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FPR Fertilisers 13 min Changing in the next 12 months

FPR: Fertilising Products Regulation (Regulation (EU) 2019/1009), explained

The Fertilising Products Regulation sets the rules under which fertilisers, soil improvers, growing media, inhibitors and plant biostimulants may be CE marked as EU fertilising products, binding manufacturers, importers and distributors, while national rules remain an option. It has applied since 16 July 2022; digital labelling applies from 1 May 2027 and the polymer rules from 17 October 2028.

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Reviewed 24 September 2026 by Conphora compliance team · Next review 12 March 2027 · Not legal advice

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Who it applies to

Covered by the act

  • Fertilising products that are CE marked when made available on the Union market, the EU fertilising products: fertilisers, liming materials, soil improvers, growing media, inhibitors, plant biostimulants and blends of these (PFC 1 to PFC 7)
  • Substances, mixtures, micro-organisms or other materials applied or intended to be applied on plants or their rhizosphere, or on mushrooms or their mycosphere, or intended to constitute the rhizosphere or mycosphere, to provide nutrients or improve nutrition efficiency
  • The component materials they are made of, which must belong to one of the 15 component material categories: virgin substances and mixtures, plants and plant extracts, compost, digestates, food industry by-products, micro-organisms, polymers, derived animal products, by-products within the meaning of the Waste Framework Directive, precipitated phosphate salts, ashes, biochar and recovered high purity materials
  • The economic operators in the chain: manufacturers, authorised representatives, importers and distributors, including online sellers who make EU fertilising products available in the Union
  • Waste used as component material, which ceases to be waste from the moment the EU declaration of conformity is drawn up (end-of-waste status)

Derived and downstream products

  • Harmonisation is optional: a fertilising product may still be placed on the market under the national rules of a Member State without the CE marking, and the regulation leaves Member States free to regulate such products (Art. 3(1), Art. 38(9) and Art. 41(2); Commission FAQ, question 2.1)
  • Animal by-products and derived products still subject to Regulation (EC) No 1069/2009 and plant protection products under Regulation (EC) No 1107/2009 are outside the regulation; derived products for which an end point in the manufacturing chain has been determined can be used as CMC 10 component materials (Art. 1(1) and Art. 42(5))
  • An importer or distributor that places an EU fertilising product on the market under its own name or trade mark, or modifies it in a way that may affect compliance, is treated as the manufacturer; one that only packages or repackages must add 'packaged by' or 'repackaged by' with its details and keep the original information for 5 years (Art. 10 and Art. 11)
  • EC fertilisers placed on the market under Regulation (EC) No 2003/2003 before 16 July 2022 may continue to be made available, but the Chapter V market surveillance rules apply to them (Art. 52)
  • A Member State that on 14 July 2019 held a cadmium derogation from Regulation (EC) No 2003/2003 may keep applying its national cadmium limits to EU fertilising products until harmonised limits at or below its level apply (Art. 3(2))
  • The regulation does not affect REACH, CLP, the Nitrates Directive, the Sewage Sludge Directive, organic production, plant health, invasive alien species, explosives precursors and the other acts listed in Article 1(2), and Member States may keep or adopt rules on the use of EU fertilising products that do not change the product or the conditions for making it available (Art. 1(2) and Art. 3(3))

Roles under the act

Manufacturer (including brand owners)

Any natural or legal person who manufactures an EU fertilising product or has an EU fertilising product designed or manufactured, and markets that EU fertilising product under his or her name or trademark; an importer or distributor that sells under its own name or trademark or modifies the product in a way that may affect compliance is treated as the manufacturer.

Source · Art. 2, point (11), and Art. 10
Authorised representative

Any natural or legal person established within the Union who has received a written mandate from a manufacturer to act on his or her behalf in relation to specified tasks; the duty to design and manufacture to Annexes I and II and to draw up the technical documentation cannot form part of the mandate.

Source · Art. 2, point (12), and Art. 7(1)
Importer

Any natural or legal person established within the Union who places an EU fertilising product from a third country on the Union market.

Source · Art. 2, point (13)
Distributor (wholesaler or retailer)

Any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes an EU fertilising product available on the market.

Source · Art. 2, point (14)

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Does FPR apply to your product?

Three questions, a first answer from the regulation’s own scope rules. No account needed.

