Product specific labelling requirements: 
Neutralising value:     94 (equivalent CaO) 
Granulometry:            5 % by mass passing through a sieve of 1,0 mm 
Total CaO:                  93 % by mass 
Total MgO:                 1 % by mass 
Ingredients: 
Burnt lime a  CAS no  305-78-8  
With a virgin material substances and mixtures 
Instructions for use: 
500 to 1000 kg/ha to increase pH from 6 to 6,5 in clay silty soils - Refer to soil analysis to calculate 
quantity and frequency to apply. Apply uniformly on humid soil and incorporate in the soil 
Contact company or company’s distributor for more specific recommendations. www.website.com 
Storage conditions: 
Keep in a dry place. Avoid exposure to air or moisture over prolonged periods. 
Information on safety and environment: 
CLP pictograms, transport classification pictograms and UFI codes must be added when applicable. 
Additional information:  
- EN 14069:2017: Burnt lime – premium quality– screened 
- Granulometry by dry sieving : 2 to 8 mm - 98 % by mass passing through a sieve of 8 mm and 4 % 
by mass passing through a sieve of 0,4 mm 
25 kg net            

Production date : XX/XX/XXXX 

Notified body n° : xxxx (if applicable) 
Manufacturer’s name 
Manufacturer’s registered trade name or trade mark 
Postal address                                         
Type number, batch number or other element allowing product identification 

Examples of voluntary additions on the label in section ‘additional information’:  

  Labelling according to Regulation (EC) No 2003/2003 or standard EN 14069 
Since 2014, liming materials have been labelled according to the criteria set in Regulation 
(EC)  No  2003/2003  as  amended  by  Regulation  (EU)  No  463/2013172.  To  ensure  some 
consistency in the labelling information and to provide users with familiar information, a 
reference  to  the  labelling  according  to  this  regulation  may  be  provided  in  the  section 
‘additional information’ on a voluntary basis.  

172 Commission Regulation (EU) No 463/2013 of 17 May 2013 amending Regulation (EC) No 2003/2003 of 
the European Parliament and of the Council relating to fertilisers for the purposes of adapting Annexes I, II 
and IV thereto to technical progress, OJ L 134, 18.5.2013, p. 1–14. 

155 

 
 
                                                 
 
 
 
 
 
Alternatively, a reference to product denomination according to standard EN 14069173 can 
be placed voluntary on the label of the liming material. This European Standard specifies 
the  standard  and  premium  requirements  of  products  of  natural  origin  and  products  from 
industrial processes to be used as liming materials in agriculture.  

  Reference to reactivity  

Annex  III  to  the  FPR  requires  declaration  of  reactivity  and  method  of  determination  of 
reactivity.  

In existing commercial practices, three methods are recognized for the determination of the 
reactivity of liming materials: 

a)  Determination  of  the  reactivity  of  carbonate  and  silicate  liming  materials  with 

hydrochloric acid; 

b)  Determination of product effect by soil incubation; 

c)  Determination of the reactivity by automatic titration method with citric acid. 

Annex  I  to  the  FPR  sets  minimum  requirements  for  reactivity  with  reference  to  the 
hydrochloric acid or incubation tests. In some EU Member States the reactivity of liming 
materials is measured using another test: the citric acid method (as currently described in 
standard EN 16357174). However, this method is not included in Annex I to the FPR and, 
therefore, cannot be used to prove compliance with the requirements therein.  

The  specific  labelling  requirements  for  PFC  2  in  Annex  III  do  not  specify  a  mandatory 
reference  to  one  of  two  tests  that  are  included  in  Annex  I.  For  labelling  purposes,  the 
manufacturer therefore has the possibility to choose among any available measuring tests 
the one that suits the product best and is of highest value to the user, and declare accordingly 
the reactivity of his/her product. 

  SPECIFIC LABELLING REQUIREMENT FOR PFC 3 SOIL IMPROVER 

 

 

PFC 3(A) Organic Soil Improver 

Examples of a label 

Example 1: for the labelling of a 100% peat organic soil improver to be used for instance as 
an amendment for blueberry cultivation:  

173 EN 14069:2017, Liming materials – Denominations, specifications and labelling 
174 EN 16357:2013, Carbonate  liming  materials  - Determination of reactivity  -  Automatic titration  method 
with citric acid 

156 

 
 
 
 
                                                 
[NAME OF THE PRODUCT] 
ORGANIC SOIL IMPROVER 
Product specific labelling requirements:  
Dry matter (DM):              45 % by mass 
pH:                                     4,5 175 
Electrical conductivity:     5 mS/m 176  
Organic carbon (Corg):     54 % mass  
Organic nitrogen (Norg):  1 % mass, organic matter of peat origin    
Corg/N ratio:                     54 
Ingredients: peata 
With a virgin material substances and mixtures 
Instructions for use: 
The function of this organic soil improver is to improve the physical properties and structure of the 
soil to which it is added and worked in to. In particular, the water holding capacity of sandy soils is 
improved. Heavy, clayey soils are improved by increasing the air capacity. The application rate is 5 
to 20 litres/m² of soil depending on how sandy or clayey a soil is. 
Contact company or company’s distributor for more specific recommendations. www.website.com 
Storage conditions: 
To avoid product’s changes, protect from exposure to weather i.e. sunlight, precipitation and drying 
out. 
Information on safety and environment: 
Do not eat. Avoid wrong and not intended application. 
Additional information:  
RPP certified (with visible logo) 
RHP certified (with visible logo) 
50 L net       

Production date: DD/MM/YYYY, see side of package177  

Notified body n° : xxxx (if applicable) 

Manufacturer’s name 
Manufacturer’s registered trade name or trade mark 
Postal address        
  Importer’s name 
Importer’s registered trade name or trade mark 
Importer’s postal address                                                   
Type number, batch number or other element allowing product identification178 

175 Recommendation to refer to the EN method. 
176 Recommendation to refer to the EN method. 

157 

 
 
                                                 
 
177 Production date, type number, batch number or other element allowing product identification (Article 6(5) 
of the FPR) can be printed separately on the package. 
178 Production date, type number, batch number or other element allowing product identification (Article 6(5) 
of the FPR) can be printed separately on the package. 

158 

 
 
 
                                                 
Example 2 for labelling of a bulky compost soil improver: 

[NAME OF THE PRODUCT] 
ORGANIC SOIL IMPROVER 
Product specific labelling requirements: 
Dry matter (DM):            40 % by mass 
pH:                                   8,5179 
Electrical conductivity:    220 mS/m 180  
Organic carbon (Corg):      15,7 % mass or 
Organic nitrogen (Norg):   1 % mass, organic matter of compost origin 
Corg/N ratio:                      16 
Indications of nutrient content: 

Total Nitrogen (N)                     1,1 % 
Total Phosphorus pentoxide (P205)   0,6 % 
Total Potassium oxide (K20)      1,0 % 

Ingredients:   Compost a 
With a CMC 3: Compost  
Instructions for use:  
Organic soil improver can be used for every soil type for maintaining and improving the physical or 
chemical properties, the structure and biological activity of the soil. The content of organic matter, 
nutrients and the pH-value acts on soil fertility conditions. 
For application on arable land (wheat, sugar beet, rapes, maize, field vegetables etc.) the individual 
conditions of soil type, climate and production have to be considered. When calculating the nutrient 
demand of the crops, the available nutrient load of the organic soil improver has to be taken into 
account.  
In  landscaping  organic  soil  improvers  are  used  for  plant  beds  or  in  planting  holes  for  shrubs, 
perennials and woody plants. 
Further applications of organic soil improver are mulching, top dressing and component for growing 
media.  
National Regulations and national official recommendations for application must be complied with. 
Contact company or company’s distributor for more specific recommendations. www.website.com 
Storage conditions: 
Outdoor storage of bulk material has to be in a way to avoid material erosion to water bodies. 
Information on safety and environment: 
Material use only in accordance with application recommendations.  
Clean hands after material use. 
40 tonnes  Production  date:  DD/MM/YYYY,  see  accompanying 
documents (bulk transport) 181  

179 Recommendation to refer to the EN method 
180 Recommendation to refer to the EN method 

181 Production date, type number, batch number or other element allowing product identification (Article 6.5 

of FPR). 

159 

 
 
                                                 
 
 
 
 
Notified body n°: xxxx 

Manufacturer’s name 
Manufacturer’s registered trade name or trademark 
Postal address        
  Importer’s name 
Importer’s registered trade name or trademark 
Importer’s postal address                                                   
Type number, batch number or other element allowing product identification182  

 

Regulatory reference, explanation and voluntary additions 

National regulations, both on the use of the product or on compliance with the requirements 
for placing it on the national market, may be added on a voluntary basis as long as they are 
clear to the user and separated from the FPR label. 

Possible statements about compliance with the FPR include: 

‘The product fulfils the requirements set for PFC 3(A) (Organic Soil Improver) in Part II of 
Annex I and for CMC 3 (Compost) in Part II of Annex II to the FPR.’  

‘The product fulfils the requirements of Regulation (EC) No 834/2007 (Organic production 
and labelling of organic products).’  

‘The  production  process  and  the  product  has  been  externally  controlled  according  to 
Module D1: Quality Assurance of the Production Process as described in Part II of Annex 
IV to the FPR.’  

182 Production date, type number, batch number or other element allowing product identification (Article 6(5) 
of the FPR).  

160 

 
 
 
 
                                                 
 

 

PFC 3(B) Inorganic Soil Improver 

Example of a label 

[NAME OF THE PRODUCT] 
INORGANIC SOIL IMPROVER 

Product specific labelling requirements:  
Dry matter content: 90% by mass 
Ingredients:    
Bentonite  a CAS no  1302-78-9 
With a virgin material substances and mixtures 
Instructions for use: 
Spread onto surface of soil and mix into top. 
Contact company or company’s distributor for more specific recommendations. www.website.com 
Storage conditions: 
Keep in a dry place. Avoid exposure to air or moisture over prolonged periods. 
Information on safety and environment: 
No special requirements 
Additional information:  
Authorized to be used in organic farming according to the current EU legislation 
40 tonnes            

Production date : DD/MM/YYYY 

Notified body n° : xxxx (if applicable) 
Manufacturer’s name 
Manufacturer’s registered trade name or trade mark 
Postal address        

  Importer’s name 
Importer’s registered trade name or trade mark 
Importer’s postal address                                                   
Type number, batch number or other element allowing product identification183  

 

Regulatory reference, explanation and voluntary additions 

Annex  I of the FPR does not  provide  efficiency  criteria or parameters for inorganic soil 
improvers, meaning that no product specific labelling requirements need to be provided. In 
the absence of harmonized criteria and their corresponding standards, product suppliers are 
invited  to  provide  information  on  efficiency  of  the  product  in  the  section  ‘additional 
information’. 

183 Production date, type number, batch number or other element allowing product identification (Article 6(5) 
of the FPR) can be printed separately on the package. 

161 

 
 
 
                                                 
 
 
 
 
  SPECIFIC LABELLING REQUIREMENTS FOR PFC 4 GROWING MEDIUM 

A PFC 4 product consists of a single bulky (volume-building) component or a mix of bulky 
(volume-building)  components  (for  example.  peat,  wood  fibers,  coconut  coir,  compost, 
expanded perlite).  

 

Examples of a label 

Example 1: the labelling of a mineral wool growing medium.  

[NAME OF THE PRODUCT] 
GROWING MEDIUM  

Products should be stored dry. If possible also store in original packaging.  
Incompatible materials: None. 
Packaging  material:  Products  are  packed  in  polyethylene  film  or  cardboard  on  wooden 

Product specific labelling requirements  
pH (H2O):    6.0                                 
Instructions for use: 
Recommended use: Usable in hydroponic cultivation systems to grow fruity vegetables and other 
crops   
Storage conditions: 
• 
• 
• 
pallets. 
Information on safety and environment 
This product can be used safely by growers for growing plants. Please follow the instructions in the 
Safe Use Instructions Sheet. 
Ingredients:    
Stone wool  CAS no° 65997-17-3a , binding material  CAS no° 9003-35-4a 
With  a virgin material substances and mixtures 
Special instructions for products containing binding materials 
Please do not use in contact with soil 
In collaboration with the manufacturer, please make sure of a sound disposal of the products 
after end of use 
Additional information:  

1 PCE, Length 133 cm x width 15 cm x height 10 cm 
Production date : DD/MM/YYYY[1]

Notified body n° : xxxx 
Manufacturer’s name 
Manufacturer’s registered trade name or trademark 
Postal address        

Importer’s name 
Importer’s registered trade name or trademark 

162 

 
 
  
  
  
 
  
 
  
Importer’s postal address 
Type number, batch number or other element allowing product identification  

Example 2: growing medium consisting of only bulky (volume-building) components 

A  growing  medium  cannot  contain  fertilisers,  liming  materials,  plant  biostimulants  or 
products belonging to other PFCs. This type of growing medium (PFC 4) is placed on the 
market for exceptional applications where the addition of products belonging to other PFCs 
is  not  essential.  It  will  also  serve  as  the  basis  for  Fertilising  Product  Blends  (PFC  7) 
containing other PFCs.  Any Growing Medium (PFC 4) blended with one or more products 
of any other PFC (for example fertiliser, liming material, plant biostimulants) is a PFC 7. 
An example is given in section 12 on the labelling requirements for PFC 7.  

163 

 
 
 
 
 
[NAME OF THE PRODUCT] 
GROWING MEDIUM  
(without addition of other PFCs) 

Product specific labelling requirements:  
Electrical conductivity:             50 mS/m 184 
pH (H2O):                                  5 185 
Phosphorus pentoxide (P2O5):   25 mg/l (CAT-soluble) 

Ingredients:    
Peata, wood fibresb, green compostc 
With a virgin material substances and mixtures,  b plants, plant parts or plant extracts , c compost  
Instructions for use: 
Growing  medium  without  any  other  blended  fertilisers,  liming  materials,  biostimulants  or  other 
products,  used  as  a  plain  PFC  4  forming  the  basis  for  other  fertilising  product  blends  (PFC7). 
Contact company or company’s distributor for more specific recommendations. www.website.com 
Storage conditions: 
To avoid product changes protect from exposure to weather i.e. sunlight, precipitation and drying 
out, store dry. 
Information on safety and environment: 
Do not eat. Avoid wrong and not intended application. 
Additional information:  
RPP certified (with visible logo). 
RHP certified (with visible logo) 
RAL certified  
70 L net            Production date : DD/MM/YYYY186 

Notified body n° : xxxx 

Manufacturer’s name 
Manufacturer’s registered trade name or trademark 

Postal address        

  Importer’s name 
Importer’s registered trade name or trademark 

Importer’s postal address                                                   

184 It’s allowed to refer to the harmonised standard or other technical specification used. 

185 It’s allowed to refer to the harmonised standard or other technical specification used. 
186 Production date, type number, batch number or other element allowing product identification (Article 6.5) 
are usually printed separately on the package. 

164 

 
 
                                                 
 
 
 
 
 
Type number, batch number or other element allowing product identification187  

Remark: This label frame is given as a general, indicative example of the label structure.  

 

Regulatory reference, explanation and voluntary additions 

National regulations may be added on a voluntary basis as long as they are clear to the user 
and separated from the FPR label. 

  SPECIFIC 

LABELLING 

REQUIREMENTS 

FOR 

PFC 

5 

INHIBITORS 

 

PFC 5(A) Nitrification Inhibitor 

Example: 

Notified body n° (if applicable)  

                                  NAME OF THE PRODUCT          

NITRIFICATION INHIBITOR 
Ingredients:  
Virgin Material Substances and Mixtures: 
3,4-dimethyl-1H-pyrazol phosphate (DMPP, CAS n° : 202842-98-6, EC no 424-640-9) 
Phosphoric acid (CAS n° : 7664-38-2, EC no : 231-633-2)  
Instructions for use: 
The nitrification inhibitor 3,4-dimethyl-1H-pyrazole phosphate (DMPP) can be added to solid and 
liquid fertilisers if at least 50 % of the total nitrogen content of the fertiliser consists of the nitrogen 
forms urea nitrogen and ammonium nitrogen.  
Minimum and maximum DMPP content is 0,8 and 1,6 as a percentage by mass of the total nitrogen 
present as ammoniacal nitrogen and urea nitrogen. 
Contact company or company’s distributor for more specific recommendations. www.website.com 
Storage recommendations: 
Store in dry conditions. For further recommendations. See Section 7 of material safety data sheet. 
Information on safety and environment: 
Product classified under the Regulation EC n°1272/2008 and GHS. Please refer to the corresponding labelling on the packaging. 
CLP  pictograms,  transport  classification  pictograms  and  UFI  codes  must  be  added  when 
applicable.        

General information:  
FOR PROFESSIONAL USE ONLY.                                                                                                                                                                                        

Company details 

187 Production date, type number, batch number or other element allowing product identification (Article 6.5.) 

are usually printed separately on the package. 

165 

 
 
 
  
 
 
 
                                                 
Product n°: ………..                                                        Batch n°: ………..   

 

PFC 5(B) Denitrification Inhibitor 

At the moment no denitrification inhibitors are commercially available on the EU market. 
The  general  label  layout  should  be  similar  to  the  layout  for  a  nitrification  and/or  urease 
inhibitor. 

 

PFC 5(C) Urease Inhibitor 

Example:  

Notified body n° (if applicable)  

                                  NAME OF THE PRODUCT          

UREASE INHIBITOR 
Ingredients:  
Virgin Material Substances and Mixtures:  
N-butylphosphorothioic triamide (NBPT, CAS n°  94317-64-3, EC no: 435-740-7) 
N-propylphosphorothioic triamide (NPPT, CAS n°  916809-14-8, EC no: 618-780-1)  
Polyethyleneimine (CAS no  9002-98-6, EC 618-346-1) 
Propylenglycol (CAS no 57-55-6, EC no  200-338-0) 
Dimethylsulfoxid (CAS no 67-68-5, EC no  200-664-3)  
Instructions for use: 
This  urease  inhibitor  (UI)  “mixture  of  N-butylphosphorothioic  triamide  (NBPT)  and  N-
propylphosphorothioic triamide (NPPT) (ratio 3:1)” can be added to solid and liquid fertilisers if at 
least 50 % of the total nitrogen content of the fertiliser consists of the nitrogen form urea nitrogen.  
Minimum and maximum UI content is 0,02 and 0,3 as a percentage by mass of the total nitrogen 
present as urea nitrogen.  
Contact company or company’s distributor for more specific recommendations. www.website.com 
Storage recommendations: 
Store in dry conditions. For further recommendations. See Section 7 of material safety data sheet. 
Information on safety and environment: 
Product classified under the Regulation EC n°1272/2008 and GHS. Please refer to the corresponding labelling on the packaging. 
CLP  pictograms,  transport  classification  pictograms  and  UFI  codes  must  be  added  when 
applicable.                                                                                                                                              
General information:  
FOR PROFESSIONAL USE ONLY.                                                                                                                                          

Company details 

Product n°: ………..                                                                       Batch n°: 
………..   

