FPR - Regulation (EU) 2019/1009

What FPR is and why it matters

The Fertilising Products Regulation (FPR) — formally Regulation (EU) 2019/1009 laying down rules on the making available on the market of EU fertilising products — is the EU framework that lets a fertilising product carry the CE mark and circulate freely across the single market. If you make or import fertilisers, soil improvers, growing media, liming materials, plant biostimulants or related products, FPR is the route to selling one compliant product across all Member States rather than navigating a patchwork of national approvals.

FPR matters because it is an optional harmonisation measure. A product that meets its requirements becomes an “EU fertilising product,” bears the CE mark and benefits from free movement throughout the Union. But FPR does not abolish national regimes: a manufacturer can still place a fertiliser on a single national market under that country’s own rules, relying on mutual recognition rather than the CE route. The Regulation also brought important innovations — most notably bringing organic and waste-derived fertilisers, biostimulants and recycled nutrients into the harmonised framework, and introducing limits on contaminants such as cadmium that were not consistently controlled before.

📄 Official text: Regulation (EU) 2019/1009 on EU fertilising products — on EUR-Lex →

Who FPR applies to

FPR applies across the supply chain rather than to a single actor. The duties scale with your role, but every link is covered:

Manufacturers — anyone who makes an EU fertilising product, or who has it made and markets it under their own name or trademark. They carry the heaviest obligations, including conformity assessment, technical documentation and drawing up the EU declaration of conformity.
Importers — businesses bringing fertilising products from outside the EU into the Union market. They must verify the manufacturer has carried out the correct conformity assessment, that documentation exists and that the CE marking and labelling are in order.
Distributors — wholesalers and retailers further down the chain who must act with due care, check that the CE marking, labelling and required documents are present, and not make available products they know or should presume to be non-compliant.
Authorised representatives — where a manufacturer appoints one, they carry the specific tasks set out in their written mandate.

The Regulation covers EU fertilising products only — those a manufacturer chooses to CE-mark. Products placed on the market under purely national rules, and certain categories such as those covered by the animal by-products or plant protection regimes, sit outside or at the edges of FPR’s harmonised scope.

Key dates and timeline

2019 — Regulation (EU) 2019/1009 was adopted and entered into force, starting a transition period for industry, notified bodies and authorities to prepare.
16 July 2022 — FPR applies from this date. From this point a product can be CE-marked as an EU fertilising product and circulate freely on that basis.
On that same date, FPR repealed Regulation (EC) No 2003/2003 (the previous “EC fertiliser” regime), which had been limited mainly to inorganic mineral fertilisers. Because FPR is a regulation, it is directly applicable in all Member States without national transposition.
The cadmium limit for phosphate fertilisers is structured as a stepwise control, with the framework allowing for tightening over time, reflecting the long political negotiation over how far to lower cadmium in phosphate-based products.

Core requirements

Product Function Categories (PFCs)

FPR classifies products by what they do, not by what they are made of. Each EU fertilising product falls into a Product Function Category (PFC) — for example fertilisers (further split into organic, organo-mineral and inorganic), liming materials, soil improvers, growing media, inhibitors, plant biostimulants and fertilising product blends. Each PFC sets its own requirements: minimum nutrient contents, permitted claims, contaminant limits and the safety and efficacy criteria the product must meet. Choosing the correct PFC is the first compliance decision, because it determines everything that follows.

Component Material Categories (CMCs)

In parallel, FPR controls what an EU fertilising product may be made from through Component Material Categories (CMCs) — for example virgin material substances, plants and plant extracts, compost, digestate, by-products of industry, certain recovered materials and others. A product must be composed exclusively of materials drawn from the permitted CMCs, each meeting its own conditions. The PFC and CMC system is the heart of FPR: a compliant product is one whose function fits a PFC and whose ingredients all fit allowed CMCs.

Contaminant limits, including cadmium

FPR sets contaminant limits to protect health and the environment, covering heavy metals and other contaminants depending on the PFC. The most politically significant is the stepwise cadmium limit for phosphate fertilisers, which caps cadmium in products above a defined phosphorus content. This was a central reason for the Regulation and addresses the gradual accumulation of cadmium in agricultural soils from phosphate fertiliser use. Limits for other contaminants — such as lead, mercury, nickel, arsenic and, for organic inputs, pathogens — are set per category.

Conformity assessment and CE marking

Before applying the CE marking, a manufacturer must put the product through the conformity assessment module specified for its PFC and composition. For lower-risk products this can be internal production control (Module A) carried out by the manufacturer alone; for higher-risk categories — for example certain biostimulants or products made from particular recovered materials — a notified body must be involved, assessing the product, the manufacturer’s quality system or both. On passing, the manufacturer draws up the EU declaration of conformity, compiles the technical documentation and affixes the CE marking (with the notified body’s identification number where one was involved).

Labelling requirements

FPR imposes detailed labelling requirements so that users get accurate, comparable information. Labels must state the PFC, the declared nutrient content and form, instructions for intended use and dosage, relevant safety and handling information, and the manufacturer’s and importer’s identification. Information must be provided in a language easily understood by end-users in the Member State where the product is made available. Labelling claims are constrained to what the relevant PFC permits, which prevents misleading agronomic claims.

Obligations by role

Manufacturers — assign the correct PFC, use only permitted CMCs, run the right conformity assessment module, hold technical documentation, draw up the EU declaration of conformity, apply the CE marking and ensure compliant labelling.
Importers — verify the manufacturer’s conformity assessment and documentation, check the CE marking and labelling, add their own identification and refuse non-compliant products.
Distributors — check that the CE marking, declaration and labelling are present, store and transport products with due care, and stop making available products they believe to be non-compliant.
Authorised representatives — perform the tasks set out in their mandate, typically keeping documentation available and cooperating with authorities.

Enforcement

FPR is enforced through the EU’s market surveillance framework, with each Member State designating competent authorities. Notified bodies are designated and overseen at national level, and their work is essential for the PFCs that require third-party assessment. Authorities can require corrective action, restrict or withdraw non-compliant products and challenge improper use of the CE marking.

Because FPR is optional harmonisation, the alternative national route remains: a fertiliser that does not carry the CE mark can still be mutually recognised and sold under a Member State’s own rules, so manufacturers should decide deliberately which route fits each product and market. The qualitative reality for a brand is that an incorrectly classified product, a contaminant exceedance or an unsupported label claim can lead to removal from the market across the EU once flagged.

Getting compliant

Decide whether to take the CE route under FPR or sell under national rules via mutual recognition.
Identify the correct PFC for each product and confirm it meets that category’s nutrient, efficacy and contaminant requirements.
Verify every ingredient falls within a permitted CMC and meets its conditions.
Check contaminant limits, with particular attention to the stepwise cadmium limit for phosphate fertilisers.
Run the conformity assessment module required for the PFC, involving a notified body where mandated.
Compile technical documentation and draw up the EU declaration of conformity.
Affix the CE marking and prepare labelling that meets FPR’s content and language requirements.

How Conphora helps

Conphora monitors FPR and maps your products against its requirements, flagging gaps in PFC classification, permitted CMCs, contaminant limits, conformity assessment and labelling before they become enforcement problems. The platform helps you generate and keep the right documentation, including the EU declaration of conformity, and alerts you when obligations change so your compliance stays current.

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Sources and further reading

This guide is for general information and is not legal advice.

Last updated: 12 June 2026