The rules behind this check
  1. Fertilising product sold under national rules without the CE marking · any · any Not in scope The regulation applies only to EU fertilising products, meaning fertilising products that are CE marked when made available on the market; a product sold under a Member State's national rules is outside it, remains subject to national law and mutual recognition, and must not bear the CE marking. Source · Art. 1(1), Art. 2, point (2), Art. 3(1) and Art. 38(9)Source · questions 2.1 and 6.10
  2. Animal by-product or derived product still subject to Regulation (EC) No 1069/2009, Plant protection product within Regulation (EC) No 1107/2009 · any · any Not in scope The regulation does not apply to animal by-products or derived products that are subject to Regulation (EC) No 1069/2009 when made available on the market, nor to plant protection products within Regulation (EC) No 1107/2009; a derived product only becomes usable as a CMC 10 component material once an end point in the manufacturing chain has been determined. Source · Art. 1(1), points (a) and (b), and Art. 42(5)
  3. EC fertiliser placed on the market under Regulation (EC) No 2003/2003 before 16 July 2022 · any · any It depends A product placed on the market as an EC fertiliser in conformity with Regulation (EC) No 2003/2003 before 16 July 2022 may continue to be made available, and the burden of proving that date lies with the supplier; the market surveillance rules of Chapter V apply to it, and a changed composition or a new product needs a full conformity assessment under this regulation. Source · Art. 51 and Art. 52Source · questions 6.2 to 6.4
  4. EU fertilising product made with compost, digestate, struvite, ashes, biochar or recovered high purity materials (CMC 3, 5, 12, 13, 14 and 15) · Manufacturer (including brand owners), Importer, Distributor (wholesaler or retailer), Authorised representative · any In scope An EU fertilising product containing compost, digestate other than fresh crop digestate, precipitated phosphate salts, thermal oxidation materials, pyrolysis and gasification materials or recovered high purity materials cannot use Module A or Modules B and C, so it goes through Module D1 quality assurance of the production process with a notified body that audits annually and samples the output material; the waste ceases to be waste when the EU declaration of conformity is drawn up. Source · Art. 19 and Annex IV, Part I, points 1.1, 3.1 and 4.1, and Part II, Module D1, point 6.3.2
  5. Nitrification, denitrification or urease inhibitor, or plant biostimulant, to be CE marked (PFC 5 and 6) · Manufacturer (including brand owners), Importer, Distributor (wholesaler or retailer), Authorised representative · any In scope Inhibitors of PFC 5 and plant biostimulants of PFC 6 may not use Module A internal production control; the manufacturer must use EU-type examination followed by conformity to type (Modules B and C) or Module D1, both involving a notified body whose identification number follows the CE marking. Source · Art. 18(3) and Annex IV, Part I, points 1.3, 3.1 and 4.1
  6. Inorganic macronutrient or micronutrient fertiliser to be CE marked, including ammonium nitrate fertiliser of high nitrogen content (PFC 1(C)) · Manufacturer (including brand owners), Importer, Distributor (wholesaler or retailer), Authorised representative · any In scope An inorganic fertiliser made from CMC 1 virgin materials may use Module A, but a phosphate fertiliser with 5 % P2O5 or more must stay under 60 mg cadmium per kg P2O5 (3 mg/kg dry matter below 5 %), and a straight or compound solid ammonium nitrate fertiliser of high nitrogen content must use Module A1 with the detonation test, from 1 July 2026 in an accredited laboratory. Source · Annex I, PFC 1(C)(I), point 2(a), and Annex IV, Part I, points 1.1, 1.3 and 2, and Part II, Module A1, point 4 (M12)
  7. Organic or organo-mineral fertiliser to be CE marked (PFC 1(A) and 1(B)), Liming material, soil improver or growing medium to be CE marked (PFC 2, 3 and 4), Blend of two or more EU fertilising products (PFC 7) · Manufacturer (including brand owners), Importer, Distributor (wholesaler or retailer), Authorised representative · any In scope An EU fertilising product may only be made available if it complies with the regulation: it must meet the Annex I requirements of its product function category, consist solely of Annex II component materials, be labelled per Annex III and pass the Annex IV module that its component materials allow; a blend must be made of EU fertilising products that each passed their own assessment, and none of the duties depend on company size. Source · Art. 4, Art. 5, Art. 6, Annex I, PFC 7, and Annex IV, Part I
  8. any · any · any It depends Whether the regulation applies turns on whether the product is to be CE marked as an EU fertilising product, whether an Article 1(1) exclusion applies, which product function category and component material categories it falls under, and which role the operator holds. Source · Art. 1, Art. 2 and Art. 4