166 

 
 
 
 
 
                  
 
 
167 

 
 
 
 
  SPECIFIC LABELLING REQUIREMENTS FOR PFC 6 PLANT BIOSTIMULANT  

Claims   

to 

in 

the 

Refer 
terminology 
specified 
harmonised 
standards 
or 
other technical 
specifications 

 

 

Examples of a label  

PFC 6(A) Microbial Plant Biostimulant 

 [NAME OF THE PRODUCT] 

Notified body n°: xx xx xx xx (if applicable) 

  PFC 6 (A) – Microbial Plant biostimulant 

  Ingredients: 
  CMC 7 – Azotobacter vinelandii AS 80 
  Micro-organism concentration: 1x107 CFU/ml 
  Instructions for use:  

Application 
rates (L/ha) 
1 to 4 

Application 
method 
Soil  applied 
nutrition  or 
via  irrigation 
water 

Application 
stage  
Pre-plant, planting, 
or top dress stage 

Crops 

in 

Refer  to  the 
terminology 
specified 
harmonised 
standards  or 
other 
technical 
specifications  

1 to 4 

Pre-plant, planting, 
or top dress stage 

Soil  applied 
nutrition  or 
via  irrigation 
water 

1 to 4 

standard 
with 
nutrition  or  via 
irrigation 

Pre-plant, planting, 
or top dress stage 

1 to 4  

pre-
the 
From 
planting through to 
mid-vegetative 
stage 

in-
Applied 
furrow  or  with 
soil nutrition as 
well  as  side-
dress/top-dress.  
The 
product 
may  also  be 

168 

value 
may 
repeat 

Application 
number 
High 
crops 
receive 
applications 
every 
1-3 
weeks.  There 
are 
no 
restrictions  on 
the  number  of 
applications per 
crop 
The product can 
be 
applied 
weekly.  There 
are 
no 
restrictions  on 
the  number  of 
applications per 
crop  or  crop 
cycle. 
The product can 
be 
applied 
weekly.  There 
are 
no 
restrictions  on 
the  number  of 
applications per 
crop  or  crop 
cycle. 
There  are  no 
restrictions  on 
the  number  of 
applications per 
crop  or  crop 
cycle. 

 
 
 
 
applied 
irrigation 

via 

  The product can be mixed with the majority of liquid fertilisers, plant nutrition products or plant 
protection products but must not be mixed with any bactericide. The product may also be applied 
with all transplant solutions, dips and watering solutions. 

  It is recommended to perform a compatibility test before applying this product as a mixture. 

SHAKE/AGITATE WELL BEFORE USING. 

  Contact  company  or  company’s  distributor 

for  more 

specific 

recommendations. 

www.website.com 

  Recommended Storage conditions: 
  Keep the product in its original packaging.  Store in a cool, dry place between 2 °C and 48 °C.   Do not 

expose to direct sunlight.  Protect from freezing. 

  Information on Safety and Environment188: 
  EUH 208: Contains Azotobacter vinelandii, micro-organisms may have the potential to provoke 

sensitising reactions 

  P102: Keep out of reach of children 
  P270:  Do not eat, drink or smoke when using this product 
  P280: Wear protective gloves/protective clothing/eye protection/face protection type FFP3 
  Emergency 

contact:   

In case of emergency contact: XX: tel. XX-XX-XX-XX, (24/24, 7/7) 

  Production date: see on the packaging 
   Expiry date: 3 years from production date 

  Type number/Batch number 
  + notified body number (if applicable) 

 5 L          LIQUID               

  ENTREPRISE S.A.S – Address. 
  Tel: XX XX XX XX XX – Fax: XX XX XX 

XX XX 

188 CLP pictograms may be added only if the product is covered by the CLP Regulation. 

169 

 
 
   
 
 
                                                 
 

PFC 6(B) Non-Microbial Plant Biostimulant 

[name of the product] 

Notified body n°: XX XX XX XX (if applicable) 

PFC 6 (B) NON-MICROBIAL PLANT BIOSTIMULANT 
Ingredients: Derived products within the meaning of Regulation (EC) No 1069/2009 (Animal protein hydrolysate) 
Virgin material substances and mixtures (Urea - Diammonium phosphate)  
Instructions for use:  

Claims   

Application 
number 
1 to 3 

Crops 

Application 
rates (L/ha) 
2 to 4 

Application 
method 
Foliar 
pulverization  
Foliar 
pulverization  

Application 
stage  
From 2-4 leaves 
stage 
From 
vegetative 
growth  
Regrowth 
vegetation 

in 

4 to 6 

Refer  to  the 
terminology 
specified 
harmonised 
standards  or 
other 
technical 
specifications 
The product is compatible with many plant protection products. In case of mixture, it is the user responsibility to test the 
mixture before application. Pour last in the tank. 

Refer 
terminology 
specified 
harmonised 
standards 
or 
other technical 
specifications 

Foliar 
pulverization  

5 to 10 

1 to 4 

2 to 5 

the 

in 

to 

Farmed animal must not be fed with herbage, either directly or by grazing, with herbage, from land to which this product 
has been applied unless the cutting or grazing takes place after the expiry of a waiting period which is at least 21 days. 
Contact company or company’s distributor for more specific recommendations. www.website.com 

Recommended storage conditions: 
Store in a dry place (see pictures). 
Information on Safety and Environment 189: 
Wash the hands after use. Do not breathe dusts. 

In case of emergency contact: XX: tel:XX-XX-XX-XX, (24/24, 7/7) 

Additional Information 
Poor in chloride 

This fertiliser contains urea, which can release ammonia and have an impact on air quality. Depending 
on local conditions, appropriate remediation measures must be taken. 

189 CLP pictograms, may be added only if the product is covered by the CLP Regulation. 

170 

 
 
 
 
 
 
 
 
 
 
                                                 
Production date: see on the packaging 

Type number/Batch number 

 Expiry date: 3 years from production date 

+ notified body number (if applicable) 

5 L          LIQUID               

ENTREPRISE S.A.S – Address. 
Tel: XX XX XX XX XX – Fax: XX XX XX XX 
XX 

 

How to label the physical form of the product?  

The physical form (liquid or solid) should be indicated.  

 

How to provide the relevant instructions related to the efficacy of the product, 
including soil management practices, chemical fertilisation, incompatibility with 
plant protection products, recommended spraying nozzles size, sprayer pressure 
and other anti-drift measures?  

The Instructions of use can be provided in a table format, as indicated in the examples in 
sub-section 11.1, including information such as crops, application rate, application method, 
application stage, application number and claims. The claimed effects should correspond to 
the ones indicated in the biostimulant definition, namely:  nutrient use efficiency, tolerance 
to abiotic stress, quality traits, or availability of confined nutrients in the soil or rhizosphere. 
These should preferably be complemented by the claimed effects identified in harmonised 
standards for biostimulants. 

 

How to include a statement regarding the fact that micro-organisms may have 
the potential to provoke sensitizing reactions?  

The label shall contain the following phrase: ‘Micro-organisms may have the potential to 
provoke sensitising reactions’. This phrase should be included within other hazard phrases 
in the label section ‘Information on Safety and Environment’. 

 

How  to  provide  the  production  and  expiry  date  and  where  to  place  it  on  the 
label?  

The production and expiration date should be provided on the label. The determination of 
the product expiry date should be up to the manufacturer. The production and expiry date 
can also be located directly on the package or on a folded leaflet (in case of a bulk product).  

 

Specific instructions for Microbial Biostimulants 

Within the part of the label ‘Declaration of content’ all intentionally added micro-organisms 
shall be indicated. Where the micro-organism should have several strains, the intentionally 
added strains should be indicated. The microorganism concentration is to be expressed as 
the number of active units per volume or weight, or in any other manner that is relevant to 
the micro-organism, for example, colony forming units per gram (cfu/g). 

171 

 
 
 
12.  SPECIFIC LABELLING REQUIREMENTS FOR PFC 7 FERTILISING PRODUCT BLEND 

As  stated  in  the  FPR,  all  the  labelling  requirements  applicable  to  all  component  EU 
fertilising  products  apply  to  the  fertilising  product  blend.  For  a  better  understanding, 
labelling requirements specific to each PFC are identified below by a colour code in the 
labelling examples.  

 

Examples of a label 

The following examples assume that the blending does not lead to a change of nature of 
each of the component of the respective fertilising product blends. 

Example 1: Labelling of a fertilising product blend composed of 2 EU fertilising products 
from the same PFC (an already EU compliant PFC 1 (C) in light blue with another already 
EU compliant PFC 1 (C) in dark blue) 

172 

 
 
173 

 
 
 
 
 
 
 
Example 2: Labelling of a fertilising product blend of 2 claimed functions: mixture of an 
already  EU  compliant  PFC  1  (C)  (inorganic  fertiliser)  in  blue  with  another  already  EU 
compliant PFC 5 (inhibitor) in orange 

174 

 
 
 
 
 
 
 
Example 3: Labelling of a fertilising product blend of 3 claimed functions: PFC 4 (growing 
medium) in red with a PFC 1 (C)(I) (Compound Solid Inorganic Macronutrient Fertiliser) 
in blue and a PFC 2 (liming material) in orange 

As explained in the section 9 , any growing medium blended with one or more other 
PFC (for example fertiliser, liming material, biostimulants) is a fertilising product blend.  

NAME OF THE PRODUCT 

COMPOUND 

GROWING MEDIUM 
with 
MACRONUTRIENT 
MATERIAL 
Content: 

SOLID 
FERTILISER 

INORGANIC 
LIMING 

and 

claimed  
  Designation 
PFC separated by a dash or a word like "and" 
or "with" 

each 

of 

Electrical conductivity (EC):         50 mS/m 
pH (H2O):                                           6.5 
Nitrogen (N):                                200 mg/l CAT-soluble 
Phosphorous pentoxide (P2O5):  30 mg/l CAT-soluble 
Potassium oxide (K2O):               180 mg/l CAT-soluble 

1 kg/m³ compound solid inorganic macronutrient fertiliser NPK 

14-16-18, with  
14.0 % Nitrogen (N) 
             5.5 % Nitrate-N 
             8.5 % Ammoniacal-N 

16.0 % Phosphorous pentoxide (P2O5) 
18.0 % Potassium oxide (K2O) 

fertiliser in granules of which 95% has a granular size between 
2.0 and 4,5 mm 

4 kg/m3 of liming material with : 

Neutralising value:  54 (equivalent CaO) 
Granulometry:         90 % < 1,0 mm 
Total CaO:                 51 % by mass 
Total MgO:                  2 % by mass 
Reactivity:                 73 %  

Declaration of content expressed as amount 
per 
volume 
calculated/adjusted  for  the  final  fertilising 
product blend  

growing 

media 

Ingredients: 

Growing medium (containing peata, wood fibresb and green compostc ) 

with  a virgin  material  substances and mixtures, b Plants,  plant 
parts and plant extracts and c compost  

List  of  EU 
fertilising  products 
composing the blend in decreasing order 
followed  by  the  word    "containing"  or 
with  brackets  [  ]  and    the  list  of 
ingredients  and  CMCs  of  each  EU 
fertilising  product  composing  the  final 
fertilising product blend 

175 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Instructions for use: 

Use this product as soon as possible after purchase for growing 
on of vegetables, e.g. cucumbers, tomatoes, peppers, egg plants. 
Use  this  product  only  for  the  intended  application  and  avoid 
misuse and mixing with other materials. 
Contact the manufacturer or manufacturer’s distributor for more 
specific recommendations. 

Storage conditions: 

Avoid  long  storage  periods.  This  product  consists  of  organic 
materials that by nature may contain saprophytic microbes. To 
avoid product quality alterations (e.g. N-immobilization) due to 
increased microbial activity, store cool and under cover. Protect 
from exposure to weather i.e. sunlight, precipitation and drying 
out. Avoid frost conditions during storage. 

Information on safety and environment: 

To  avoid  risks  to  human  health  and  the  environment,  please 
comply  with  the  recommended  use  instructions  of  this 
fertilising  product.  Do  not  eat.  Avoid  false  and  not  intended 
application.  

Additional information: 

This fertilising product blend is for professional use. It contains 
all  essential  macro  and  micronutrients  as  well  as  a  liming 
material to ensure optimal plant growth for the intended use.  
Contains  1  kg/m³  of  compound  solid  inorganic  macronutrient  fertiliser 
NPK  14-16-18  (containing  ammonium  nitratea    CAS  no  6484-52-2, 
potassium  nitratea  CAS  no  7757-79-1,  ammonium  phosphatea  CAS  no 
7722-76-1, magnesium sulphatea CAS no7487-88-9) 
4  kg/m³  of  liming  materials  (containing  lime  stone  CAS  no 
471-34-1) 

a with virgin material substances and mixtures 

RPP certified 
RHP certified 
RAL certified 

Production date: XX/XX/XXXX 

Type number, batch number or other element allowing product 
identification 
70 L (A12) NET                           

Notified body no. (if applicable) 

Manufacturer’s name 
Manufacturer’s registered trade name or trade mark 
Manufacturer’s postal address 

176 

Information  provided  for 
fertilising product blend 

the  final 

  Production  date  of  the  final  fertilising  

product blend 

The manufacturer is the blender of the final 
fertilising product 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Example  4:  Labelling  of  a  fertilising  product  blend  of  3  claimed  functions:  PFC  1(C) 
(inorganic fertiliser) in blue + PFC 2 (liming material) in orange + PFC 6(B) (non-microbial 
plant biostimulant) in red 

NAME OF THE PRODUCT 

COMPOUND  SOLID  INORGANIC  MACRONUTRIENT  FERTILISER  PK  (S)  14-24  (21)  – 
LIMING MATERIAL WITH NON-MICROBIAL PLANT BIOSTIMULANT  
PK (Ca) (S) 8,4-14,4 (18,5) (12,6) 
Content: 
8,4 %    Total phosphorus pentoxide (P2O5)  
              4,7 % phosphorus pentoxide (P2O5) soluble in formic acid 
14,4 %  Potassium oxide (K2O) water soluble 
30 %     Total calcium oxide (CaO) 
12,6 %  Sulphur trioxide (SO3) water soluble 
18         Neutralising value (equivalent CaO) 

Granules. 95 % of the final product has a granular size between 2,0 – 4 
mm and 1 % passing through a sieve of 1,0 mm  
The product contains: 
20 g / kg of plant biostimulant 
35 % of liming material with a reactivity (hydrochloric acid test) of 50 
Instructions for use: (see guidance document point 3) 
Application 
Application 
method 
stage  
Soil applied  With 

Application 
rates (kg/ha) 
200 to 400 

Application 
number 
1 to 3 

Claims   

Crops 

Field 
crop 

seeding 

Better 
tolerance 
to  abiotic 
stress 

Designation  of 
claimed  
PFC separated by a dash or a word 
like "and" or "with" 

each 

Content  of  nutrients  as  expressed 
final  product  blend 
for 

the 

Declaration 
as 
of 
expressed  for  the  final  fertilising 
product blend 

content 

Granulometry  expressed  for  the 
final fertilising product (PFC 1 C 
and PFC 2 requirements) 

Instructions provided for the final 
fertilising product blend 

Storage conditions: (see guidance document point 3) 
Keep  the  product  in  its  original  packaging.  Store  at  temperature 
between +5 °C and +25 °C  
Information on safety and environment: (see guidance document point 3) 
The product is compatible with many plant protection products. In case of mixture, it 
is the user responsibility to test the mixture before application. Pour last in the tank. 

Recommendations  provided  for 
the final fertilising product. 

Ingredients:  calcium carbonate1 CAS  n° 471-34-1, rock phosphate1 , potassium 
sulfate1 CAS n°7778-80-5 
with 1 Virgin material substances and mixtures  
Additional information:  
Can be used in organic farming according to the current European legislation. 
Plant biostimulant composed of… (not mandatory)  
600 KG NET                             Production date: see on the packaging  
 Expiry date: 3 years after production date 

+ notified body number/s (if applicable) 

  List  of  ingredients  in  decreasing 
order as all ingredients over 5 % are 
identified  for  the  final  fertilising 
product  

Production  date  of 
fertilising product  

the 

final 

Expiry date of the biostimulant 

COMPANY – Address 
Type number, batch number or other element allowing product identification 

The manufacturer is the blender of 
the final fertilising product 

177 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
Example 5: Labelling of a fertilising product blend of 2 claimed functions: PFC 6(B) (non-
microbial plant biostimulant) in red and PFC 1(B) (organic fertiliser) in blue 

178 

 
 
 
 
 
 

How to express labelling requirements for PFC 7?  

As specified in Annex III to the FPR, labelling requirements of all component EU fertilising 
products apply to the fertilising product blend. They shall be expressed in relation to the 
final product. 

If  a  labelling  requirement  applies  to  only  one  component  EU  fertilising  product,  it  also 
applies to final fertilising product blend. In other words, a labelling requirement, which is 
relevant for a component, is also relevant for the entire blend. 

As a general rule, labelling requirements of component EU fertilising products should be 
expressed for the final fertilising product blend.  

If minimum content or concentrations are required for a specific component EU fertilising 
product of a fertilising product blend, they do not apply to the blend. 

→ Example: The nutrient content of a fertilising product blend of which 10 % is a solid 
organic fertiliser with 4 % of total nitrogen (N) and 12% of total potassium oxide (K2O), 
as declared nutrients, will be expressed for the final product blend as such:  

  0,4 % total nitrogen (N) 
  1,2 % total potassium oxide (K2O) 

The minimum content requirement of 1 % of total nitrogen for solid organic fertilisers 
does not apply to the fertilising product blend. 

If a labelling requirement doesn’t provide any useful information when expressed for the 
final fertilising product  blend, or if it is not possible to express it for the final fertilising 
product  blend,  then  it  is  expressed  for  the  specific  component  EU  fertilising  product 
concerned.  In  that  case,  the  percentage  of  the  component  EU  fertilising  product  in  the 
fertilising product blend is indicated. 

→  Example:  The  labelling  of  reactivity  of  a  fertilising  product  blend  containing  a 
liming material would be declared as follow:  

If a labelling requirement is common to several component EU fertilising products, but has 
different ways of expression, both labelling requirements are mentioned on the label of the 
final fertilising product blend and expressed for each PFC respectively. 

→  Example:  Granulometry  can  be  expressed  as  %  by  mass  of  product  passing 
through different sieves (through a 1,0 mm sieve for liming materials and through a 
determined sieve for solid inorganic fertilisers that can be different than 1,0 mm). 
Granulometry for a fertilising product blend containing a liming material and a solid 
inorganic fertiliser could be labelled as follow:  

179 

35 % of liming material with a reactivity (hydrochloric acid test) of 50        
 
 
If an expiry date applies for one component EU fertilising product, it will also apply for the 
final fertilising product blend. The expiration date should be adapted according to the final 
fertilising product blend and cannot be later than the one applicable to the component EU 
fertilising product. 
If this requirement applies to several components of the EU fertilising products, the most 
restrictive date applies. 

If a notification body number is present on one or more component EU fertilising products 
label, it has also to be put on the label of the final fertilising product blend with the reference 
of the component EU fertilising product. 