Key dates

  1. Regulation (EU) 2019/1009 adopted by the European Parliament and the Council in Brussels Source · title (Regulation of 5 June 2019) and signature block after Art. 53
  2. Entry into force, the twentieth day after publication in OJ L 170 of 25 June 2019; Articles 4(3), 14 and 42 to 47 (labelling guidance, common specifications, delegated acts, committee and the amendments to the animal by-products and plant protection regulations) apply from this date Source · Art. 53
  3. Articles 20 to 36 on the notification of conformity assessment bodies apply, so that notified bodies could be designated before the regulation applied in full Source · Art. 53, point (b)
  4. Deadline for the Commission to publish a guidance document for manufacturers and market surveillance authorities on the visual appearance of the Annex III label Source · Art. 4(3)
  5. Delegated Regulation (EU) 2021/1768 in force: first technical adaptation of Annexes I to IV, applying from 16 July 2022 Source · Art. 2 and OJ L 356 of 8 October 2021
  6. Delegated Regulations (EU) 2021/2086, 2021/2087 and 2021/2088 in force: CMC 12 precipitated phosphate salts and derivates, CMC 13 thermal oxidation materials and derivates and CMC 14 pyrolysis and gasification materials added, applying from 16 July 2022 Source · Art. 2Source · Art. 2Source · Art. 2 and OJ L 427 of 30 November 2021
  7. The regulation applies in full; Regulation (EC) No 2003/2003 repealed; EC fertilisers placed on the market before this date may continue to be made available, subject to the Chapter V market surveillance rules; deadline for the delegated act on by-product criteria in CMC 11 Source · Art. 42(7), Art. 51, Art. 52 and Art. 53
  8. Delegated Regulation (EU) 2022/1171 in force: CMC 15 recovered high purity materials added, applying from 16 July 2022 Source · Art. 2 and OJ L 183 of 8 July 2022
  9. Delegated Regulation (EU) 2022/1519 in force: inhibiting compounds, post-processing of digestate, polymer registration and the PCB limit for CMC 14 Source · Art. 2 and OJ L 236 of 13 September 2022
  10. Delegated Regulation (EU) 2023/409 in force: minimum calcium oxide content of a straight solid inorganic macronutrient fertiliser set at 9 % by mass Source · Art. 1 and Art. 2 and OJ L 59 of 24 February 2023
  11. Delegated Regulation (EU) 2024/1682 in force: processed manure added to CMC 10 with its own processing, PAH16, storage and labelling conditions Source · Art. 2 and OJ L 2024/1682 of 13 June 2024
  12. Deadline for the Commission to assess biodegradability criteria for CMC 9 polymers and to review the possibility of including mulch films in CMC 9 Source · Art. 42(6) and Art. 50
  13. Regulation (EU) 2024/2516 in force: digital labelling of EU fertilising products (Articles 11a to 11c), applying from 1 May 2027 Source · Art. 2 and OJ L 2024/2516 of 30 September 2024
  14. Delegated Regulation (EU) 2024/2770 in force: biodegradability criteria for coating agents and water retention polymers in CMC 9; Annex I and point 1 of Annex II of that act apply from 17 October 2028 Source · Art. 2 and OJ L 2024/2770 of 28 October 2024
  15. Delegated Regulations (EU) 2024/2786 (enterococci and presumption of conformity without verification), 2024/2787 (mulch films in CMC 9), 2024/2788 (polymers in CMC 11) and 2024/2790 (polymers in CMC 1) in force; the two polymer acts apply from 17 October 2028 Source · Art. 2Source · Art. 2Source · Art. 2Source · Art. 2 and OJ L of 31 October 2024
  16. Delegated Regulation (EU) 2025/1421 in force: under Module D1 the notified body carries out annual audits and samples output material for CMCs 3, 5, 12, 13, 14 and 15 Source · Art. 1(2) and Art. 2 and OJ L 2025/1421 of 10 December 2025
  17. Module A1 thermal cycles and detonation test for ammonium nitrate fertilisers of high nitrogen content must be carried out in laboratories accredited for those activities (Article 1(1) of Delegated Regulation (EU) 2025/1421, date set by the corrigendum of 15 December 2025) Source · Art. 2 as correctedSource · Annex IV, Part II, Module A1, point 4 (M12)
  18. Deadline for the Commission's report to the European Parliament and the Council on the application of the regulation, including the review of the cadmium limit values for phosphate fertilisers and of the other contaminant limits Source · Art. 49
  19. Digital labelling rules of Regulation (EU) 2024/2516 apply: Articles 11a to 11c, the amended Articles 6(5) to 6(7), 8(3) to 8(4) and 9(2), and the Annex III and IV changes; deadline for the Commission's delegated acts on digital labelling requirements Source · Art. 1, point (5), and Art. 2
  20. Polymer rules apply: biodegradability criteria for coating agents and water retention polymers in CMC 9 (Delegated Regulation (EU) 2024/2770), and polymers in CMC 1 and CMC 11 aligned with the REACH microplastics restriction (Delegated Regulations (EU) 2024/2790 and 2024/2788) Source · Art. 2Source · Art. 2Source · Art. 2