→ Example: Fertilising product blend composed of EU fertilising product which went 
through Module D1  

Notified body number: 0123 (inhibitor) 

The number of the notified body has to be put on the labels only for fertilising products 
having had their conformity assessed through Module A1 and Module D1 

180 

70 % of liming material with 85 % of product passing through a 1,0 mm sieve    
 
 
 
 
 
 
 
 
1.  PFC 1 (FERTILISER) 

ANNEX 7: POLICY OPTIONS  

Label information 

Policy options 

I
I
I
x
e
n
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Part I, point 1(a) 

Part I, point 1(c) 

Part I, point 1(d) 

designation of the 
PFC 

the quantity of the 
EU 
fertilising 
product, indicated 
by mass or volume 
Other  instructions 
for intended use 

Part I, point 1(d) 

frequency 

r
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(c) 

1 

PFC 
FERTILISER 
INORGANIC 
10 Kg, 1 L 

YES (only 
for certain 
products) 
YES (only 
for certain 
products) 

for 

suitable 
foliar 
application 
apply  once  a 
week 

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IC 

AP 

AP 

181 

 
 
 
 
     
 
 
 
 
 
 
     
 
 
 
 
 
   
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Part I, point 1(d) 

timing 

Part I, point 1(d) 

application rates 

Part I, point 1(d) 

Part I, point 1(e) 

Part I, point 1(e) 

Part I, point 1(e) 

Part I, point 1(e) 

Part I, point 1(f) 

targeted  plants or 
mushrooms 
other 
recommended 
storage conditions 

storage 
conditions-
temperature 

in  Part 

products 
a 

storage 
conditions-
sunlight 
storage 
conditions-
humidity 
for 
containing 
polymer 
belonging  to  CMC 
9 
II  of 
Annex  II,  the time 
period 
following 
use  during  which 
nutrient 
the 
is  being 
release 
controlled  or  the 
water 
retention 
capacity  is  being 
increased 
(the 
‘functionality 
period’) 

YES (only 
for certain 
products) 
YES (only 
for certain 
products) 
NO 

NO 

NO 

NO 

NO 

NO 

apply  during 
growing 
season 
125 
kg/hectar 

leafy 
vegetables 
keep 
the 
in 
products 
the  original 
package 
storing 
temperature 
10-30 
degrees C 
keep  out  of 
direct 
sunlight 
keep  in  a  dry 
space 

functionality 
period 
-  4 
months 

AP 

AP 

AP 

AP 

AP 

AP 

AP 

AE 

182 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Part I, point 1(f) 

NO 

products 
a 

for 
containing 
polymer 
belonging  to  CMC 
II  of 
9 
Annex  II,  tspecial 
use instruction 

in  Part 

Part I, point 1(g) 

risk  management 
measures 

NO 

Part I, point 1(h) 

list 
all 
of 
ingredients  above 
5  %, including  the 
name 
the 
of 
substances 

Part I, point 1(h) 

relevant CMC 

Part I, point 1(h) 

Part I, point 3 

the 

identification 
number  of 
substance 
declare 
presence  of 
substance 
exceeding  MRL 
(maximum 

the 
a 

NO (only 
main 
component
s e.g. 
nutrients 
and 
chelating/c
omplexing 
agents and 
inhibitors 
NO 

only for 
certain 
substances 
NO 

AE 

S 

IC 

yes 

Re-
application 
during 
the 
functionality 
period  is  not 
allowed. 
Contact 
company  or 
company’s 
distributor 
for 
specific 
wash 
your 
hands  after 
use; keep out 
of  reach  of 
children 
cocoa 
shell, 
bone  meal, 
castor  cake, 
bentonite 

more 

CMC 2 (plant, 
plant  parts, 
plant 
extracts) 
CASS  65997-
17-3 

IC 

IC 

yes 

clopyralid 

S 

183 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NO 

0.1 mg/kg 

S 

yes 

Part I, point 3 

Part I, point 3 

residues  limit  for 
food or feed) 

the 
the 

declare 
content  of 
substance 
exceeding MRL 
warning  on  using  the 
product in such a way 
to  avoid  exceeding 
MRL in the crop 

NO 

Part I, point 4 

products  derived  out 
of animal by-products 

NO 

Part I, point 5 

for products with ricin 

NO 

Part I, point 6 

Part I, point 7a 

NO 

NO 

contains 
product 
unprocessed 
or 
processed cocoa shells 
declare  the  presence 
of  manganese  (Mn) 
where 
EU 
fertilising 
product 
contains or consists of 
oxidation 
thermal 

the 

do not use in such 
to 
a  way  as 
the 
exceed 
maximum 
limit 
allowed in food or 
feed 
‘Farmed  animals 
shall  not  be  fed, 
either  directly  or 
by  grazing,  with 
herbage 
from 
land to which the 
product  has  been 
applied unless the 
cutting  or  grazing 
takes  place  after 
the  expiry  of  a 
waiting  period  of 
at least 21 days.’. 
Hazardous 
to 
animals in case of 
ingestion 
Toxic to dogs and 
cats 

S 

S 

S 

S 

S 

184 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EU 

the 

and 
materials 
derivates  or  pyrolysis 
or 
gasification 
materials 
declare the content of 
(Mn) 
manganese 
where 
EU 
fertilising 
product 
contains or consists of 
oxidation 
thermal 
materials 
and 
derivates  or  pyrolysis 
or gasification 
declare  the  presence 
of selenium (Se) where 
the 
fertilising 
product  contains  or 
consists  of  recovered 
high  purity  materials 
or certain by- products 
belonging to CMC 11 
declare the content of 
selenium  (Se)  where 
the 
fertilising 
product  contains  or 
consists of recovered 
declare  the  presence 
of chloride (Cl-) where 
the 
fertilising 
product  contains  or 
consists of recovered 
declare the content of 
(Cl-)  where 
chloride 
the 
fertilising 
product  contains  or 
consists of recovered 

EU 

EU 

EU 

Part I, point 7a 

Part  I,  point  7b*  and 
Article  4  of  Regulation 
on 
and 
safety 
efficiency 
argonomic 
criteria for by-products* 

Part  I,  point  7b*  and 
Article  4  of  Regulation 
on 
and 
safety 
argonomic 
efficiency 
criteria for by-products* 
Part  I,  point  7b*  and 
Article  4  of  Regulation 
on 
and 
safety 
argonomic 
efficiency 
criteria for by-products* 
Part  I,  point  7b*  and 
Article  4  of  Regulation 
on 
and 
safety 
efficiency 
argonomic 
criteria for by-products* 

NO 

S 

yes 

NO 

S 

NO 

NO 

NO 

S 

yes 

S 

S 

YES 

185 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Part  II,  PFC  1(C)(I)(a), 
point 2 

Part  II,  PFC  1(A)  and 
1(B), point 1, d), i) 

Part  II,  PFC  1(A)  and 
1(B), point 1, d), v) 
Part  II,  PFC  1(A),  1(B) 
and 1(C)(I), point 1, (b) 

Part  II,  PFC  1(A),  1(B) 
and 1(C)(I), point 1, a) 

of 

shall 

the 
organic 
(organic 

The granulometry of a 
solid 
inorganic 
macronutrient 
fertiliser 
be 
indicated,  expressed 
as  %  by  mass  of  the 
product 
passing 
through  a  determined 
sieve. 
declaration  of 
origin 
matter 
nitrogen is declared) 
content  of  organic 
carbon 
Declaration  of  the 
of 
presence 
secondary  nutrients 
(Ca), 
calcium 
(Mg), 
magnesium 
or 
sodium 
sulphur  (S)  by  their 
chemical  symbols  in 
the order Ca-Mg-Na-
S; 
Declaration  of 
the 
presence  of  primary 
nutrients: 
nitrogen 
(N), phosphorus (P) or 
(K),  by 
potassium 
their 
chemical 
symbols  in  the  order 
NPK 

(Na) 

NO 

NO 

NO 

YES 

IC 

Granules. 95 % of 
the product has a 
granular 
size 
between  2,0–4,5 
mm. 

S 

from animal and 
vegetal origin, of 
which  Y  %  from 
manure 

AE 

yes 

AE 

YES 

AE 

186 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
YES 

AE 

yes 

YES 

AE 

yes 

Part II, PFC 1(A), 1(B) and 
1(C)(I), point 1, c) 

(N), 

the  content  of  the 
primary 
declared 
total 
nutrients 
total 
nitrogen 
the 
phosphorus 
form  of  phosphorus 
pentoxide  (P2O5)  or 
total potassium in the 
form  of  potassium 
oxide (K2O) 

in 

Part II, PFC 1(A), 1(B) and 
1(C)(I), point 1, c) 

of 

content 

the 
secondary 
macronutrients 
calcium  oxide  (CaO), 
magnesium 
oxide 
(MgO),  sodium  oxide 
(Na2O)  or 
sulphur 
trioxide (SO3) 

Part II, PFC 1(A), 1(B) and 
1(C)(I), point 1, d), i) 

declaration 
of 
presence  of  forms  of 
nitrogen (N) 

Part II, PFC 1(A), 1(B) and 
1(C)(I), point 1, d), i) 

declaration  of 
the 
content  of  various 
forms of nitrogen 

Part II, PFC 1(A), 1(B) and 
1(C)(I), point 1, d), iv) 

content  of  water-
soluble  calcium  oxide 
(CaO), 
magnesium 
oxide  (MgO),  sodium 
oxide 
and 
(Na2O) 
sulphur trioxide (SO3) 

YES 

YES 

YES 

Part II, PFC 1(A), 1(B) and 
1(C)(I), point 1, d), iv) 

presence  of  water-
soluble  calcium  oxide 
magnesium 
(CaO), 

YES 

organic  nitrogen, 
ammoniacal 
nitrogen 

AE 

AE 

YES 

AE 

yes 

AE 

187 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
oxide  (MgO),  sodium 
oxide 
and 
(Na2O) 
sulphur trioxide (SO3) 

Part  II,  PFC  1(A),  1(B) 
point 1, d), vi) 

dry matter 

Part II, PFC 1(A), point 1, 
e) 

The  ratio  of  organic 
total 
in 
carbon 
nitrogen 

Part II, PFC 1(A), point 1, 
f) 

production date 

Part II, PFC 1(A), point 1, 
g)  and  PFC  1(C)(I)(a), 
point 3 

form  of  the  physical 
unit 

NO 

NO 

NO 

Part  II,  PFC  1(B)  and 
1(C)(I) point 1, e) 

air  quality  impact  of 
urea 

NO 

IC 

yes 

AE 

yes 

IC 

yes 

powder, granule 

IC 

S 

fertiliser 
This 
contains 
urea, 
which  can  release 
ammonia and have 
an  impact  on  air 
quality.  Depending 
on local conditions, 
appropriate 
remediation 
measures  must  be 
The 
taken. 
manufacturer 
of 
this  fertiliser  has 
already  taken  the 
remediation 
measure 
incorporating 
urease inhibitor. 

of 
a 

188 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
YES 

YES 

YES 

YES 

YES 

AE 

phosphorus 
pentoxide 
(P2O5) 
soluble  in  neutral 
ammonium citrate 

AE 

yes 

AE 

AE 

yes 

AE 

Part  II,  PFC  1(B)  and 
1(C)(I), point 1, d), ii) 

declaration  of  soluble 
forms  of  phosphorus 
pentoxide (P2O5) 

Part  II,  PFC  1(B)  and 
1(C)(I), point 1, d), ii) 

declaration of content 
of  soluble  forms  of 
phosphorus pentoxide 
(P2O5) 

Part  II,  PFC  1(B)  and 
1(C)(I), point 1, d), iii) 

declaraton 
of 
presence  of  water 
soluble 
potassium 
oxide (K2O) 

Part  II,  PFC  1(B)  and 
1(C)(I), point 1, d), iii) 

content 
soluble 
oxide (K2O) 

of  water 
potassium 

Part II, PFC 1(B), point 2, 
1(C)(I)(a)  point  5  and 
1(C)(I)(b) point 3 

the 
declaration  of 
presence 
of 
micronutrients  boron 
(B),  cobalt  (Co),  iron 
(Fe),  manganese  (Mn) 
molybdenum 
and 
(Mo) 
in  an  organo- 
mineral  fertiliser  and 
an 
inorganic 
macronutrient 
fertiliser  (name  and 
chemical symbol) 

Part II, PFC 1(B), point 2, 
1(C)(I)(a)  point  5  and 
1(C)(I)(b) point 3 

the 
declaration  of 
content 
of 
micronutrients  boron 
(B),  cobalt  (Co),  iron 
(Fe),  manganese  (Mn) 

YES 

AE 

yes 

189 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
molybdenum 
and 
(Mo) 
in  an  organo- 
mineral  fertiliser  and 
an 
inorganic 
macronutrient 
fertiliser 

Part  II,  PFC  1(B),  point 
5(b), 1(C)(I)(a) point 8(b) 
and 1(C)(I)(b), point 6(b) 

declaration  of 
the 
presence of the water-
content  of 
soluble 
micronutrients  in  an 
organo-mineral 
fertiliser 
or 
inorganic 
macronutrient 
fertiliser 

an 

Part  II,  PFC  1(B),  point 
5(b), 1(C)(I)(a) point 8(b) 
and 1(C)(I)(b), point 6(b) 

declaration  of 
the 
water-soluble  content 
of  micronutrients 
in 
organo-mineral 
an 
fertiliser 
an 
or 
inorganic 
macronutrient 
fertiliser 

Part  II,  PFC  1(B),  point 
5(c), 1(C)(I)(a) point 8(c) 
and 1(C)(I)(b), point 6(d) 

declaration  of 
the 
chelating  agent  of 
micronutrients  in  an 
organo-mineral 
fertiliser 
or 
inorganic 
macronutrient 
fertiliser 

an 

YES (only 
inorganic 
fertilisers 
covered) 

YES (only 
inorganic 
fertilisers 
covered) 

YES (only 
inorganic 
fertilisers 
covered) 

AE 

AE 

yes 

EDTA 

AE 

190 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Part  II,  PFC  1(B),  point 
5(c), 1(C)(I)(a) point 8(c) 
and 1(C)(I)(b), point 6(d) 

the 
declaration  of 
amount  of  chelated 
micronutrients  in  an 
organo-mineral 
or 
fertiliser 
inorganic 
macronutrient 
fertiliser 

an 

YES (only 
inorganic 
fertilisers 
covered) 

AE 

yes 

Part  II,  PFC  1(B),  point 
5(ca),  1(C)(I)(a)  point 
8(ca) 
1(C)(I)(b), 
and 
point 6(ca) 

where  the  declared 
micronutrients 
are 
chelated  by  chelating 
agent(s), the pH range 
guaranteeing 
acceptable stability 

NO 

AE 

Part  II,  PFC  1(B),  point 
5(d), 1(C)(I)(a) point 8(d) 
and 1(C)(I)(b), point 6(d) 

declaration  of 
the 
complexing  agent  of 
micronutrients  in  an 
mineral 
organo- 
fertiliser 
an 
inorganic 
macronutrient 
fertiliser 

or 

Part  II,  PFC  1(B),  point 
5(d), 1(C)(I)(a) point 8(d) 
and 1(C)(I)(b), point 6(d) 

declaration  of 
the 
amount  of  complexed 
micronutrients  in  an 
organo-mineral 
fertiliser 
or 
inorganic 
macronutrient 
fertiliser 

an 

HGA 

AE 

AE 

yes 

YES (only 
inorganic 
fertilisers 
covered) 

YES (only 
inorganic 
fertilisers 
covered) 

Part  II,  PFC  1(B),  point 
5(e),  1(C)(I)(a)  point 

in 

caution 
organo-mineral 
inorganic 
macronutrient 

NO 

using 
and 

To  be  used  only 
where  there  is  a 
recognised  need. 

S 

191 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
8(e),  1(C)(I)(b),  point  6€ 
and PFC 1(C)(II) point 4 

fertilisers 
micronutrients 
inorganic 
micronutrient 
fertilisers 

with 
and 

Do  not  exceed  the 
application rate. 

Part II, PFC 1(B), points 3 
and 4, 1(C)(I)(a) points 6-
7 and 1(C)(I)(b) points 4-
5 

the 
declaration  of 
presence 
of 
micronutrient  copper 
(Cu)  or  zinc  (Zn)  in  an 
organo-mineral 
fertiliser 
and 
inorganic 
macronutrient 
fertiliser  (name  and 
chemical bl) 

an 

Part II, PFC 1(B), points 3 
and 4, 1(C)(I)(a) points 6-
7 and 1(C)(I)(b) points 4-
5 

declaration  of 
the 
of 
content 
micronutrient  copper 
(Cu)  or  zinc  (Zn)  in  an 
organo-mineral 
and 
fertiliser 
inorganic 
macronutrient 
fertiliser 

an 

II,  PFC  1(C)(I)(a), 

Part 
point 1 

inorganic 

solid 
A 
macronutrient 
be 
fertiliser  may 
labelled 
‘complex’ 
only  if  each  physical 
unit  contains  all  the 
declared  nutrients  in 
their declared content 

NO 

S 

YES (only 
inorganic 
fertilisers 
covered) 

S 

yes 

NO 

AE 

192 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Part 
point 4 

Part 
point 4 

Part 
point 4 

II,  PFC  1(C)(I)(a), 

name  of  the  coating 
agents 

II,  PFC  1(C)(I)(a), 

%  of  fertiliser  coated 
by each coating agent 

II,  PFC  1(C)(I)(a), 

caution 
coated fertilisers 

in 

using 

Part  II,  PFC  1(C)(I)(b), 
point 
PFC 
and 
1 
1(C)(II)(b), point 2 

the 
indication 
fertiliser 
in 
suspension or solution 

if 
is 

Part  II,  PFC  1(C)(II)(a), 
point 1 

typology 

of 
inorganic 

the 
straight 
micronutrient 
fertiliser  as  indicated 
in Annex I, Part II 

NO 

NO 

NO 

NO 

YES 

Part  II,  PFC  1(C)(II)(a), 
point 
PFC 
and 
2 
1(C)(II)(b), point 3 

declaration  of 
content 
micronutrients 
micronutrient 
fertiliser 

YES 

the 
of 
in  a 

Part  II,  PFC  1(C)(II)(a), 
PFC 
and 
2 
point 
1(C)(II)(b), point 3 

declaration  of 
the 
water-soluble  content 
of  micronutrients  in  a 

YES 

with 

AE 

coated 
BRANDNAME® 
coating 

AE 

yes 

AE 

the rate of nutrient 
releases  can  vary 
according  to  the 
temperature  (and 
biological  activity) 
of  the  substrate. 
An  adjustment  of 
fertilisation may be 
necessary 

IC 

Micronutrient 
chelate fertiliser 

AE 

AE 

yes 

AE 

193 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
YES 

AE 

yes 

YES (but not in 
a specific 
order) 

AE 

micronutrient 
fertiliser 

Part  II,  PFC  1(C)(II)(a), 
PFC 
and 
2 
point 
1(C)(II)(b), point 3 

declaration  of 
the 
water-soluble  content 
of  micronutrients  in  a 
micronutrient 
fertiliser 

Part II, PFC 1(C)(II), point 
1 

the 
declaration  of 
presence 
of 
micronutrients  in  the 
inorganic 
micronutrient 
fertiliser 
their 
by 
names  and  chemical 
symbols 
the 
following order: boron 
(Co), 
cobalt 
(B), 
copper (Cu), iron (Fe), 
manganese 
(Mn), 
molybdenum (Mo) 

in 

Part II, PFC 1(C)(II), point 
1 

of 
declaration 
counter-ions 
of 
micronutrients  in  the 
inorganic 
micronutrient 
fertiliser 

Part II, PFC 1(C)(II), point 
2 

declaration  of 
the 
chelating  agent  of 
micronutrients  in  an 
inorganic 
micronutrient 
fertiliser 

YES 

sodium 
sulphate 

salt, 

IC 

YES 

EDTA 

AE 

194 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Part II, PFC 1(C)(II), point 
2 

the 
declaration  of 
amount  of  chelated 
micronutrients  in  an 
inorganic 
micronutrient 
fertiliser 

YES 

AE 

yes 

NO 

AE 

Part II, PFC 1(C)(II), point 
2a 

Where  the  declared 
are 
micronutrients 
chelated  by  chelating 
agent(s), the pH range 
guaranteeing 
acceptable 
shall be indicated.’ 

stability 

Part II, PFC 1(C)(II), point 
3 

declaration  of 
the 
complexing  agent  of 
micronutrients  in  an 
inorganic 
micronutrient 
fertiliser 

Part II, PFC 1(C)(II), point 
3 

declaration  of 
the 
amount  of  complexed 
micronutrients  in  an 
inorganic 
micronutrient 
fertiliser 

YES 

HGA 

AE 

YES 

AE 

yes 

Part II, PFC 1, point 2 

NO 

declare  the  presence 
and 
nitrogen 
of 
phosphorus 
content 
when  they  are  not 
declared nutrients 

S 

195 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Part II, PFC 1, point 2 

Part II, PFC 1, point 3 (b)-
(d)* 

NO 

content  of  nitrogen 
and 
phosphorus 
content when they are 
not declared nutrients 

YES 

labelling  of  fertilisers 
with  inhibitors  -  the 
content  of  inhibiting 
compound 

Part II, PFC 1, point 3(a)  labelling  of  fertilisers 
with  inhibitors  -  the 
label shall refer to the 
presence of inhibitor 

YES 

S 

YES 

AE 

1,6% DMPP as % by 
mass 
total 
of 
nitrogen present as 
ammoniacal 
nitrogen  and  urea 
nitrogen 

nitrification 
inhibitor 

AE 

* work in progress for introducing these requirements - should be applicable during summer 

AE = agronomic efficiency 
IC= information on content  
S = safety requirements 
AP = after purchase information 

Options 0 and 1 (Measure 1) - no regulatory changes (all information is provided on the label/accompanying document/leaflet)   

Option 2 (Measure 2) - certain information may be provided digitally (without distinction professional/non-professional users)  

Option 3 (Measure 3a) - certain information may be provided digitally for professional users 

Option 3 (Measure 3b) - certain information may be provided digitally for non-professional users 

may be provided digitally 
remains on the physical label 

Option 4 (Measure 4)- most of the information may be provided digitally (without distinction professional/non-professional users) 

Option 5 (Measure 5a) - most of the information may be provided digitally for professional users 

196 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Option 5 (Measure 5b) - most of the information may be provided digitally for non-professional users 

Option 3 (Measure 6) - all information is provided digitally for certain categories of products (products sold in bulk, products for industrial users - blenders 

2.  PFC 2 (LIMING MATERIAL)  

Label information 

Policy options 

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Part I, point 1(a) 

designation of the PFC 

YES 

Part I, point 1(c) 

Part I, point 1(d) 

the  quantity  of  the 
EU 
fertilising 
product, indicated by 
mass or volume 
other  instructions  for 
intended use 

Part I, point 1(d) 
Part I, point 1(d) 
Part I, point 1(d) 

frequency 
timing 
application rates 

YES 

NO 

NO 
NO 
NO 

LIMING 

AE 

PFC  2 
MATERIAL 
25 KG net 

IC 

AP 

Apply  uniformly 
and 
incorporate 
in the soil 
AP 
once a year 
before planting  AP 
to  4000 AP 
1500 

197 

 
 
 
     
 
 
 
 
 
 
     
 
 
 
 
 
   
 
 
 
 
 
 
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Part I, point 1(d) 

Part I, point 1(e) 

targeted  plants  or 
mushrooms 
other 
storage conditions 

recommended 

Part I, point 1(e) 

storage 
temperature 

conditions-

NO 

NO 

NO 

storage 
sunlight 
storage 
humidity 
risk 
measures 

conditions-

NO 

conditions-

NO 

management 

Part I, point 1(e) 

Part I, point 1(e) 

Part I, point 1(g) 

Part I, point 1(h) 

Part I, point 1(h) 

Part I, point 1(h) 

Part I, point 3 

Part I, point 3 

Part I, point 3 

NO 

NO 

NO 

NO 

NO 

list  of  all ingredients 
above 5 %, including 
the  name  of 
the 
substance 
relevant CMC 

a 

identification  number 
of the substance 
declare  the  presence 
substance 
of 
exceeding 
MRL 
residues 
(maximum 
limit for food or feed) 
declare the content of 
the 
substance 
exceeding MRL 
warning on using the 
in  such  a 
product 

kg/ha 
cereals 

AP 

keep the products 
the  original 
in 
package 
storing 
temperature  10-
30 degrees C 
keep out of direct 
sunlight 
keep 
space 
wash  your  hands 
after  use;  keep 
out  of  reach  of 
children 
Limestone 

in  a  dry 

AP 

AP 

AP 

AP 

S 

IC 

IC 

(Virgin 

CMC  1 
material 
substances 
mixtures) 
CAS No 471-34-1  IC 

and 

clopyralid 

S 

YES 

YES 

YES 

NO 

0.1 mg/kg 

S 

YES 

NO 

do not use in such 
to 
a  way  as 

S 

198 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
to 

way 
exceeding  MRL 
the crop 

avoid 
in 

Part I, point 4 

products  derived  out 
of animal by- products 

NO 

Part I, point 5 

for products with ricin 

NO 

Part I, point 6 

Part I, point 7a 

NO 

NO 

the 

contains 
product 
unprocessed 
or 
processed cocoa shells 
declare the  presence 
of  manganese  (Mn) 
where 
EU 
fertilising 
product 
contains  or  consists 
of  thermal  oxidation 
and 
materials 
derivates or pyrolysis 
or 
gasification 
materials 

the 
limit 
in  food 

exceed 
maximum 
allowed 
or feed 
‘Farmed  animals 
shall  not  be  fed, 
either  directly  or 
by  grazing,  with 
from 
herbage 
land to which the 
product has been 
applied 
unless 
the  cutting  or 
grazing 
takes 
place  after  the 
expiry 
a 
waiting  period  of 
at least 21 days.’. 
Hazardous 
to 
animals in case of 
ingestion 
‘Toxic to dogs and 
cats’ 

of 

S 

S 

S 

S 

199 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Part I, point 7a 

Part  I,  point  7b*  and 
Article  4  of  Regulation 
on 
and 
safety 
efficiency 
argonomic 
criteria 
by-
products* 

for 

the 

declare the content of 
(Mn) 
manganese 
where 
EU 
fertilising 
product 
contains or consists of 
oxidation 
thermal 
materials 
and 
derivates  or  pyrolysis 
or 
gasification 
materials 
declare  the  presence 
(Se) 
selenium 
of 
where 
EU 
the 
product 
fertilising 
contains or consists of 
recovered  high  purity 
materials  or  certain 
by-products belonging 
to CMC 11 
declare the content of 
selenium  (Se)  where 
the 
fertilising 
product  contains  or 
consists  of  recovered 
high purity materials 
declare  the  presence 
of chloride (Cl-) where 
fertilising 
the 
product  contains  or 
consists  of  recovered 
high purity materials 
declare the content of 
chloride  (Cl-  )  where 
the 
fertilising 
product  contains  or 
consists  of  recovered 
high purity materials 

EU 

for 

Part  I,  point  7b*  and 
Article  4  of  Regulation 
on 
and 
safety 
efficiency 
argonomic 
criteria 
by-
products* 
Part  I,  point  7b*  and 
Article  4  of  Regulation 
and 
safety 
on 
efficiency 
argonomic 
criteria 
by-
products* 
Part  I,  point  7b*  and 
Article  4  of  Regulation 
on 
and 
safety 
efficiency 
argonomic 
criteria 
by-
products* 
Part II, PFC 2, first tiret  The neutralising value 

for 

for 

EU 

EU 

NO 

S 

YES 

NO  

S 

NO  

S 

YES 

NO  

S 

NO  

S 

YES 

YES 

Neutralising 
value: 

AE 

54 

200 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Part  II,  PFC  2,  second 
tiret 

granulometry, 
expressed  as  %  by 
product 
mass 
through  a 
passing 
sieve of 1,0 mm; 

of 

Part II, fourth tiret 

Part II, PFC 2, third tiret total  calcium  oxide 
(CaO), expressed as % 
by mass; 
magnesium 
total 
(MgO), 
oxide 
expressed  as  %  by 
mass; 
reactivity and method 
of  determination  of 
reactivity,  except  for 
oxide  and  hydroxide 
limes 

Part II, fifth tiret 

(equivalent CaO) 

90%  by  mass 
passing 
through a sieve 
of 1,0 mm 

IC 

NO (certain 
values was put 
as a product 
requirement; an 
optional 
labelling 
provision existed 
additionally) 

YES 

YES 

Total CaO: 51% by 
mass 

AE 

Total MgO: 2% by 
mass 

AE 

YES 

YES 

Reactivity:  73% 
(hydrochloric 
acid test) 

AE 

NO (certain 
values was put 
as a product 
requirement; an 
optional 
labelling 
provision existed 
additionally) 

AE = agronomic efficiency 
IC= information on content  
S = safety requirements 
AP = after purchase information 

Options 0 and 1 (Measure 1) - no regulatory changes (all information is provided on the label/accompanying document/leaflet)   

Option 2 (Measure 2) - certain information may be provided digitally (without distinction professional/non-professional users)  

Option 3 (Measure 3a) - certain information may be provided digitally for professional users 

Option 3 (Measure 3b) - certain information may be provided digitally for non-professional users 

may be provided digitally 
remains on the physical label 

201 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Option 4 (Measure 4)- most of the information may be provided digitally (without distinction professional/non-professional users) 

Option 5 (Measure 5a) - most of the information may be provided digitally for professional users 

Option 5 (Measure 5b) - most of the information may be provided digitally for non-professional users 

Option 3 (Measure 6) - all information is provided digitally for certain categories of products (products sold in bulk, products for industrial users - blenders 

3.  PFC 3 (SOIL IMPROVER)  

Label information 

Policy options 

-
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4
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i

Part I, point 1(a) 

designation of the PFC 

PFC 3 SOIL IMPROVER  AE 

PFC 1-6 

Part I, point 1(c) 

Part I, point 1(d) 

the 
the  quantity  of 
EU fertilising 
product, 
indicated  by  mass  or 
volume 
other 
intended use 

instructions 

for 

40 tonnes  

IC 

except PFC 4 

Apply  uniformly  and 
incorporate in the soil 

AP 

Part I, point 1(d) 

frequency  

once a year 

AP 

202 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Part I, point 1(d) 

timing 

before planting 

Part I, point 1(d) 

application rates 

1500 to 4000 kg/ha  

Part I, point 1(d) 

targeted 
mushrooms 

plants 

or 

all crops 

AP 

AP 

AP 

Part I, point 1(e) 

other 
storage conditions 

recommended 

keep  the  products  in 
the original package 

AP 

Part I, point 1(e) 

storage 
temperature 

conditions-

storing 
10-30 degrees C 

temperature 

AP 

Part I, point 1(e) 

Part I, point 1(e) 

Part I, point 1(g) 

storage 
sunlight  
storage 
humidity 
risk 
measures 

conditions-

conditions-

keep  out  of  direct 
sunlight 
keep in a dry space 

AP 

AP 

management 

wash  your  hands  after 
use;  keep  out  of  reach 
of children 

S 

Part I, point 1(h) 

list  of  all 
ingredients 
above 5 %, including the 
name of the substance 

Part I, point 1(h) 

relevant CMC 

Part I, point 1(h) 

identification  number  of 
the substance 

Part I, point 3 

Part I, point 3 

declare the presence of a 
substance 
exceeding 
MRL  (maximum  residues 
limit for food or feed) 

declare  the  content  of 
the  substance  exceeding 
MRL 

Bentonite 

IC 

YES 

CMC 1 (Virgin material 
substances 
and 
mixtures)  
CAS no 1302-78-9 

IC 

IC 

YES 

clopyralid  

S 

0.1 mg/kg 

S 

YES 

203 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Part I, point 3 

warning  on  using  the 
product in such a way to 
avoid  exceeding  MRL  in 
the crop 

do  not  use  in  such  a 
way  as  to  exceed  the 
maximum limit allowed 
in food or feed 

Part I, point 4 

products  derived  out  of 
animal by-products 

Part I, point 5 

for products with ricin 

Part I, point 6 

Part I, point 7a 

product 
unprocessed 
processed cocoa shells  

contains 
or 

declare  the  presence  of 
manganese  (Mn)  where 
the EU fertilising product 
contains  or  consists  of 
oxidation 
thermal 
materials  and  derivates 
or 
or 
pyrolysis 
gasification materials  

S 

S 

S 

been 

‘Farmed  animals  shall 
not  be 
fed,  either 
directly  or  by  grazing, 
with herbage from land 
to  which  the  product 
has 
applied 
unless  the  cutting  or 
grazing 
takes  place 
after  the  expiry  of  a 
waiting  period  of  at 
least 21 days.’. 
Hazardous  to  animals 
in case of ingestion 

‘Toxic to dogs and cats’  S 

S 

204 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Part I, point 7a 

Part  I,  point  7b* 
and  Article  4  of 
on 
Regulation 
safety 
and 
argonomic 
efficiency 
for by-products* 

criteria 

Part  I,  point  7b* 
and  Article  4  of 
on 
Regulation 
safety 
and 
agronomic 
efficiency 
for by-products* 

criteria 

Part  I,  point  7b* 
and  Article  4  of 
on 
Regulation 
safety 
and 
argonomic 
efficiency 
for by-products* 

criteria 

declare  the  content  of 
manganese  (Mn)  where 
the EU fertilising product 
contains  or  consists  of 
oxidation 
thermal 
materials  and  derivates 
or 
or 
pyrolysis 
gasification materials  

declare  the  presence  of 
selenium  (Se)  where  the 
EU 
fertilising  product 
contains  or  consists  of 
recovered  high  purity 
materials  or  certain  by-
products  belonging  to 
CMC 11 

declare  the  content  of 
selenium  (Se)  where  the 
EU 
fertilising  product 
contains  or  consists  of 
recovered  high  purity 
materials  

declare  the  presence  of 
chloride  (Cl-)  where  the 
EU 
fertilising  product 
contains  or  consists  of 
recovered  high  purity 
materials  

4 % manganese (Mn) 

S 

YES 

S 

S 

YES 

S 

205 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Part  I,  point  7b* 
and  Article  4  of 
on 
Regulation 
safety 
and 
agronomic 
efficiency 
for by-products* 

criteria 

declare  the  content  of 
chloride  (Cl-)  where  the 
EU 
fertilising  product 
contains  or  consists  of 
recovered  high  purity 
materials  

S 

YES 

Part II, PFC 3, point 
1 

declare  dry  matter  as  % 
of mass 

90 % by mass 

IC 

YES 

Part II, PFC 3, point 
2 

Part II, PFC 3, point 
2 

declare  the  presence  of 
nitrogen 
(N), 
phosphorous  pentoxide 
(P2O5)  and  potassium 
oxide  (K2O)  as  a  %  of 
mass  if  exceedig  5%  by 
mass 

declare  the  content  of 
nitrogen 
(N), 
phosphorous  pentoxide 
(P2O5)  and  potassium 
oxide  (K2O)  as  a  %  of 
mass  if  exceedig  5%  by 
mass 

S 

S 

YES 

Part  II,  PFC  3(A), 
first tyret  

pH 

8,5 

II,PFC  3(A), 

Part 
second tyret  

electrical 
given as mS/m 

conductivity 

220 mS/m 

IC 

AE 

Part  II,  PFC  3(A), 
third tyret  

organic  carbon  content 
as % by mass 

15,7 % by mass 

AE 

YES 

Part  II,  PFC  3(A), 
fourth tyret  

declare  the  presence  of 
organic nitrogen 

IC 

206 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Part  II,  PFC  3(A), 
fourth tyret  

content 
nitrogen 

of 

organic 

Part  II,  PFC  3(A), 
fourth tyret  

describe origin of organic 
matter 

IC 

YES 

S 

organic  matter  of  peat 
origin, from animal and 
vegetal origin, of which 
Y % from manure 

Part  II,  PFC  3(A), 
fifth tyret  

ratio  organic  carbon  to 
total nitrogen (Corg/N) 

16 

IC 

YES 

AE = agronomic efficiency 
IC= information on content  
S = safety requirements 
AP = after purchase information 

Options 0 and 1 (Measure 1) - no regulatory changes (all information is provided on the label/accompanying document/leaflet)   

Option 2 (Measure 2) - certain information may be provided digitally (without distinction professional/non-professional users)  

Option 3 (Measure 3a) - certain information may be provided digitally for professional users 

Option 3 (Measure 3b) - certain information may be provided digitally for non-professional users 

may be provided digitally 
remains on the physical label 

Option 4 (Measure 4)- most of the information may be provided digitally (without distinction professional/non-professional users) 

Option 5 (Measure 5a) - most of the information may be provided digitally for professional users 

Option 5 (Measure 5b) - most of the information may be provided digitally for non-professional users 

Option 3 (Measure 6) - all information is provided digitally for certain categories of products (products sold in bulk, products for industrial users - blenders 

207 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
4.  PFC 4 (GROWING MEDIUM) 

Label information 

Policy options 

l

e
b
a

l

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1
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i

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)
2
e
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u
s
a
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M

(

-
a
2
n
o
i
t
p
O

for 

PFC 4 GROWING MEDIUM AE  
AP  
Add  water  before  adding 
the seeds 

y
l
l

a
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(

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s
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u

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f
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-
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o
n

i

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a
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c

-

)
a
3
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(
b
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Part I, point 1(a) 
Part I, point 1(d) 

Part I, point 1(d) 
Part I, point 1(d) 

instructions 

designation of the PFC 
other 
intended use 
frequency 
timing 

Part I, point 1(d) 

application rates 

Part I, point 1(d) 

Part I, point 1(e) 

Part I, point 1(e) 

Part I, point 1(e) 

Part I, point 1(e) 

Part I, point 1(e) 

AP  
AP  
- 

AP  

AP  

AP  

AP  

AP  

for  planting 

period 
spring, autumn 
Mix  50%  with  soil  from 
your garden 
leafy vegetables; tullips 

or 

plants 

recommended 

targeted 
mushrooms 
other 
storage conditions 
storage 
temperature 
storage conditions - place  keep  the  products  in  the 

store at 20 degrees C 

conditions 

- 

storage 
sunlight 
storage 

conditions 

original package 
keep out of direct sunlight  AP  
- 

conditions 

- keep in a dry place 

AP  

208 

 
 
       
 
 
 
 
 
 
 
     
 
 
 
 
 
 
       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Part I, point 1(g) 

Part I, point 1(h) 

Part I, point 1(h) 

Part I, point 1(h) 