What you must do

Obligations by role

Manufacturer (including brand owners)14
  • Design and manufacture the EU fertilising product to meet the Annex I requirements of its product function category, including the contaminant, pathogen and nutrient-content limits, and use only component materials that comply with one or more of the Annex II component material categories; for any aspect not covered by those Annexes the product must not present a risk to human, animal or plant health, to safety or to the environment. Art. 4(1), Art. 4(2) and Art. 6(1)
  • Before placing the product on the market, draw up the technical documentation of Annex IV. Art. 6(2) and Annex IV, Part I
  • Carry out or commission the Annex IV conformity assessment module allowed for your component materials and category: Module A, Module A1 for ammonium nitrate fertilisers of high nitrogen content, Modules B and C, or Module D1 with a notified body for compost, digestate and the recovered materials of CMCs 12 to 15, inhibitors and biostimulants. Art. 6(2) and Art. 15
  • Draw up the EU declaration of conformity on the Annex V model with the elements of the module used, keep it continuously updated, translate it into the languages required by the Member State where the product is placed or made available, and combine it into a single declaration where another Union act also requires one; by drawing it up you assume responsibility for compliance, and material that was waste ceases to be waste at that moment. Art. 16 and Art. 19
  • Affix the CE marking visibly, legibly and indelibly to the packaging or, for products supplied without packaging, to an accompanying document, before placing the product on the market, followed by the notified body's identification number where Annex IV requires one. Art. 17 and Art. 18
  • Keep the technical documentation and the EU declaration of conformity for 5 years after the product was placed on the market. Art. 6(3)
  • Give other economic operators a copy of the EU declaration of conformity on request. Art. 6(3)
  • Keep series production in conformity, taking account of changes in the production process, the product or the harmonised standards, common specifications or other technical specifications referenced. Art. 6(4)
  • Where the performance or the risks of a product warrant it, sample-test marketed products, investigate complaints and keep a register of complaints, non-conforming products and recalls, and keep distributors informed. Art. 6(4)
  • Mark the packaging, or the accompanying document for unpackaged products, with a type number, batch number or other identifier and with your name, registered trade name or trade mark and a single postal contact address, in a language easily understood by end-users and market surveillance authorities. Art. 6(5) and Art. 6(6)
  • Provide the Annex III labelling on a label affixed to the package, in a leaflet for information that does not fit or for unpackaged products, in a language easily understood by end-users as determined by the Member State: the PFC designation, quantity, instructions for use with application rates, timing and frequency, storage conditions, risk-management information, the ingredient list above 5 %, the nutrient declaration and warnings, and from 1 May 2027 optionally as a digital label under Articles 11a to 11c. Art. 6(7) and Annex III, Part IArt. 1, points (2) and (4), and Art. 2
  • If you consider or have reason to believe that a product you placed on the market does not conform, immediately bring it into conformity, withdraw or recall it, and where it presents a risk inform the competent national authorities of every Member State where you made it available. Art. 6(8)
  • On a reasoned request from a competent national authority, provide all the information and documentation needed to demonstrate the conformity of the EU fertilising product, in a language that authority can easily understand, and cooperate with it on any action to eliminate the risks posed by EU fertilising products you placed on the market. Art. 6(9)
  • Be able to identify to the market surveillance authorities, for 5 years after the supply, every economic operator that supplied you with an EU fertilising product and every economic operator you supplied with one. Art. 12
Authorised representative7
  • Act as authorised representative only under a written mandate from the manufacturer that sets out the tasks you perform. Art. 7(1) and Art. 7(2)
  • Keep the EU declaration of conformity and the technical documentation at the disposal of the national market surveillance authorities for 5 years after the product was placed on the market. Art. 7(2), point (a)
  • On a reasoned request from a competent national authority, provide all the information and documentation necessary to demonstrate the conformity of the EU fertilising product, and cooperate with the authorities on any action taken to eliminate the risks posed by the products covered by your mandate. Art. 7(2), points (b) and (c)
  • Do not take over the manufacturer's duty to design and manufacture to Annexes I and II or to draw up the technical documentation; those obligations cannot form part of the mandate. Art. 7(1)
  • Where a notified body is involved and instructs you to, affix its identification number after the CE marking. Art. 18(3)
  • For fertilising product blends, keep the EU declaration of conformity of each component product. Annex I, PFC 7, point 4(b)
  • Be able to identify to the market surveillance authorities, for 5 years after the supply, every economic operator that supplied you with an EU fertilising product and every economic operator you supplied with one. Art. 12
Importer13