Part I, point 3 

Part I, point 3 

Part I, point 3 

Part I, point 4 

humidity 
risk 
measures 

management 

list of all ingredients above 
5 %, including the name of 
the substance 
relevant CMC 

identification  number  of 
the substance 
declare the presence of a 
substance exceeding MRL 
(maximum  residues  limit 
for food or feed) 
declare the content of the 
substance exceeding MRL 
warning  on  using  the 
product  in  such  a  way  to 
avoid  exceeding  MRL  in 
the crop 
products  derived  out  of 
animal by- products 

Part I, point 5 

Part I, point 6 

for products with ricin 

product 
unprocessed 
processed cocoa shells 

contains 
or 

S 

wash your hands after use; 
keep  out  of  reach  of 
children 
stone wool, peat, plants,  S  YES 

virgin  material  substances 
or mixtures 
CASS 65997-17-3 

IC   

IC  YES 

clopyralid 

S 

0.1 mg/kg 

S  YES 

do not use in such a way as 
to  exceed  the  maximum 
limit  allowed  in  food  or 
feed 
‘Farmed  animals  shall  not 
be  fed,  either  directly  or 
by  grazing,  with  herbage 
from  land  to  which  the 
product  has  been  applied 
unless 
the  cutting  or 
grazing  takes  place  after 
the  expiry  of  a  waiting 
period 
least 
21 days.’. 
Hazardous  to  animals  in 
case of ingestion 
‘Toxic to dogs and cats’ 

of 

at 

S 

S 

S 

209 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Part I, point 7 

Part I, point 7 

Part I, point 7a 

Part I, point 7a 

Part I, point 7b* and Article 
4  of  Regulation  on  safety 
and  argonomic  efficiency 
criteria for by-products* 

Part I, point 7b* and Article 
4  of  Regulation  on  safety 
and  argonomic  efficiency 

on 

polymer  bas  d  binding 
or  mineral 
material 
growing  medium 
- 
instructions not to use in 
contact with soil 
polymer  based  binding 
or  mineral 
material 
- 
growing  medium 
safe 
instructions 
disposal 
declare  the  presence  of 
manganese  (Mn)  where 
the EU fertilising product 
contains  or  consists  of 
thermal 
oxidation 
materials and derivates or 
pyrolysis  or  gasification 
materials 
declare  the  content  of 
manganese  (Mn)  where 
the EU fertilising product 
contains  or  consists  of 
thermal 
oxidation 
materials and derivates or 
pyrolysis  or  gasification 
materials 
declare  the  presence  of 
selenium  (Se)  where  the 
EU 
fertilising  product 
contains  or  consists  of 
recovered  high  purity 
materials  or  certain  by- 
products  belonging 
to 
CMC 11 
declare  the  content  of 
selenium  (Se)  where  the 
fertilising  product 
EU 

do not use in contact with 
soil 

make  sure  of  a  sound 
disposal  of  the  product 
in 
after  end  of  use, 
the 
collaboration  with 
manufacturer 

S 

S 

S 

S  YES 

S 

S  YES 

210 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
criteria for by-products* 

Part I, point 7b* and Article 
4  of  Regulation  on  safety 
and  argonomic  efficiency 
criteria for by-products* 

Part I, point 7b* and Article 
4  of  Regulation  on  safety 
and  argonomic  efficiency 
criteria for by-products* 

Part II, PFC 4, first tiret 

Part II, PFC 4, second tiret 
Part II, PFC 4, third tiret 

Part II, PFC 4, fourth tiret 

Part II, PFC 4, fifth tiret 

contains  or  consists  of 
recovered  high  purity 
materials 
declare  the  presence  of 
chloride  (Cl-)  where  the 
EU 
fertilising  product 
contains  or  consists  of 
recovered  high  purity 
materials 
declare  the  content  of 
chloride  (Cl-)  where  the 
EU 
fertilising  product 
contains  or  consists  of 
recovered  high  purity 
materials 
electrical 
conductivity 
given as mS/m, except for 
mineral wool; 
pH 
special 
quantity 
declare  the  presence  of 
nitrogen  (N),  phosphorus 
or 
pentoxide 
(K2O) 
potassium  oxide 
by 
extractable 
CaCl2/DTPA 
(calcium 
chloride/ 
diethylenetriaminepenta
acetic 
‘CAT-
acid; 
soluble’), 
declare  the  content  of 
nitrogen  (N),  phosphorus 
or 
pentoxide 
(K2O) 
potassium  oxide 
by 
extractable 
(calcium 
CaCl2/DTPA 

provision 

(P2O5) 

(P2O5) 

on 

S 

S  YES 

1.0-2.0 mmhos/cm 

pH (H2O) 6,0 
1  PCE: 
length  133  cm, 
width 15 cm, height 10 cm 
nitrogen  (N)  extractable 
by CaCl2/DTPA 

AE  

AE  
IC   

AE  

phosphorus 
pentoxide 
(P2O5)  extractable  by 
CaCl2/DTPA 30 mg/l 

AE  YES 

211 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
chloride/ 
diethylenetriaminepenta
acetic 
‘CAT-
acid; 
soluble’), 

Part II, PFC 4, seventh tiret  production date 

11 March 2022 

IC  YES 

AE = agronomic efficiency 
IC= information on content  
S = safety requirements 
AP = after purchase information 

Options 0 and 1 (Measure 1) - no regulatory changes (all information is provided on the label/accompanying document/leaflet)   

Option 2 (Measure 2) - certain information may be provided digitally (without distinction professional/non-professional users)  

Option 3 (Measure 3a) - certain information may be provided digitally for professional users 

Option 3 (Measure 3b) - certain information may be provided digitally for non-professional users 

may be provided digitally 
remains on the physical label 

Option 4 (Measure 4)- most of the information may be provided digitally (without distinction professional/non-professional users) 

Option 5 (Measure 5a) - most of the information may be provided digitally for professional users 

Option 5 (Measure 5b) - most of the information may be provided digitally for non-professional users 

Option 3 (Measure 6) - all information is provided digitally for certain categories of products (products sold in bulk, products for industrial users - blenders 

212 

 
 
 
 
 
 
 
 
 
 
 
 
 
5.  PFC 5 (INHIBITOR) 

Label information 

Policy options 

I
I
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n
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A
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Part I, point 1(a) 
Part I, point 1(c) 

Part I, point 1(d) 

designation of the PFC 
the  quantity  of  the  EU 
product, indicated by mass or volume 
other instructions for intended use 

fertilising 

l

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PFC 5 INHIBITORS 

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Part I, point 1(e) 

other recommended storage conditions Keep 

Part I, point 1(e) 

storage conditions-temperature 

Part I, point 1(e) 

storage conditions-sunlight 

Part I, point 1(e) 
Part I, point 1(g) 

Part I, point 1(h) 

management 

storage conditions-humidity 
risk 
measures 
(human,animal,  plant  health/  safety  or 
environment) 
relevant CMC 

the  original 

to  a 
can  be  added 
fertiliser  with  50%  of 
nitrogen out of nitrogen 
from urea 
in 
packaging 
keep  at  a  temperature 
between 5-35 degrees C 
keep  out  of  direct 
sunlight 
keep in a dry space 
wash  your  hands  after 
use; keep out of reach of 
children 
CMC  1  virgin  material 
substances and mixtures 

AP   

AP   

AP   

AP   

AP   
S 

IC   

213 

 
 
     
 
 
 
 
 
 
         
 
 
 
 
 
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Part I, point 1(h) 
Part I, point 3 

Part I, point 3 

Part I, point 3 

clopyralid 

identification number of the substance  CASS nr 7664-38-2 
declare  the  presence  of  a  substance 
exceeding MRL (maximum residues limit 
for food or feed) 
declare  the  content  of  the  substance 
exceeding MRL 
warning on using the product in such 
a way to avoid exceeding MRL in the 
crop 

0.1 mg/kg 

to 

do not use in such a way 
as 
the 
maximum  limit  allowed 
in food or feed 

exceed 

IC   
S 

S  YES 

Part II, PFC 5 

All  ingredients  declared  in  descending 
order of magnitude 

Part II, PFC 5, point 2*  declaration  of  content  of 

inhibiting 

Part  II,  PFC  5,  point 
3(a)* 
Part  II,  PFC  5,  point 
3(b)* 

compounds 
use instructions - types of fertilisers with 
which the inhibitor may be mixed 
use 
-  minimum  and 
inhibiting 
concentration 
maximum 
compounds when mixed with a fertiliser 

instrutions 

IC  YES 

AE  YES 

AE   

AE   

* work in progress for introducing these requirements - should be applicable during summer 

AE = agronomic efficiency 
IC= information on content  
S = safety requirements 
AP = after purchase information 

Options 0 and 1 (Measure 1) - no regulatory changes (all information is provided on the label/accompanying document/leaflet)   

Option 2 (Measure 2) - certain information may be provided digitally (without distinction professional/non-professional users)  

Option 3 (Measure 3a) - certain information may be provided digitally for professional users 

Option 3 (Measure 3b) - certain information may be provided digitally for non-professional users 

Option 4 (Measure 4)- most of the information may be provided digitally (without distinction professional/non-professional users) 

may be provided digitally 
remains on the physical label 

214 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Option 5 (Measure 5a) - most of the information may be provided digitally for professional users 

Option 5 (Measure 5b) - most of the information may be provided digitally for non-professional users 

Option 3 (Measure 6) - all information is provided digitally for certain categories of products (products sold in bulk, products for industrial users - blenders 

6.  PFC 6 (PLANT BIOSTIMULANT) 

Label information 

Policy options 

n
o
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t
c
n
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t
s
i
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t
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o
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t
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Part 
1(a) 

Part 
1(c) 

Part 
1(d) 

Part 
1(d) 

I,  point 

designation of the PFC 

PFC 
BIOSTIMULANT 

6: 

PLANT 

AE 

I,  point 

I,  point 

quantity 

of 
the 
the 
EU fertilising 
product, 
indicated  by  mass  or 
volume 
other 
intended use 

instructions 

for 

IC 

AP 

I,  point 

frequency  

once every three weeks  AP 

215 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Part 
1(d) 
Part 
1(d) 
Part 
1(d) 
Part 
1(e) 

Part 
1(e) 
Part 
1(e) 
Part 
1(e) 
Part 
1(g) 

Part 
1(h) 

Part 
1(h) 
Part 
1(h) 

I,  point 

timing 

top dress stage 

I,  point 

application rates 

1 L/ha 

I,  point 

I,  point 

I,  point 

I,  point 

I,  point 

I,  point 

or 

plants 

targeted 
mushrooms 
other 
storage conditions 

recommended 

keep the products in the 
original package 

conditions-

storage 
temperature 
storage conditions-sunlight   keep  out  of  direct 

protect from freezing 

storage 
humidity 
risk 
measures 

conditions-

sunlight 
keep in a dry place 

management 

wash  your  hands  after 
use; keep out of reach of 
children 

I,  point 

list of all ingredients above 
5 %, including the name of 
the substance 

I,  point 

relevant CMC 

I,  point 

identification  number  of 
the substance 

AP 

AP 

AP 

AP 

AP 

AP 

AP 

S 

IC 

YES 

IC 

IC 

YES 

Part I, point 3 

declare  the  presence  of  a 
substance  exceeding  MRL 
(maximum  residues 
limit 
for food or feed) 

clopyralid  

S 

Part I, point 3 

declare  the  content  of  the 
substance exceeding MRL 

0.1 mg/kg 

S 

YES 

Part I, point 3  warning  on  using 

the 
product  in  such  a  way  to 
avoid exceeding MRL in the 
crop 

to 

do not use in such a way 
as 
the 
maximum  limit  allowed 
in food or feed 

exceed 

216 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
‘Farmed animals shall not 
be fed, either directly or 
by grazing, with herbage 
from  land  to  which  the 
product has been applied 
unless  the  cutting  or 
grazing  takes  place  after 
the  expiry  of  a  waiting 
period 
least 
21 days.’ 
Hazardous  to  animals  in 
case of ingestion 

of 

at 

‘Toxic to dogs and cats’ 

Part I, point 4 

products  derived  out  of 
animal by-products 

Part I, point 5 

for products with ricin 

Part I, point 6 

product 
contains 
unprocessed  or  processed 
cocoa shells  

Part I, point 7a  declare  the  presence  of 
manganese 
(Mn)  where 
the  EU  fertilising  product 
contains  or  consists  of 
thermal 
oxidation 
materials  and  derivates  or 
pyrolysis  or  gasification 
materials  
Part I, point 7a  declare  the  content  of 
manganese 
(Mn)  where 
the  EU  fertilising  product 
contains  or  consists  of 
oxidation 
thermal 
materials  and  derivates  or 
pyrolysis  or  gasification 
materials  
declare  the  presence  of 
selenium (Se) where the EU 
fertilising product contains 
or  consists  of  recovered 
high  purity  materials  or 
by-products 
certain 
belonging to CMC 11 

I,  point 
Part 
7b* and Article 
4 of Regulation 
on  safety  and 
argonomic 
efficiency 
criteria  for  by-
products* 

S 

S 

S 

S 

S 

YES 

S 

217 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
I,  point 
Part 
7b* and Article 
4 of Regulation 
on  safety  and 
argonomic 
efficiency 
criteria  for  by-
products* 
Part 
I,  point 
7b* and Article 
4 of Regulation 
on  safety  and 
argonomic 
efficiency 
criteria  for  by-
products* 
Part 
I,  point 
7b* and Article 
4 of Regulation 
on  safety  and 
argonomic 
efficiency 
criteria  for  by-
products* 
Part  II,  PFC  6, 
point (a) 

Part  II,  PFC  6, 
point (b) 

Part  II,  PFC  6, 
point (b) 

Part  II,  PFC  6, 
point (c) 

declare  the  content  of 
selenium (Se) where the EU 
fertilising product contains 
or  consists  of  recovered 
high purity materials  

declare  the  presence  of 
chloride (Cl-) where the EU 
fertilising product contains 
or  consists  of  recovered 
high purity materials  

declare  the  content  of 
chloride (Cl-) where the EU 
fertilising product contains 
or  consists  of  recovered 
high purity materials  

S 

YES 

S 

S 

YES 

physical form 

liquid 

IC 

production date 

expiry date 

application methods 

via irrigation water 

Part  II,  PFC  6, 
point (d) 

effect  claimed  for  each 
target plant 

improves  nutrient  use 
efficiency 

Part  II,  PFC  6, 
point (e) 

specific  use  instructions  - 
relevant  product  efficacy-
related instructions  

perform  a  compatibility 
test before application 

IC 

YES 

AE 

YES 

AP 

AE 

AP 

218 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Part  II,  PFC  6, 
point (e) 

specific  use  instructions  - 
soil management 

AP 

Part  II,  PFC  6, 
point (e) 

specific  use  instructions  - 
chemical fertilisation 

compatible  with 
fertillisers 

liquid 

AP 

not  mix  with 

do 
bactericides 

AP 

Part  II,  PFC  6, 
point (e) 

Part  II,  PFC  6, 
point (e) 

specific  use  instructions  - 
incompatibility  with  plant 
protection products 

specific  use  instructions  - 
spraying 
recommended 
nozzle sizes 

Part  II,  PFC  6, 
point (e) 

specific  use  instructions  - 
sprayer pressure 

Part  II,  PFC  6, 
point (e) 

specific  use  instructions  - 
other anti-drift measures 

Part 
II,  PFC 
6(A), first para 

Part 
II,  PFC 
6(A), first para 

intentionally  added 
to  be 

All 
micro-organisms 
indicated 
where 
relevant, 
shall be indicated 

strains 

Part 
II,  PFC 
6(A), first para 

Concentration  of  micro-
organisms 

1x10 7 CFU/ml 

caution statement 

II,  PFC 
second 

Part 
6(A), 
para 

Micro-organisms  may 
have  the  potential  to 
provoke 
sensitising 
reactions 

AP 

AP 

AP 

AE 

AE 

AE 

S 

* work in progress for introducing these requirements - should be applicable during summer 

AE = agronomic efficiency 
IC= information on content  
S = safety requirements 
AP = after purchase information 

Options 0 and 1 (Measure 1) - no regulatory changes (all information is provided on the label/accompanying document/leaflet)   

Option 2 (Measure 2) - certain information may be provided digitally (without distinction professional/non-professional users)  

219 

may be provided digitally 
remains on the physical label 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
Option 3 (Measure 3a) - certain information may be provided digitally for professional users 

Option 3 (Measure 3b) - certain information may be provided digitally for non-professional users 

Option 4 (Measure 4)- most of the information may be provided digitally (without distinction professional/non-professional users) 

Option 5 (Measure 5a) - most of the information may be provided digitally for professional users 

Option 5 (Measure 5b) - most of the information may be provided digitally for non-professional users 

Option 3 (Measure 6) - all information is provided digitally for certain categories of products (products sold in bulk, products for industrial users - blenders 

220 

 
 
 
[
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]

ANNEX 8: EXAMPLE OF POLICY OPTIONS (PHYICAL LABELS) 

1.  POLICY OPTION 1 – FULL PHYSICAL LABEL 

COMPOUND SOLID INORGANIC MACRO NUTRIENT FERTILISER 

NPK (Mg) Mineral Fertiliser with micronutrients, 18-11-18(+2.5)/18-4.8-14.9(+1.5)  

18 % TOTAL NITROGEN (N) 

9.9% Nitric nitrogen, 7.7% Ammoniacal nitrogen, 0.4% Urea nitrogen. 

11% TOTAL PHOSPHORUS PENTOXIDE (P205) (=4.8% P) 

11 % water-soluble Phosphorus pentoxide (P2O5) (=4.8% P)  

11% Phosphorus pentoxide (P2O5) (= 4.8% P) soluble in neutral ammonium citrate  

18% POTASSIUM OXIDE (K20) (=14.9% K) Water soluble. 

2.5% MAGNESIUM OXIDE (MgO) 1.5% Mg) Water soluble. 

Poor in chloride. 

Micronutrients are completely water soluble: 0.010% Boron (B), as Boric Acid / 0.010% 
Copper  (Cu),  chelated  by  EDTA  /  0.100%  Iron  (Fe),  chelated  by  EDTA  /  0.040  % 
Manganese (Mn), chelated by EDTA / 0.001% Molybdenum (Mo), as Sodium Molybdate / 
0.010 % Zinc (Zn), chelated by EDTA  

pH range guaranteeing acceptable stability of chelated fraction: Cu 1.5-10; Fe 1.5-6.5; Mn 
3-10; Zn 2-19. 

This fertiliser contains urea, which can release ammonia and have an impact on air quality. 
Depending on local conditions, appropriate remediation measures must be taken. 

Ingredients: Potassium nitrate (7757-91-1) 1, Monoammonium phosphate (7722-76-1) 

1, Magnesium sulphate (7778-80-5)1 

1) Virgin material substances and mixtures 

Storage conditions: Prefers inside storage. Keep the product in its original packaging, in a 
dry and well-ventilated space out of direct sunlight, on clean and dry ground or pellets. Store 
at temperature between +0C and +40C. 

Granulometry: Combination of powder and prills. 63 % of the product passes through sieve 
of 1 mm and the remaining 37 % through sieve of 4 mm. 

Instructions for use: recommendation for shrubs and small trees. Can be used for container 

Nursery  Stock  and  potted  plants.  0.5-2.0  g/L  irrigation  water  to  the  plant.  Dosage  rate 
depending  on  interval  or  continuous  feeding  program  and  requirements.  Contact  HP 
Fertilisers  or  our  local  distributor  for  specific  recommendations.  Apply  lower  rates  in 
greenhouses or under hot climate conditions. 