  • Place only compliant EU fertilising products on the market, and before doing so check that the manufacturer carried out the appropriate Annex IV conformity assessment, drew up the technical documentation, applied the identification and the name and address required by Article 6(5) and (6), and that the product is accompanied by the required documents; hold back a product you believe is non-conforming until it complies, and inform the manufacturer and the market surveillance authorities where it presents a risk. Art. 8(1) and Art. 8(2)
  • Indicate your name, registered trade name or trade mark and postal contact address on the packaging or, for unpackaged products, in an accompanying document, in a language easily understood by end-users and market surveillance authorities. Art. 8(3)
  • Ensure the product is accompanied by the Annex III information on a label affixed to the package, in a leaflet where the package is too small or the product is unpackaged, in a language easily understood by end-users as determined by the Member State, and from 1 May 2027 in the physical or digital form allowed by Article 11a. Art. 8(4)Art. 1, points (3) and (4), and Art. 2
  • While a product is under your responsibility, keep its storage and transport conditions from jeopardising its compliance with Annex I or Annex III. Art. 8(5)
  • Where the performance or the risks of a product warrant it, sample-test marketed products, investigate complaints and keep a register of complaints, non-conforming products and recalls, and keep distributors informed. Art. 8(6)
  • If a product you placed on the market does not conform, immediately take corrective measures, withdraw or recall it, and where it presents a risk inform the competent national authorities of the Member States concerned with details of the non-compliance and the measures taken. Art. 8(7)
  • Keep a copy of the EU declaration of conformity at the disposal of the market surveillance authorities for 5 years after the product was placed on the market, and ensure the technical documentation can be made available to them on request. Art. 8(8)
  • Give other economic operators a copy of the EU declaration of conformity on request. Art. 8(8)
  • On a reasoned request from a competent national authority, provide all the information and documentation needed to demonstrate the conformity of the EU fertilising product, in a language that authority can easily understand, and cooperate with it on any action to eliminate the risks posed by EU fertilising products you placed on the market. Art. 8(9)
  • Be able to identify to the market surveillance authorities, for 5 years after the supply, every economic operator that supplied you with an EU fertilising product and every economic operator you supplied with one. Art. 12
  • If you place the product on the market under your own name or trade mark, or modify it in a way that may affect compliance, you carry the manufacturer's obligations under Article 6. Art. 10
  • If you only package or repackage the product, add 'packaged by' or 'repackaged by' with your name, registered trade name or trade mark and postal address. Art. 11(a)
  • If you package or repackage the product, keep a specimen of the original labelling information at the disposal of the market surveillance authorities for 5 years. Art. 11(b)
Distributor (wholesaler or retailer)9
  • Act with due care and, before making a product available, verify that it is accompanied by the required documents and the Annex III information in a language easily understood by end-users in the Member State where it is sold, and that the manufacturer and the importer have applied the identification, name and address required by Articles 6(5), 6(6) and 8(3); hold back a product you believe is non-conforming and inform the manufacturer or importer and the market surveillance authorities where it presents a risk. Art. 9(1) and Art. 9(2)
  • Keep storage and transport conditions from jeopardising compliance with Annex I or Annex III while the product is under your responsibility. Art. 9(3)
  • If a product you made available does not conform, make sure corrective measures are taken to bring it into conformity, withdraw or recall it, and where it presents a risk immediately inform the competent national authorities of the Member States concerned. Art. 9(4)
  • On a reasoned request from a competent national authority, provide all the information and documentation needed to demonstrate the conformity of the EU fertilising product, in a language that authority can easily understand, and cooperate with it on any action to eliminate the risks posed by EU fertilising products you made available. Art. 9(5)
  • Be able to identify to the market surveillance authorities, for 5 years after the supply, every economic operator that supplied you with an EU fertilising product and every economic operator you supplied with one. Art. 12
  • If you sell the product under your own name or trade mark, or modify it in a way that may affect compliance, you take on the manufacturer's obligations. Art. 10
  • If you only package or repackage the product, add 'packaged by' or 'repackaged by' with your name, registered trade name or trade mark and postal address. Art. 11(a)
  • If you package or repackage the product, keep a specimen of the original labelling information at the disposal of the market surveillance authorities for 5 years. Art. 11(b)
  • From 1 May 2027, where a product is supplied to end-users without packaging with a digital label only, post the digital label information in a visible place at the point of sale, and provide the information by alternative means on request or when the digital label is unavailable at the time of purchase. Art. 1, point (4) (Article 11c), and Art. 2