To be used only where there is recognised need. Do not exceed appropriate rate. 

DANGER: 1-1318: Causes serious eye damage. H272: May intensify fire; oxidiser. P210: 
Keep  away  from  heat,  hot  surfaces,  sparks,  open  flames  and  other  ignition  sources.  No 

221 

 
 
 
 
 
 
smoking.  P220:  Keep/  Stole  away  from  clothing/combustible  materials.  P280:  Wear 
protective gloves/protective clothing/eye protection/face protection. P305+P351 +P338: IF 
IN  EYES:  Rinse  cautiously  with  water  for  several  minutes.  Remove  contact  lenses,  it 
present  and  easy  to  do.  Continue  rinsing.  P310:  Immediately  call  a  POISON 
CENTER/doctor. 

Batch/Type number                                                  25 KG NET 

             +  notified  body  number  if  applicable          COMPANY 
Name address 

222 

 
 
 
 
 
2.  POLICY  OPTION  2A  –  CERTAIN  INFORMATION  MOVES  DIGITALLY  (TEXT  IN  GREEN 

MAY BE PROVIDED DIGITALLY) 

COMPOUND SOLID INORGANIC MACRO NUTRIENT FERTILISER 

NPK (Mg) Mineral Fertiliser with micronutrients, 18-11-18(+2.5)/18-4.8-14.9(+1.5)  

18 % TOTAL NITROGEN (N) 

9.9% Nitric nitrogen, 7.7% Ammoniacal nitrogen, 0.4% Urea nitrogen. 

11% TOTAL PHOSPHORUS PENTOXIDE (P205) (=4.8% P) 

11 % water-soluble Phosphorus pentoxide (P2O5) (=4.8% P)  

11% Phosphorus pentoxide (P2O5) (= 4.8% P) soluble in neutral ammonium citrate  

18% POTASSIUM OXIDE (K20) (=14.9% K) Water soluble. 

2.5% MAGNESIUM OXIDE (MgO) 1.5% Mg) Water soluble. 

Poor in chloride. 

Micronutrients are completely water soluble: 0.010% Boron (B), as Boric Acid / 0.010% 
Copper  (Cu),  chelated  by  EDTA  /  0.100%  Iron  (Fe),  chelated  by  EDTA  /  0.040  % 
Manganese (Mn), chelated by EDTA / 0.001% Molybdenum (Mo), as Sodium Molybdate / 
0.010 % Zinc (Zn), chelated by EDTA  

pH range guaranteeing acceptable stability of chelated fraction: Cu 1.5-10; Fe 1.5-6.5; Mn 
3-10; Zn 2-19. 

This fertiliser contains urea, which can release ammonia and have an impact on air quality. 
Depending on local conditions, appropriate remediation measures must be taken. 

Ingredients: Potassium nitrate (7757-91-1) 1, Monoammonium phosphate (7722-76-1) 

1, Magnesium sulphate (7778-80-5)1 

1) Virgin material substances and mixtures 

Storage conditions: Prefer inside storage. Keep the product in its original packaging, in a 
dry and well-ventilated space out of direct sunlight, on clean and dry ground or pellets. Store 
at temperature between +0C and +40C. 

Granulometry: Combination of powder and prills. 63 % of the product passes through sieve 
of 1 mm and the remaining 37 % through sieve of 4 mm. 

Instructions for use: recommendation for shrubs and small trees. Can be used for container 

Nursery  Stock  and  potted  plants.  0.5-2.0  g/L  irrigation  water  to  the  plant.  Dosage  rate 
depending  on  interval  or  continuous  feeding  program  and  requirements.  Contact  HP 
Fertilisers  or  our  local  distributor  for  specific  recommendations.  Apply  lower  rates  in 
greenhouses or under hot climate conditions. 

To be used only where there is recognised need. Do not exceed appropriate rate. 

DANGER: 1-1318: Causes serious eye damage. H272: May intensify fire; oxidiser. P210: 
Keep  away  from  heat,  hot  surfaces,  sparks,  open  flames  and  other  ignition  sources.  No 
smoking.  P220:  Keep/  Stole  away  from  clothing/combustible  materials.  P280:  Wear 
protective gloves/protective clothing/eye protection/face protection. P305+P351 +P338: IF 
IN  EYES:  Rinse  cautiously  with  water  for  several  minutes.  Remove  contact  lenses,  it 

223 

 
 
present  and  easy  to  do.  Continue  rinsing.  P310:  Immediately  call  a  POISON 
CENTER/doctor. 

Batch/Type number                                                  25 KG NET 

             +  notified  body  number  if  applicable          COMPANY 
Name address 

3.  POLICY  OPTION2C  –  MOST  OF  THE  INFORMATION  MOVED  DIGITALLY  (TEXT  IN 

GREEN IS ALLOWED TO GO DIGITAL) 

COMPOUND SOLID INORGANIC MACRO NUTRIENT FERTILISER 

NPK (Mg) Mineral Fertiliser with micronutrients, 18-11-18(+2.5)/18-4.8-14.9(+1.5)  

18 % TOTAL NITROGEN (N) 

9.9% Nitric nitrogen, 7.7% Ammoniacal nitrogen, 0.4% Urea nitrogen. 

11% TOTAL PHOSPHORUS PENTOXIDE (P205) (=4.8% P) 

11 % water-soluble Phosphorus pentoxide (P2O5) (=4.8% P)  

11% Phosphorus pentoxide (P2O5) (= 4.8% P) soluble in neutral ammonium citrate  

18% POTASSIUM OXIDE (K20) (=14.9% K) Water soluble. 

2.5% MAGNESIUM OXIDE (MgO) 1.5% Mg) Water soluble. 

Poor in chloride. 

Micronutrients are completely water soluble: 0.010% Boron (B), as Boric Acid / 0.010% 
Copper  (Cu),  chelated  by  EDTA  /  0.100%  Iron  (Fe),  chelated  by  EDTA  /  0.040  % 
Manganese (Mn), chelated by EDTA / 0.001% Molybdenum (Mo), as Sodium Molybdate / 
0.010 % Zinc (Zn), chelated by EDTA  

pH range guaranteeing acceptable stability of chelated fraction: Cu 1.5-10; Fe 1.5-6.5; Mn 
3-10; Zn 2-19. 

This fertiliser contains urea, which can release ammonia and have an impact on air quality. 
Depending on local conditions, appropriate remediation measures must be taken. 

Ingredients: Potassium nitrate (7757-91-1) 1, Monoammonium phosphate (7722-76-1) 

1, Magnesium sulphate (7778-80-5)1 

1) Virgin material substances and mixtures 

Storage conditions: Prefers inside storage. Keep the product in its original packaging, in a 
dry and well-ventilated space out of direct sunlight, on clean and dry ground or pellets. Store 
at temperature between + 0 oC and +40 oC. 

Granulometry: Combination of powder and prills. 63 % of the product passes through sieve 
of 1 mm and the remaining 37 % through sieve of 4 mm. 

Instructions for use: recommendation for shrubs and small trees. Can be used for container 

Nursery  Stock  and  potted  plants.  0.5-2.0  g/L  irrigation  water  to  the  plant.  Dosage  rate 
depending  on  interval  or  continuous  feeding  program  and  requirements.  Contact  HP 

224 

 
 
 
 
 
 
Fertilisers  or  our  local  distributor  for  specific  recommendations.  Apply  lower  rates  in 
greenhouses or under hot climate conditions. 

To be used only where there is recognised need. Do not exceed appropriate rate. 

DANGER: 1-1318: Causes serious eye damage. H272: May intensify fire; oxidiser. P210: 
Keep  away  from  heat,  hot  surfaces,  sparks,  open  flames  and  other  ignition  sources.  No 
smoking.  P220:  Keep/  Stole  away  from  clothing/combustible  materials.  P280:  Wear 
protective gloves/protective clothing/eye protection/face protection. P305+P351 +P338: IF 
IN  EYES:  Rinse  cautiously  with  water  for  several  minutes.  Remove  contact  lenses,  it 
present  and  easy  to  do.  Continue  rinsing.  P310:  Immediately  call  a  POISON 
CENTER/doctor. 

Batch/Type number                                                  25 KG NET 

             +  notified  body  number  if  applicable          COMPANY 
Name address 

4.  POLICY  OPTION  2B  -  PROFESSIONAL  USERS  -  MEASURE  3A  (TEXT  IN  GREEN  IS 

ALLOWED TO GO DIGITAL) 

COMPOUND SOLID INORGANIC MACRO NUTRIENT FERTILISER 

NPK (Mg) Mineral Fertiliser with micronutrients, 18-11-18(+2.5)/18-4.8-14.9(+1.5)  

18 % TOTAL NITROGEN (N) 

9.9% Nitric nitrogen, 7.7% Ammoniacal nitrogen, 0.4% Urea nitrogen. 

11% TOTAL PHOSPHORUS PENTOXIDE (P205) (=4.8% P) 

11 % water-soluble Phosphorus pentoxide (P2O5) (=4.8% P)  

11% Phosphorus pentoxide (P2O5) (= 4.8% P) soluble in neutral ammonium citrate  

18% POTASSIUM OXIDE (K20) (=14.9% K) Water soluble. 

2.5% MAGNESIUM OXIDE (MgO) 1.5% Mg) Water soluble. 

Poor in chloride. 

Micronutrients are completely water soluble: 0.010% Boron (B), as Boric Acid / 0.010% 
Copper  (Cu),  chelated  by  EDTA  /  0.100%  Iron  (Fe),  chelated  by  EDTA  /  0.040  % 
Manganese (Mn), chelated by EDTA / 0.001% Molybdenum (Mo), as Sodium Molybdate / 
0.010 % Zinc (Zn), chelated by EDTA  

pH range guaranteeing acceptable stability of chelated fraction: Cu 1.5-10; Fe 1.5-6.5; Mn 
3-10; Zn 2-19. 

This fertiliser contains urea, which can release ammonia and have an impact on air quality. 
Depending on local conditions, appropriate remediation measures must be taken. 

Ingredients: Potassium nitrate (7757-91-1) 1, Monoammonium phosphate (7722-76-1) 

1, Magnesium sulphate (7778-80-5)1 

1) Virgin material substances and mixtures 

225 

 
 
 
 
 
 
Storage conditions: Prefers inside storage. Keep the product in its original packaging, in a 
dry and well-ventilated space out of direct sunlight, on clean and dry ground or pellets. Store 
at temperature between + 0 oC and +40 oC. 

Granulometry: Combination of powder and prills. 63 % of the product passes through sieve 
of 1 mm and the remaining 37 % through sieve of 4 mm. 

Instructions for use: recommendation for shrubs and small trees. Can be used for container 

Nursery  Stock  and  potted  plants.  0.5-2.0  g/L  irrigation  water  to  the  plant.  Dosage  rate 
depending  on  interval  or  continuous  feeding  program  and  requirements.  Contact  HP 
Fertilisers  or  our  local  distributor  for  specific  recommendations.  Apply  lower  rates  in 
greenhouses or under hot climate conditions. 

To be used only where there is recognised need. Do not exceed appropriate rate. 

DANGER: 1-1318: Causes serious eye damage. H272: May intensify fire; oxidiser. P210: 
Keep  away  from  heat,  hot  surfaces,  sparks,  open  flames  and  other  ignition  sources.  No 
smoking.  P220:  Keep/  Stole  away  from  clothing/combustible  materials.  P280:  Wear 
protective gloves/protective clothing/eye protection/face protection. P305+P351 +P338: IF 
IN  EYES:  Rinse  cautiously  with  water  for  several  minutes.  Remove  contact  lenses,  it 
present  and  easy  to  do.  Continue  rinsing.  P310:  Immediately  call  a  POISON 
CENTER/doctor. 

Batch/Type number                                                  25 KG NET 

             +  notified  body  number  if  applicable          COMPANY 
Name address 

5.  POLICY  OPTION  2E  -  PROFESSIONAL  USERS  -  MEASURE  5A  (TEXT  IN  GREEN  IS 

ALLOWED TO GO DIGITAL) 

COMPOUND SOLID INORGANIC MACRO NUTRIENT FERTILISER 

NPK (Mg) Mineral Fertiliser with micronutrients, 18-11-18(+2.5)/18-4.8-14.9(+1.5)  

18 % TOTAL NITROGEN (N) 

9.9% Nitric nitrogen, 7.7% Ammoniacal nitrogen, 0.4% Urea nitrogen. 

11% TOTAL PHOSPHORUS PENTOXIDE (P205) (=4.8% P) 

11 % water-soluble Phosphorus pentoxide (P2O5) (=4.8% P)  

11% Phosphorus pentoxide (P2O5) (= 4.8% P) soluble in neutral ammonium citrate  

18% POTASSIUM OXIDE (K20) (=14.9% K) Water soluble. 

2.5% MAGNESIUM OXIDE (MgO) 1.5% Mg) Water soluble. 

Poor in chloride. 

Micronutrients are completely water soluble: 0.010% Boron (B), as Boric Acid / 0.010% 
Copper  (Cu),  chelated  by  EDTA  /  0.100%  Iron  (Fe),  chelated  by  EDTA  /  0.040  % 
Manganese (Mn), chelated by EDTA / 0.001% Molybdenum (Mo), as Sodium Molybdate / 
0.010 % Zinc (Zn), chelated by EDTA  

226 

 
 
 
 
 
 
pH range guaranteeing acceptable stability of chelated fraction: Cu 1.5-10; Fe 1.5-6.5; Mn 
3-10; Zn 2-19. 

This fertiliser contains urea, which can release ammonia and have an impact on air quality. 
Depending on local conditions, appropriate remediation measures must be taken. 

Ingredients: Potassium nitrate (7757-91-1) 1, Monoammonium phosphate (7722-76-1) 

1, Magnesium sulphate (7778-80-5)1 

1) Virgin material substances and mixtures 

Storage conditions: Prefers inside storage. Keep the product in its original packaging, in a 
dry and well-ventilated space out of direct sunlight, on clean and dry ground or pellets. Store 
at temperature between + 0 oC and +40 oC. 

Granulometry: Combination of powder and prills. 63 % of the product passes through sieve 
of 1 mm and the remaining 37 % through sieve of 4 mm. 

Instructions for use: recommendation for shrubs and small trees. Can be used for container 

Nursery  Stock  and  potted  plants.  0.5-2.0  g/L  irrigation  water  to  the  plant.  Dosage  rate 
depending  on  interval  or  continuous  feeding  program  and  requirements.  Contact  HP 
Fertilisers  or  our  local  distributor  for  specific  recommendations.  Apply  lower  rates  in 
greenhouses or under hot climate conditions. 

To be used only where there is recognised need. Do not exceed appropriate rate. 

DANGER: 1-1318: Causes serious eye damage. H272: May intensify fire; oxidiser. P210: 
Keep  away  from  heat,  hot  surfaces,  sparks,  open  flames  and  other  ignition  sources.  No 
smoking.  P220:  Keep/  Stole  away  from  clothing/combustible  materials.  P280:  Wear 
protective gloves/protective clothing/eye protection/face protection. P305+P351 +P338: IF 
IN  EYES:  Rinse  cautiously  with  water  for  several  minutes.  Remove  contact  lenses,  it 
present  and  easy  to  do.  Continue  rinsing.  P310:  Immediately  call  a  POISON 
CENTER/doctor. 

Batch/Type number                                                 25 KG NET 

             +  notified  body  number  if  applicable          COMPANY 
Name address 

6.  POLICY OPTION 2B – NON-PROFESSIONAL USERS - MEASURE 3B (TEXT IN GREEN IS 

ALLOWED TO GO DIGITAL) 

COMPOUND SOLID INORGANIC MACRO NUTRIENT FERTILISER 

NPK (Mg) Mineral Fertiliser with micronutrients, 18-11-18(+2.5)/18-4.8-14.9(+1.5)  

18 % TOTAL NITROGEN (N) 

9.9% Nitric nitrogen, 7.7% Ammoniacal nitrogen, 0.4% Urea nitrogen. 

11% TOTAL PHOSPHORUS PENTOXIDE (P205) (=4.8% P) 

11 % water-soluble Phosphorus pentoxide (P2O5) (=4.8% P)  

11% Phosphorus pentoxide (P2O5) (= 4.8% P) soluble in neutral ammonium citrate  

227 

 
 
 
 
 
 
18% POTASSIUM OXIDE (K20) (=14.9% K) Water soluble. 

2.5% MAGNESIUM OXIDE (MgO) 1.5% Mg) Water soluble. 

Poor in chloride. 

Micronutrients are completely water soluble: 0.010% Boron (B), as Boric Acid / 0.010% 
Copper  (Cu),  chelated  by  EDTA  /  0.100%  Iron  (Fe),  chelated  by  EDTA  /  0.040  % 
Manganese (Mn), chelated by EDTA / 0.001% Molybdenum (Mo), as Sodium Molybdate / 
0.010 % Zinc (Zn), chelated by EDTA  

pH range guaranteeing acceptable stability of chelated fraction: Cu 1.5-10; Fe 1.5-6.5; Mn 
3-10; Zn 2-19. 

This fertiliser contains urea, which can release ammonia and have an impact on air quality. 
Depending on local conditions, appropriate remediation measures must be taken. 

Ingredients: Potassium nitrate (7757-91-1) 1, Monoammonium phosphate (7722-76-1) 

1, Magnesium sulphate (7778-80-5)1 

1) Virgin material substances and mixtures 

Storage conditions: Prefers inside storage. Keep the product in its original packaging, in a 
dry and well-ventilated space out of direct sunlight, on clean and dry ground or pellets. Store 
at temperature between + 0 oC and +40 oC. 

Granulometry: Combination of powder and prills. 63 % of the product passes through sieve 
of 1 mm and the remaining 37 % through sieve of 4 mm. 

Instructions for use: recommendation for shrubs and small trees. Can be used for container 

Nursery  Stock  and  potted  plants.  0.5-2.0  g/L  irrigation  water  to  the  plant.  Dosage  rate 
depending  on  interval  or  continuous  feeding  program  and  requirements.  Contact  HP 
Fertilisers  or  our  local  distributor  for  specific  recommendations.  Apply  lower  rates  in 
greenhouses or under hot climate conditions. 

To be used only where there is recognised need. Do not exceed appropriate rate. 

DANGER: 1-1318: Causes serious eye damage. H272: May intensify fire; oxidiser. P210: 
Keep  away  from  heat,  hot  surfaces,  sparks,  open  flames  and  other  ignition  sources.  No 
smoking.  P220:  Keep/  Stole  away  from  clothing/combustible  materials.  P280:  Wear 
protective gloves/protective clothing/eye protection/face protection. P305+P351 +P338: IF 
IN  EYES:  Rinse  cautiously  with  water  for  several  minutes.  Remove  contact  lenses,  it 
present  and  easy  to  do.  Continue  rinsing.  P310:  Immediately  call  a  POISON 
CENTER/doctor. 