FPR in plain terms

The Fertilising Products Regulation (FPR), formally Regulation (EU) 2019/1009, is the EU’s CE-marking law for fertilising products. It applies to EU fertilising products, meaning fertilising products that are CE marked when made available on the market (Art. 1(1) and Art. 2, point (2)), and a fertilising product is any substance, mixture, micro-organism or other material applied or intended to be applied on plants or their rhizosphere, or on mushrooms or their mycosphere, or intended to constitute the rhizosphere or mycosphere, whether on its own or mixed with another material, to provide nutrients or improve nutrition efficiency (Art. 2, point (1)); the last limb is what brings growing media of PFC 4 within the definition. A product that meets the regulation may be CE marked and Member States may not impede its making available for reasons of composition, labelling or other aspects the regulation covers (Art. 3(1)).

Unlike most CE-marking laws, harmonisation is optional. The regulation applies only to products the manufacturer chooses to CE mark; it leaves Member States free to regulate fertilising products that are not EU fertilising products (Art. 38(9) and Art. 41(2)), and the Commission’s FAQ spells out the three options: apply the regulation and affix the CE mark, follow national rules and rely on mutual recognition elsewhere, or do both. As a regulation it applies directly in every Member State without transposition. It entered into force on 15 July 2019 and has applied in full since 16 July 2022, when it repealed Regulation (EC) No 2003/2003 on EC fertilisers (Art. 51 and Art. 53).

Official text Read the regulation on EUR-Lex: Regulation (EU) 2019/1009 (CELEX 32019R1009), or the consolidated text of 1 July 2026, which lists twelve delegated regulations, from the four new component material categories to the 2025 conformity assessment changes. It does not yet show the rules that apply later: the digital labelling of Regulation (EU) 2024/2516 from 1 May 2027, and the polymer requirements of Delegated Regulations (EU) 2024/2770, 2024/2788 and 2024/2790 from 17 October 2028. Those have to be read in the acts themselves.

Scope

The regulation does not apply to animal by-products or derived products that are subject to Regulation (EC) No 1069/2009 when made available on the market, nor to plant protection products within Regulation (EC) No 1107/2009 (Art. 1(1)). Derived animal products can only enter an EU fertilising product as CMC 10 materials once an end point in the manufacturing chain has been determined under the animal by-products regulation, which the FPR itself amended to allow (Art. 42(5) and Art. 46). The regulation also lists sixteen acts it does not affect, from REACH and CLP to the Nitrates Directive, the Sewage Sludge Directive, organic production and plant health (Art. 1(2)), and Member States may keep or adopt rules on the use of EU fertilising products as long as they do not require the product to be modified or change the conditions for making it available (Art. 3(3)).