Batch/Type number                                                  25 Kg NET 

             +  notified  body  number  if  applicable          COMPANY 
Name address 

7.  POLICY OPTION 2D – NON-PROFESSIONAL USERS - MEASURE 5B (TEXT IN GREEN IS 

ALLOWED TO GO DIGITAL) 

COMPOUND SOLID INORGANIC MACRO NUTRIENT FERTILISER 

228 

 
 
 
 
 
 
NPK (Mg) Mineral Fertiliser with micronutrients, 18-11-18(+2.5)/18-4.8-14.9(+1.5)  

18 % TOTAL NITROGEN (N) 

9.9% Nitric nitrogen, 7.7% Ammoniacal nitrogen, 0.4% Urea nitrogen. 

11% TOTAL PHOSPHORUS PENTOXIDE (P205) (=4.8% P) 

11 % water-soluble Phosphorus pentoxide (P2O5) (=4.8% P)  

11% Phosphorus pentoxide (P2O5) (= 4.8% P) soluble in neutral ammonium citrate  

18% POTASSIUM OXIDE (K20) (=14.9% K) Water soluble. 

2.5% MAGNESIUM OXIDE (MgO) 1.5% Mg) Water soluble. 

Poor in chloride. 

Micronutrients are completely water soluble: 0.010% Boron (B), as Boric Acid / 0.010% 
Copper  (Cu),  chelated  by  EDTA  /  0.100%  Iron  (Fe),  chelated  by  EDTA  /  0.040  % 
Manganese (Mn), chelated by EDTA / 0.001% Molybdenum (Mo), as Sodium Molybdate / 
0.010 % Zinc (Zn), chelated by EDTA  

pH range guaranteeing acceptable stability of chelated fraction: Cu 1.5-10; Fe 1.5-6.5; Mn 
3-10; Zn 2-19. 

This fertiliser contains urea, which can release ammonia and have an impact on air quality. 
Depending on local conditions, appropriate remediation measures must be taken. 

Ingredients: Potassium nitrate (7757-91-1) 1, Monoammonium phosphate (7722-76-1) 

1, Magnesium sulphate (7778-80-5)1 

1) Virgin material substances and mixtures 

Storage conditions: Prefers inside storage. Keep the product in its original packaging, in a 
dry and well-ventilated space out of direct sunlight, on clean and dry ground or pellets. Store 
at temperature between + 0 oC and +40 oC. 

Granulometry: Combination of powder and prills. 63 % of the product passes through sieve 
of 1 mm and the remaining 37 % through sieve of 4 mm. 

Instructions for use: recommendation for shrubs and small trees. Can be used for container 

Nursery  Stock  and  potted  plants.  0.5-2.0  g/L  irrigation  water  to  the  plant.  Dosage  rate 
depending  on  interval  or  continuous  feeding  program  and  requirements.  Contact  HP 
Fertilisers  or  our  local  distributor  for  specific  recommendations.  Apply  lower  rates  in 
greenhouses or under hot climate conditions. 

To be used only where there is recognised need. Do not exceed appropriate rate. 

DANGER: 1-1318: Causes serious eye damage. H272: May intensify fire; oxidiser. P210: 
Keep  away  from  heat,  hot  surfaces,  sparks,  open  flames  and  other  ignition  sources.  No 
smoking.  P220:  Keep/  Stole  away  from  clothing/combustible  materials.  P280:  Wear 
protective gloves/protective clothing/eye protection/face protection. P305+P351 +P338: IF 
IN  EYES:  Rinse  cautiously  with  water  for  several  minutes.  Remove  contact  lenses,  it 
present  and  easy  to  do.  Continue  rinsing.  P310:  Immediately  call  a  POISON 
CENTER/doctor. 

Batch/Type number                                                  25 KG NET 

229 

 
 
 
 
             +  notified  body  number  if  applicable          COMPANY 
Name address 

230 

 
 
 
 
 
 
Annex 9: Case Studies 

1.  CASE STUDY 1: 

LARGE MANUFACTURER  

Company description 

The company is a large manufacturer from the growing media industry, with more than 249 
employees. The company has offices in three European countries and distributes fertilisers 
all  over  the  EU-27  and  internationally  .  It  specialises  in  producing  and  selling  growing 
media and fertilising product blends. The company’s product line includes over 70 different 
growing medium products, to which 175.000 labels are used each year. Most labels are for 
packages  between  101-500  litres  or  kgs,  while  15.000  labels  are  used  per  annum  for 
packages larger than 500kg. Furthermore, the company produces over 4000 different types 
of blends, using 14.250.000 labels. 11.500.000 of these are fixed on 6-20 kg/l packages, 
2.500.000 are attached on 101-500 kg/l bags and 250.000 on bulk bags larger than 500kg/l. 
The mixture and components of these blends are customised according to the needs of the 
customer,  therefore  labelling  information  also  varies  highly.  Primarily,  customers  are 
ordering specialised blends in large quantities, but sometimes small-scale farmers also buy 
standardised products from their warehouses.  

Labelling exercises and costs of compliance 

When labelling customised products, the company’s current practice is to put standard, not 
frequently  changing  information  on  one  type  of  bag,  which  are  used  for  a  number  of 
different products. Additional info is provided digitally (e.g. in PDF) or in a paper format 
that  follows  the  product  but  not  as  a  label.  According  to  the  interviewee,  it  would  be 
“impossible that we should have 10,000 different bags instead of five with all the costs and 
all  the  surplus  in  warehouse  of  different  bags  and  all  the  waste  of  plastic  and  all  the 
changes”. Hence, the company has a database and system set up for tracking information 
digitally, which can easily be sent to users . Therefore, the company has strong capacity 
already to cover the digitalisation of information about fertilising products. However, the 
final method of presenting information (standardised template or not) as well as the place 
of  information  (centralised  database  or  manufacturers’  website)  could  incur  additional 
expenditure. Hence, when asked about digitalisation, a one-off cost of 100.000 EUR was 
indicated for set-up costs (e.g. acquisition of equipment such as a QR code printer) in the 
case of policy options 2-5. No other costs were mentioned regarding the maintenance of 
webpages, development of software or staff training. 

The survey questionnaire differentiated the cost of compliance with the FPR according to 
one-off and ongoing costs. The company expects that compliance will put an additional one-
off cost  of 10.000 EUR on staff time, a one-off cost  of 100.000 EUR for obtaining new 
machinery  and  100.000  EUR  because  of  operational  changes  (managing,  ordering  and 
storing  labels,  designing  label  replacements  etc.).    Altogether,  the  one-off  costs  of 
compliance  will  amount  to  210.000  EUR.  However,  as  noted  above,  this  can  be  spread 
across a total of 190,000 labels per annum (the total tables produced annually for smaller 
and larger packages combined).  

231 

 
 
Furthermore,  complying  with  the  FPR  2019  has  led  to  25.000  EUR  additional  ongoing 
annual costs of maintaining machinery to meet FPR labelling obligations, 25.000 EUR of 
additional ongoing costs of label printing and an additional 15.000 EUR for fixing labels to 
packaging. Nonetheless, in the interview, the representative said that the costs of having 
different bags would by far outweigh the costs of digitalisation. 

Regarding costs input, the manufacturer emphasized that these are in fact “guestimates” and 
their main problem  is  not  so much the  financial costs involved “much  more the balance 
between  the  practical  challenge  (providing  required  info  in  many  different  languages  on 
ever  changing  products  that  are  customised  according  to  customers’  needs)  versus  the 
potential benefit (professional growers already know what they get”. Thus, according to the 
interviewee’s argument, the comparative benefit of delivering more information on physical 
labels to their customers under the new FPR coming into effect in July 2022 is rather low, 
as,  by  the  time  the  product  is  delivered,  they  already  know  the  necessary  information. 
Customers place orders based on their needs or prepare products in consultation with the 
manufacturer. 

In summary, the manufacturer reported that their main cost of digitalisation would be the 
acquisition of equipment needed for printing (e.g. QR codes), this being identical across all 
policy options that offer a certain degree of digitalisation, while it did not foresee costs for 
purchasing  software,  the  set-up  of  webpages,  additional  staff  training  or  for  keeping 
information up to date. Producing customised blends, the company has already built up the 
capacity to handle information digitally, due to frequently changing information items (list 
of ingredients, nutrient content).  According to the representative, their primary concern is 
less  so  the  costs,  but  whether  it  is  feasible  to  comply  with  the  regulation  without 
digitalization.  Customised  products  would  require  the  constant  revision  of  labelling 
information of the physical label. In the event of not introducing digitalization, their first 
consideration would be to sell only standardized products. 

Thus,  the  expected  utility  of  digitalisation  lies  in  the  removal  of  frequently  changing 
information from the labels, which is provided in Policy Options 2 and 4. Increasing the 
amount  of  the  removed  information  would  have  no  further  cost  saving  effect  on  the 
company, whereas users would lose access to additional information. 

2.  CASE STUDY 2: 

MID-SIZE FIRM 

Company description and fertiliser products 

The company is an Ireland-based, small-sized manufacturer specialising in soil, plant and 
animal  nutrition.  Whilst it has about  100  employees, it is  80% owned by a much bigger 
entity, a large multinational with 1.6 bn euros in turnover across 40 countries, with 6200 
employees. 

Regarding  the  volume  of  fertilisers  /  year,  the  company  sells  350000  tonnes  in  Ireland/ 
annum. 10% is sold in bulk, 75% are sold in ½ tonne bags, and 15% in 50 kg bags. The 
company  are  both  baggers  of  minerals  and  inorganic  fertilisers.  Additionally,  they  are 
blenders of mixtures of fertilisers that are often produced in small quantities for clients on 
a customised basis.  

General feedback on the digitalisation of fertiliser labels  

232 

 
 
The company was therefore generally favourable to the possibility of voluntary adoption of 
digital labelling and has been considering transitioning to digital labels ahead of any changes 
in EU legislation. The interviewees stated that going ahead with producing digital labels 
would be relatively straight forward, but would incur some costs.  

They  foresaw  that  two  QR  codes  would  need  to  be  used,  the  first  displaying  health  and 
safety  (H&S)  information,  and  the  other  setting  out  any  complementary,  but  non-safety 
related product data. They also stated that the list of ingredients should remain on physical 
labels, given that fertiliser producers such as the firm concerned produce blends and it is not 
possible to pre-print labels or digitalise all the information, as it isn’t known upfront which 
raw materials will be included in the blend and go into the bag. Therefore, the ingredients 
must remain on the physical label for blended products. 

The product name, batch QR code and expiry date would also be needed on the digital label. 

Regarding feedback on which information should remain on physical labels, key safety data 
would have to remain on the bag, but potentially other information, such as on nutrients, 
could be digitalised.  

An advantage of QR codes they anticipated was that the type of digitalised information can 
be very adaptable.  

Regarding potential cost savings, the firm said that there may be some minor cost-efficiency 
savings  of  digital  labelling,  but  also  some  upfront  and  recurring  costs.  However,  they 
viewed potential voluntary digital labelling under the FPR 2019 as being less a cost-saving 
driver and more a means of implementing the FPR.  

Regarding  the  baseline  situation  and  current  market  practices,  the  firm  noted  that  safety 
instructions are pre-printed by all the main brands of fertilisers on bags. Smaller firms falling 
under the current 2003 Regulations attach a physical sticky label. However, a concern was 
expressed about the new FPR 2019 that the new requirements coming into effect in July 
2022 require a lot of additional information to be put on physical labels, and often labels 
cannot  be  produced  that  would  be  big  enough  to  incorporate  all  of  the  information 
requirements under the new 2019 Regulation. They noted that for some fertilisers, it would 
be physically impossible to put all the information onto a label to be affixed to the product. 
Hence they expressed the view that digital labelling was the most efficient and effective 
means of achieving regulatory compliance in future. 

In terms of the willingness of the fertiliser industry to accept voluntary digital labelling, in 
their estimation, the majority of farmers have smart phones and 80% of their fertiliser sales 
are to larger-scale farmers who are familiar with using QR codes. For small farmers, they 
advocated  ensuring  that  a  leaflet  /  brochure  was  available  containing  basic  safety 
information and user instructions. 

Costs of the digitalisation of fertiliser labels 

In terms of the costs of the digitalisation of fertiliser labels, they estimated that they would 
need to purchase one QR coding machine per fertiliser production factory for 20,000 EUR.  

3.  CASE STUDY 3: A MID-SIZE DISTRIBUTOR, IBERIAN BRANCH 

Company description and fertiliser products 

233 

 
 
The company is a medium-sized business (between 50-249 employees), which distributes 
products  in  their  country  of  operation  and  is  a  regional  branch  of  a  multinational  crop 
nutrition company. It mainly sells inorganic fertilisers, having 75 different products on the 
market, as well as one organo-mineral and three bio-stimulant fertilising products. 

Almost exclusively, the company sells products in bulk packages, most in 25 kg bags and 
do not target the non-professional consumer market. 

General feedback on the digitalisation of fertiliser labels  

The company does not provide labelling information digitally at present. It calculates that 
in order to comply with FPR they will face a one-off cost of 5.000 EUR in staff time, 10.500 
EUR  in  costs  of  fixing  labels  to  packaging  and  10.000  because  of  required  operational 
changes (e.g. how to place labels on packaging, manage labels and packaging, ordering and 
storage).    Without  FPR,  the  company  indicated  a  cost  of  150  EUR  for  fixing  labels  to 
packaging. Compliance with FPR also creates an annual cost of 5000 EUR in staff time and 
an additional 2000 EUR cost of printing labels. 

In an interview with company representatives, storage of labels was indicated as one of the 
main cost drivers. Labels have to be pre-ordered well in advance (e.g. half a year before) 
and in larger quantities, as there are minimum pre-order sizes. Thus, the company prefers 
to  order  labels  for  a  longer  duration  of  time.  Secondly,  the  management  of  labelling 
information  was  another  driver  of  operational  costs.  According  to  the  interviewee, 
managing labelling information is a complex issue, especially if these are multi-language 
ones. The process of updating and changing label information itself is costly in staff time 
but pre-printed labels will also have to be discarded. For this reason, the company thinks 
that the most substantive advantage of digitalisation is the operational aspect,that would be 
considerably streamlined. Given that information subject to frequent changes affects more 
the operational management of labels, the expected costs and savings are also influenced by 
whether digitalisation extends to frequently changing information items. 

When asked about  how the implementation  costs of FPR in  relative terms,  the company 
expects a 30% increase of costs in staff time (not including design of labels), a 3% increase 
in  costs  of  fixing  labels  and  a  20%  increase  in  operational  changes  as  compared  to  the 
2003/2003 regulation. Compared to these costs of compliance with FPR, digital labelling 
would reduce costs of staff time by a factor of three (from 30% to 10% in case of Option 2, 
3a, 3b and to 15%  in  case of options 4, 5a,  5b). Costs in operational changes would be 
reduced in case of policy options 4, 5a and 5b from 20% increase to 10%. 

Costs of the digitalisation of fertiliser labels 

The company estimates that costs of digitalisation would incur a 500 EUR one-off costs for 
the development and purchase of software, 1000 EUR for setting up web pages and 1000 
EUR for staff training. An ongoing expense of 1000 EUR for staff training was indicated, 
per annum, whereas updating information on webpages would draw an additional 200 EUR 
yearly expense. The additional one-off and ongoing costs of staff training was present even 
in the absence of digitalisation. Thus, the main costs drivers of digitalisation would be the 
purchasing  or  development  of  relevant  software,  the  set-up  of  webpages  and  expenses 
related  to  website  maintenance  and  updating  information.  Crucially,  these  costs  are 
unrelated to the extent of digitalisation and are much smaller than compliance costs.   

234 

 
 
The company expects additional environmental and social benefits from Policy Option 4 
onwards,  while  economic  benefits  would  be  present  even  in  case  of  Policy  Option  2. 
Consequently, the company would prefer Options 4 or 5a/5b.  

They presently have two factories so a total one-off cost of 40,000 EUR.  

There  would  then  be  the  costs  of  paying  for  an  ongoing  services  (including  software) 
contract with the QR software developer. No costs data was available for this as the firm 
has  spoken  to  a  potential  QR  code  specialist  provider  but  they  have  delayed  making  a 
decision on signing a contract as there are currently no mandatory rules on digital labelling 
and they are awaiting the implementation approach to the FPR 2019.  

They noted that there would be some cost differences compared with physical labelling. In 
theory, it will be more efficient, but in practice, they will at least in the early years of the 
FPR 2019’s implementation have to put a leaflet on every bag. This was seen as being a bit 
costly and not very practical for fertilisers sold in small quantities, say 50 kg bags. 

The  firm  only  produces  bags  in  Ireland,  therefore  they  only  need  to  produce  labels  in 
English. They stated that for exporting firms, there would be costs for both physical and 
digital  labels  associated  with  producing  bags  in  several  EU  languages.  However,  there 
would be no specific additional costs associated with digital labelling in this regard.  

As noted in the previous section, the fertiliser producer saw minor cost savings stemming 
from  digitalisation  but  was  more  interested  in  ensuring  compliance  with  the  significant 
increase in information requirements under the FPR.  

235 

 
 
ANNEX 10: TRENDS IN DIGITALISATION  

1.  DIGITAL LITERACY AND SKILLS AND INTERNET ACCESS 

Consideration is now given to issues relating to the digital divide, including between rural 
and  urban  areas,  different  types  of  socio-economic  groups,  including  the  issue  of 
vulnerable social groups and the extent to which they can get access to digital means of 
accessing fertilising products labels. Any distinctions in digital skills and willingness to 
use  digital  labelling  are  considered,  for  instance,  between  professional  and  non-
professional users. The extent to which there is divergence across the EU-27 and between 
rural  and  urban  areas  in  terms  of  fertilising  products  users’  access  to  the  internet  is 
considered.  Here,  among  the  issues  considered  are  broadband  availability  and  the 
reliability and stability of internet access in different locations, including rural areas.  

Box 10.1: Data availability and gaps 

Whilst some relevant data is available on access to broadband internet and on digital 
skills among the European population, there are also shortcomings in the data.  

For  instance,  DESI  reports  on  broadband  internet  access  at  national  level.  Although 
some  regional  data  exists  through  national  statistical  systems  (NSS),  this  is  not  fully 
comparable across the EU-27, and even sometimes within a Member State (e.g. Italy). 
Despite these challenges, some data on broadband internet at a NUTS III regional level 
has  been  produced  in  the  Study  on  Broadband  Coverage  in  Europe  2020  for  DG 
CNECT. There may be data gaps in some regions, but the picture shown is reasonably 
comprehensive.  

There  is  no  specific  data  available  on  digital  literacy  and  internet  access  among 
fertilising product users, therefore interview feedback and an online survey were used 
to  gather  data.  Views  were  solicited  as  to  how  far  professional  and  non-professional 
users have digital skills and access to the internet whilst at home/ the office and on the 
move.  

Overall, the findings are that:  

  Digital  literacy  is  not  uniform  across  the  EU-27.  In  Northern  Europe,  there  are 

generally higher levels of digital literacy than in Southern Europe.  

  Digital  literacy  varies  by  age  group  and  social  group.  Younger  people  are 

considerably more digitally literate than older people.  

  Digital  literacy  varies  according  to  the  educational  level.  Those  with  no  or  only 
basic education are proportionately much more likely to lack basic digital skills.  

  Access to broadband internet has improved significantly in the past decade. This 
has been driven by different factors, such as major increases in investment in fixed line 
and  mobile  broadband  access.  The  increasing  ubiquity  of  smart  mobile  phones  has 
made broadband access much easier for professional and non-professional users on the 
move to access information about fertilising products.  