The duties fall on the economic operators: manufacturer, authorised representative, importer and distributor (Art. 2, point (15)). A manufacturer is whoever manufactures an EU fertilising product or has it designed or manufactured and markets it under his or her name or trademark (Art. 2, point (11)); an importer or distributor that sells under its own name or trademark, or modifies a product already placed on the market in a way that may affect compliance, takes on the manufacturer’s obligations (Art. 10). An importer or distributor that only packages or repackages must add ‘packaged by’ or ‘repackaged by’ with its name and address and keep the original labelling for 5 years (Art. 11).

Two transitional situations matter for the trade. EC fertilisers placed on the market in conformity with Regulation (EC) No 2003/2003 before 16 July 2022 may continue to be made available, but the market surveillance rules of Chapter V apply to them (Art. 52). And a Member State that on 14 July 2019 held a cadmium derogation under the old regulation may keep applying its national cadmium limits to EU fertilising products until harmonised limits at or below its level apply at Union level (Art. 3(2)).

What you must do

Product function categories

An EU fertilising product must meet the requirements of Annex I for its product function category, the requirements of Annex II for its component material categories, and be labelled in accordance with Annex III; for any aspect the annexes do not cover it must not present a risk to human, animal or plant health, to safety or to the environment (Art. 4). Annex I, Part I designates seven PFCs by claimed function: PFC 1 fertiliser, split into 1(A) organic, 1(B) organo-mineral and 1(C) inorganic fertiliser, the last divided into 1(C)(I) macronutrient and 1(C)(II) micronutrient fertilisers with solid and liquid, straight and compound sub-categories and a separate entry for ammonium nitrate fertiliser of high nitrogen content; PFC 2 liming material; PFC 3 soil improver, organic or inorganic; PFC 4 growing medium; PFC 5 inhibitor, nitrification, denitrification or urease; PFC 6 plant biostimulant, microbial or non-microbial; and PFC 7 fertilising product blend. Each PFC carries its own minimum nutrient contents, contaminant and pathogen limits and, for biostimulants and inhibitors, efficacy requirements. A blend must consist of EU fertilising products of PFC 1 to PFC 6 that each passed their own conformity assessment, and the blender draws up its own declaration while holding those of every component (Annex I, PFC 7).

Component material categories

Annex II lists the 15 CMCs of which an EU fertilising product may solely consist: CMC 1 virgin material substances and mixtures, CMC 2 plants, plant parts or plant extracts, CMC 3 compost, CMC 4 fresh crop digestate, CMC 5 digestate other than fresh crop digestate, CMC 6 food industry by-products, CMC 7 micro-organisms, CMC 8 nutrient polymers, CMC 9 polymers other than nutrient polymers, CMC 10 derived products within the meaning of Regulation (EC) No 1069/2009, CMC 11 by-products within the meaning of Directive 2008/98/EC, and four added by delegated acts before the regulation applied: CMC 12 precipitated phosphate salts and derivates, CMC 13 thermal oxidation materials and derivates, CMC 14 pyrolysis and gasification materials and CMC 15 recovered high purity materials (Annex II, Part I). Processed manure joined CMC 10 in 2024 and biodegradable mulch films CMC 9. Each CMC sets input materials, process conditions and, for CMC 1, REACH registration. The regulation is also an end-of-waste instrument: waste contained in a compliant EU fertilising product is deemed to meet Article 6 of the Waste Framework Directive and ceases to be waste from the moment the EU declaration of conformity is drawn up (Art. 19).

Contaminant limits, including cadmium

The cadmium limit for phosphate fertilisers is fixed, not stepwise: an inorganic macronutrient or organo-mineral fertiliser with 5 % P2O5 equivalent or more by mass may contain at most 60 mg of cadmium per kg of P2O5, and 3 mg/kg dry matter below that phosphorus content (Annex I, PFC 1(B), point 3, and PFC 1(C)(I), point 2). Organic fertilisers, inorganic soil improvers, growing media and plant biostimulants are limited to 1,5 mg/kg dry matter and liming materials and organic soil improvers to 2 mg/kg. Hexavalent chromium, mercury, nickel, lead, arsenic, biuret and perchlorate limits and pathogen limits for Salmonella, Escherichia coli or enterococci follow per category. The Commission cannot lower the cadmium values by delegated act (Art. 42(1)); instead it had to report to the European Parliament and the Council by 16 July 2026 with a review of the phosphate cadmium limits and the other contaminant limits, accompanied where appropriate by a legislative proposal (Art. 49).