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2.  DIGITAL DIVIDE – DIGITAL SKILLS 

Based on the European Digital Competence Framework for Citizens, basic digital skills 
allow  ‘the  confident,  critical  and  responsible  use  of,  and  engagement  with,  digital 
technologies for learning, at work, and for participation in society.’  The following table 
considers  the  extent  to  which  among  the  population  generally,  there  are  digital  skills, 
drawing  on  Eurostat  data  analysed  in  the  human  capital  dimensions  of  DESI  (Digital 
Economy and Society Index), 2021. The data only provides a proxy in that it relates to the 
whole  population,  but  is  useful  when  considering  digital  literacy  issues  among  non-
professional users. 

Box 10.2: Digital literacy among the EU population (relevant to non-professional 
users). 

According to DESI 2021, in 2021, 56% of individuals in the EU-27 had at least basic digital 
skills (covering all ages). 

Socio-demographic factors however mask strong variations in digital literacy depending 
on the age cohort and educational background. For example, as DESI 2021 points out "80% 
of young adults (aged 16-24), 84% of individuals with high formal education, and 87%  of 
students have at least basic digital skills. By contrast, only 33% of those aged 55-74 and 
28% of the retired and the inactive possess at least basic digital skills". 

A substantial digital skills gap persists however between rural and urban areas. Whereas 
only 48% of individuals in rural areas possess at least basic digital skills, this increases to 
62% for those living in cities and urban areas. 

In  earlier  editions  of  DESI  (e.g.  2020  edition  using  2019  data),  a  more  detailed 
disaggregation was provided. 35% of the EU labour force population aged 25-64 years old 
did  not  have  at  least  basic  computer  skills.  The  variation  in  the  active  labour  force 
percentage without at least basic digital competencies across EU MS is considerable. The 
working  populations  without  basic  digital  competencies  in  the  Netherlands,  Finland, 
Sweden, Germany, Denmark, Luxembourg, and Austria constituted less than 30% of the 
population. In contrast, Italy, Cyprus, Latvia, Romania, and Bulgaria lead with the highest 
percentages of digitally incompetent working populations, which accounted for over 50%.  

However,  Eurostat  data  revealed  that  basic  computer  skills  have  been  consistently 
growing in most of the EU Member States. When comparing 2015-2019 data across all 
EU MS, 12 out of EU-27 countries had higher than the EU average (65%) of the working 
population with at least basic digital skills. Furthermore, the data showed that only in seven 
Member  States,  including  Denmark,  Luxembourg,  Estonia,  Greece,  Italy,  Latvia,  and 
Bulgaria,  the  proportion  of  the  working  population  with  basic  digital  competencies 
decreased slightly between 2015-2019. 

Based on the Commission’s Digital  Skills  Indicator, in  2021, Finland demonstrated the 
best  performance  in  the  human  capital  dimensions  of  DESI.  Estonia,  Sweden,  and  the 
Netherlands were also the top countries having high percentages of populations with basic 
and advanced digital skills. On the other hand, Italy, Romania and Bulgaria demonstrated 

237 

 
 
 
the  lowest  rate  of  digitally  advanced  people  in  terms  of  basic  and  more  sophisticated 
computer skills.190   

An OECD study revealed that whilst gender did not have a crucial impact on the level of 
computer skills, age and educational attainment were important determinants of the level 
of competencies within the EU countries. Eurostat statistics confirmed such findings as 
more  than  30%  of  the  population  without  any  education  (or  having  only  low  formal 
education) had basic digital competencies, 85% of adults with a degree in higher education 
had at least basic computer skills. In terms of age, digital literacy of people over 30 years 
old (75%) deteriorated progressively with those over 55 demonstrating the lowest level of 
basic digital skills (43%).191 

The  digital  divide  affects  people  in  rural  areas.  The  statistics  suggest  that  there  is  a 
problem  around  lack  of  basic  digital  skills  in  rural  localities.  This  was  shown  in  the 
previous  table,  as  only  48%  of  the  population  in  rural  areas  has  basic  digital  skills. 
However, the data do not indicate whether these were farm managers, farm owners, retired 
persons, farm labourers, etc. Hence not too much weight should be placed on such data. 

It is important to highlight that cultural factors can be more significant than having access 
to the internet in determining whether users of fertilising products are willing to use digital 
labels.  Demographic  ageing  affects  rural  areas  more  than  urban  areas,  and  older  non-
professional  users  (e.g.  hobby  gardeners)  and  some  older  professional  users  (e.g.  small 
farmers) are less digitally literate than younger users, and also culturally less likely to use 
digital means to access product information. The evidence for this is interview feedback 
from fertiliser industry associations and from fertiliser producing companies, as well as 
some  groups  representing  users.  This  finding  is  also  implicit  from  the  statistics  on  the 
digital society more generally from Eurostat mentioned earlier, which shows that if digital 
literacy is lower in some Member States, especially in Southern and South-Eastern Europe, 
and lower in rural than in urban areas, this is likely to impact the willingness to use digital 
labels.  

Overall, the adoption of digital labelling by users in rural areas can be argued to be more 
dependent on age, educational and cultural factors rather than access to the internet 
being the problem, although the latter can still be an issue in very remote rural areas, or in 
areas with slow internet. 

3.  DIGITAL DIVIDE – ACCESS TO THE INTERNET 

As noted in an analysis of statistics on the digital society, “people living in remote regions 
may  be  excluded  as  a  lack  of  investment  in  infrastructure  leads  to  access  and/or 
performance issues when trying to use the internet”.  192  

190 European Commission. (2021). Digital economy and Society Index (DESI). Available at: https://digital-
strategy.ec.europa.eu/en/policies/desi  
191 European Court of Auditors. (2021). Review 02/2021: EU actions to address low digital skills. Available 
at:  https://www.eca.europa.eu/Lists/ECADocuments/RW21_02/RW_Digital_skills_EN.pdf  
192https://ec.europa.eu/eurostat/statistics-
explained/index.php?title=Digital_society_statistics_at_regional_level#Internet_users 

238 

 
 
                                                 
However, there has been significant EU and national investment in the past decade to 
improve  internet  access  (especially  broadband)  in  rural  areas  which  should  be 
recognised  when  considering  how  far  lack  of  internet  access  in  rural  areas  remains  a 
problem. For instance, investment in broadband infrastructure has been made through a 
combination of EU funding, national government investment and private sector investment 
(often subsidised or incentivised by government to address the digital divide).  
The  main  EU  funding  sources193  for  infrastructure  development  have  been  through 
cohesion policy programmes e.g. ERDF and EAFRD funding. Whilst the latter evidently 
focuses  on rural  areas,  the ERDF has also  sometimes been used to  invest in  broadband 
infrastructure in rural areas. Moreover, the EIB’s large loans scheme has provided funding 
to  invest  in  upgrading  broadband  infrastructures  linked  to  legacy  national  telecoms 
networks.  DG  DEFIS’s  Secure  Connectivity  Initiative  proposal  announced  in  late  2021 
will provide satellite-based connectivity and is designed to improve internet access in rural 
areas. 

Additionally,  there  has  been  significant  private sector  investment  in  mobile  internet 
technologies,  including  4G  and  5G,  such  that  there  is  much  improved  internet  access 
across large areas of the EU-27. Rural locations that can't get decent fixed-line broadband 
access can benefit from 4G. However, in some rural areas, sometimes only 3G is available, 
and there remain pockets where it is either difficult or impossible to get internet access.   

The most recent 2021 DESI Scoreboard found that the problem of the digital divide in 
rural  areas  may  not  be  as  pronounced  today  as  it  was  5-10  years  ago  due  to  rapid 
rollout  of  broadband,  with  mobile  broadband  making  internet  access  widely  accessible 
except  in  some  rural  pockets.  The  2021  DESI  Scoreboard  found  that  97%  of  the  EU 
(including rural areas) provide access to either a fixed or mobile broadband connection, or 
both.  

According to DESI 2021's chapter on connectivity, "over three quarter of EU households 
(77%) had a fixed broadband subscription in 2020, following a steady growth (an annual 
growth rate of 2.1%) over the last 8 years". However, there are considerable variations 
between Member States. For instance, DESI 2021 data shows that national take-up rates 
of fixed broadband “ranged from only 57% to 92%. Cyprus, Germany and the Netherlands 
registered  the  highest  figure,  while  Finland,  Bulgaria,  Italy,  Latvia  and  Lithuania  the 
lowest. The relatively low take-up rates in Finland, Italy, Poland and Latvia may partly be 
due to fixed-mobile substitution". 

In 2020, overall, according to DESI, 91% of households had access to the internet at 
home,  86%  of  individuals  were  regular  internet  users  (using  it  at  least  weekly),  while 
almost 80% were using it either every day or almost every day”. Nevertheless, it was also 
noted that in some countries where people are not using the internet, such as Bulgaria and 
Greece, where one in five individuals has never used the internet (in comparison with circa 
1% of the adult population in Sweden, Luxembourg and Denmark). 

Notwithstanding the progress that has been made, there remain some rural areas across 
the EU-27 with difficulties in accessing the internet. The following Figures highlight 

193 BROADBAND IN THE EU (2017), European Court of Auditors 
https://www.eca.europa.eu/Lists/ECADocuments/AB_BROADBAND/AB_BROADBAND_EN.pdf  

239 

 
 
                                                 
different types of broadband data availability in regions across the EU-27 taken from the 
Study on Broadband Coverage in Europe 2020194.  

In the first  Figure, the situation is shown in  respect of fixed broadband coverage at the 
NUTS III level overall where data is available.  

Figure 10.1: Study on Broadband Coverage in Europe 2020 – fixed broadband coverage 
(NUTS III level) 

Source: Study on Broadband Coverage in Europe 2020, a study by IHS Markit, Omdia and Point Topic.  

The  data  shows  that  there  are  regions  where  fixed  broadband  coverage  is  between  0- 
75%,  such  as  in  parts  of  Spain,  Poland  and  parts  of  Lithuania,  Hungary,  Bulgaria  and 
Romania where it is 75-95%, whereas in most regions, it is around 95%-100%.  

In the next Figure,  rural fixed broadband coverage at the NUTS III level is provided 
across European regions. This shows greater gaps in coverage, for instance in Scandinavia, 
Poland, some of the Baltic States and in Hungary, Bulgaria and Romania.  

194  Study  on  broadband  coverage  in  Europe  2020  -  https://digital-strategy.ec.europa.eu/en/policies/desi-
connectivity  

240 

 
 
 
                                                 
Figure 10.2: Study on Broadband Coverage in Europe 2020 – rural fixed 
broadband coverage (NUTS III level) 

Source: Study on Broadband Coverage in Europe 2020, a study by IHS Markit, Omdia and Point Topic. 

It  should  be  noted  however  that  whilst  these  data  are  useful,  there  is  a  lack  of 
comprehensive data on broadband coverage differentiated between urban and rural 
areas and the occupational mix in those areas. As noted in the earlier overview of data 
shortcomings,  there  are  gaps  in  the  data,  and  in  some  cases,  major  comparability 
problems between and within Member States in terms of regional level data.  

Overall, whilst a rural digital divide persists in some areas, the situation has considerably 
improved in the past 5 years. Smart phones have increasingly become prevalent and mobile 
internet connections have provided a substitute in some rural areas yet to benefit from fixed 
line  infrastructure  upgrades  (as  evidenced  in  DESI,  2021).  There  are  varying  internet 
speeds depending whether in an urban or rural area, with slower access more common in 
rural areas due to the major investment required being more prohibitive. An example here 
was provided earlier that 5G investments are concentrated in major cities, and some rural 
areas have only patchy internet coverage through 4G.    

However, the situation regarding the digital divide between urban and rural areas is not as 
clear-cut  as  is  commonly  supposed.  Some  rural  areas  enjoy  high-speed  internet  access, 
whereas some urban areas are lumbered with legacy networks and lack investment in high-
speed fibre-optic cables. “Some rural areas that have received investment from telecoms 
companies enjoy ultrafast speeds, while nearby “second cities” will be surfing via copper 

241 

 
 
 
phone lines, rather than next-generation access (NGA) — or faster, upgraded networks — 
for the foreseeable future. 195 

In the following Figure, an overview of access to high-speed NGA broadband in rural areas 
is provided:  

Figure 10.3: Overall rural NGA196 broadband coverage, 2020 

Source: Study on Broadband Coverage in Europe 2020, a study by IHS Markit, Omdia and Point Topic. 

There  are  considerable  gaps  in  broadband  coverage  in  some  Member  States  in  rural 
regions, such as France (also Corsica), Spain, parts of Eastern Germany, Poland, Lithuania, 
Hungary, Bulgaria and Romania.  

It should again be recalled that these are partly addressed through mobile internet access.   

195 See inter alia FT Article - Patchy broadband leaves Europe with digital divide (NOVEMBER 21 2018) - 
https://www.ft.com/content/8bbea1ce-ad58-11e8-8253-48106866cd8a  
196 Next Generation Access (NGA) coverage: includes fixed-line broadband access technologies capable of 
achieving  download  speeds  meeting  the  Digital Agenda  objective  of  at  least  30  Mbps  coverage,  such  as 
combination of VDSL, DOCSIS 3.0, and FTTP. 

242 

 
 
 
                                                 
In  addition  to  the  secondary  data  presented  earlier,  some  primary  data  was  collected. 
Among the survey findings were that:  

  The  stakeholders  usually  have  access  to  the  internet  at  least  in  some  places.  Most 
professional users surveyed selected that they have the internet at home (85.7%) and 
the  office  (55.3%).  Non-professional  users  said  that  they  have  the  internet  at  home 
(96.2%) and on-the-go (64%). 

  Stakeholders who check, assess, or inspect fertilising products also said that they have 
the internet at home (93.3%), at the office (83.3%) and while travelling (63.3%). 

Statistical data on access to internet (connectivity) and digital devices also show that 
there is a digital divide between some types of users by socio-economic group. While most 
households  in  the  EU  have  no  problem  connecting  to  the  internet  or  accessing  digital 
devices,  some  rural  areas  might  be  problematic  in  this  regard.  In  addition,  the  research 
identified differences between access to the internet depending whether both professional 
and non-professional users were in the office (professional) or home (non- professional), 
where net access was very high or out in fields, gardens etc. where access to the internet 
dropped.  

Those lacking digital skills include not only more elderly people, but also more traditional 
farmers and hobby users, blind and partially-sighted people, the less well educated, and 
those living in rural areas (the latter especially in some MS, where more than half of the 
population lack basic digital skills – see data presented earlier). 

The analysis of statistical data on internet connectivity and access to devices in the EU is 
presented in the box below. 

Based on Statista Research Department data197, in 2020, a significant 91% of households 
across  the  EU  had  access  to  the  internet.  In  comparison,  in  2019,  the  percentage  of 
households  connected  to  the  internet  accounted  for  90%.  The  Netherlands  (97%), 
Germany (96%), Finland (96%), Denmark (95%) and Sweden (94%) lead with internet 
connectivity coverage in households. In contrast, the lowest rates of internet connectivity 
were  observed  in  countries  like  Greece  (80%)  and  Bulgaria  (79%).  In  terms  of  the 
selected  Member  States  of  interest  (Denmark,  France,  Germany,  Lithuania,  Poland, 
Romania, Spain), the highest proportion (96%) of households with internet connectivity 
in 2020 was found in Germany, whereas Lithuania had the weakest performance (82%) 
in this area.  

There is some gap in households’ access to the internet when comparing urban and rural 
areas. While households in cities and other suburbs demonstrated internet accessibility 
rates accounting for 92% and 89%, respectively, households in rural areas were not so 
advanced (86%).198 The urban-rural gap was most accurate in Greece, Bulgaria, Portugal, 
Slovenia, and Romania as these countries demonstrated lower than the EU average level 
of  internet  connectivity  (85%).  Germany  had  the  same  level  of  internet  connectivity 

197  Statista.  (2021).  Household  internet  access  in  European  countries  2017-2020.  Available  at: 
https://www.statista.com/statistics/185663/internet-usage-at-home-european-countries/  
198  Eurostat.  (2020).  Digital  economy  and  society  statistics  –  households  and  individuals.  Available  at: 
https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Digital_economy_and_society_statistics_-
_households_and_individuals#Internet_access  

243 

 
 
                                                 
across households in cities and rural areas (96%). In contrast, the Netherlands (one per 
cent  lower  in  urban  areas)  and  Denmark  (one  per  cent  higher  in  urban  areas) 
demonstrated almost identical proportions of households. In Sweden, the highest level 
of internet connectivity was found in rural (97%) rather than urban areas (95%).  

International  Telecommunication  Union  analysis199  in  2019  revealed  that  the  gap  in 
internet  access  between  urban-rural  areas  is  not  the  same  as  the  divide  in  computer 
access. That is to say, the urban-rural gap is even wider in household computer access 
than in internet connectivity. In Europe, 82% of households in urban areas had access to 
a computer, whereas only 66% percent of households in rural areas had such privilege.  

The results of the external study, when complemented with statistical data, clearly show 
that some professional users, especially farmers, can be at a disadvantage in the context 
of the digitalisation of fertilising product labels. The reasons for this disadvantage are the 
fact that many farms are located in rural areas which have worse internet connectivity and 
the fact that farmers are often older citizens, potentially having limited digital skills.  

Overall,  whilst  digitalisation  is  a  major  trend  and  whilst  the  percentage  of  European 
citizens and businesses with access to broadband/ the internet has significantly increased 
in the past decade, not all social groups throughout the EU (and not all non-professional 
users) have access to reliable and stable internet. Moreover, particular social groups, such 
as elderly hobby gardeners, may have less access to the internet. However, it should also 
be recognised that whilst some users may face challenges in using digital technologies, 
many older people are able to use smartphones and having a QR code with digital product 
information would enable them to  enlarge the size of a fertiliser label compared with  a 
physical equivalent, where sometimes very detailed label information needs to be included, 
depending on the specific product types, as the requirements vary between fertilisers. 

The issue of the digital divide was considered when deciding which countries to focus on 
for the research. Generally it is also more isolated and rural communities/ areas where there 
is a gap in access to the internet. Some details provided in Broadband coverage in Europe 
2020200 confirm that for example that in some areas, e.g. northern Spain, this is the case.    

A further issue of relevance to both  agricultural  and hobby users is that there are some 
members of society that are not very conversant with digital technologies. Thus there are 
different  types of farmers  –  for example it was  mentioned that in  Spain  there are more 
traditional  farmers  who  tend  to  be  older  and  not  very  au  fait  with  digital  technology, 
whereas others are focused on maximising production and export markets and are highly 
conversant with digital technologies. Age is also an issue, as for example hobby gardeners 
are often elderly and not very digitally literate.  

For not-sighted people, or those with little sight, it might be that some information on the 
physical label is accessible (maybe through braille?), but providing such information in a 
digital format presents some challenges (although some sites can provide spoken text).  

199 International Telecommunication Union. (2020). Measuring digital development. Facts and figures 2020. 
Available at: https://www.itu.int/en/ITU-D/Statistics/Documents/facts/FactsFigures2020.pdf  
200  Broadband  coverage  in  Europe  2020,  DG  Communications  Networks  and  Technology,  p.56  by  IHS 
Markit, OMDIA and Point Topic    

244