Conformity assessment and CE marking

Before placing a product on the market the manufacturer draws up the technical documentation and carries out the conformity assessment procedure of Annex IV, then draws up the EU declaration of conformity and affixes the CE marking (Art. 6(2) and Art. 15). Annex IV, Part I maps the modules to the composition: Module A internal production control for products made solely of CMC 1 virgin materials other than inhibiting compounds, CMC 4, CMC 6, CMC 8 and CMC 11, and for blends; Module A1 with supervised product testing, mandatory for ammonium nitrate fertilisers of high nitrogen content and blends with 28 % or more nitrogen from them, whose thermal cycles and detonation test must from 1 July 2026 be run in accredited laboratories; Modules B and C, EU-type examination followed by conformity to type, for inhibiting compounds, CMC 2, CMC 7, CMC 9 and CMC 10 materials and the Module A materials; and Module D1 quality assurance of the production process, usable for any product except ammonium nitrate fertilisers of high nitrogen content and blends with 28 % or more nitrogen from them, and the only route for compost, digestate other than fresh crop digestate and the recovered materials of CMCs 12 to 15, where the notified body audits every year and samples the output material. Module A may never be used for inhibitors or plant biostimulants (Annex IV, Part I, point 1.3).

Products conforming to harmonised standards cited in the Official Journal, or to common specifications the Commission adopts where standards are missing, are presumed to conform (Art. 13 and Art. 14). The declaration follows the Annex V model, is kept updated, translated as the Member State requires and merged into a single declaration where another Union act also requires one (Art. 16). The CE marking goes on the packaging or, for unpackaged products, on an accompanying document, before placing on the market, followed by the notified body’s identification number where Annex IV requires one (Art. 17 and Art. 18).

Labelling and the digital label from 2027

Annex III, Part I requires the PFC designation, the quantity, instructions for use with application rates, timing, frequency and target plants, storage conditions, the functionality period of CMC 9 polymers, risk-management information and a list of all ingredients above 5 % by weight or volume with their CMC designations, followed by the PFC-specific nutrient declarations of Part II within the tolerances of Part III. Specific warnings cover derived animal products other than manure, ricin, cocoa shells, growing media not for soil contact, ashes and biochar with manganese above 3,5 %, high purity materials with selenium or chloride, and processed manure with its ammonia and aminopyralid and clopyralid warnings (Annex III, Part I, points 4 to 7d). Voluntary information must not mislead and must relate to verifiable factors (Annex III, Part I, point 8). The label sits on the package, with a leaflet for what does not fit or for unpackaged products, in a language easily understood by end-users as determined by the Member State, together with the manufacturer’s and importer’s name, address and batch number (Art. 6(5) to 6(7) and Art. 8(3) to 8(4)).

Regulation (EU) 2024/2516 adds a digital label from 1 May 2027. Products supplied to other economic operators may carry all labelling elements on a digital label; products supplied to end-users in packaging keep a physical label, with a digital label as an optional duplicate on which only the asterisked elements of Annex III may appear digitally alone; products supplied to end-users without packaging may use a digital label or a leaflet (Art. 11a). The digital label must be free, searchable, accessible on all major operating systems without registration, presented for vulnerable groups and available for 10 years, with a data carrier visible on the packaging or accompanying document (Art. 11b); operators may not track users and must provide the information by alternative means on request or when the label is unavailable at purchase, and post it at the point of sale for unpackaged products (Art. 11c).

Enforcement and penalties

Market surveillance follows the horizontal framework: Article 37 still cites Articles 16 to 29 of Regulation (EC) No 765/2008, which Regulation (EU) 2019/1020 repealed from 16 July 2021, so the surveillance powers are those of Regulation (EU) 2019/1020; its Annex I lists Regulation (EC) No 2003/2003, read as Regulation (EU) 2019/1009 under the repeal clause (Art. 51). Where an authority has sufficient reason to believe that an EU fertilising product presents a risk, it evaluates the product, requires corrective action, withdrawal or recall within a period commensurate with the risk and, if the operator does not act, prohibits or restricts the making available, withdraws or recalls the product and informs the Commission and the other Member States, which triggers the Union safeguard procedure (Art. 38 and Art. 39). Compliant products that still present a risk can be treated the same way (Art. 40), and formal non-compliance such as a wrongly affixed CE marking, a missing notified-body number, a missing or incorrect declaration, incomplete technical documentation or missing identification must be ended or leads to restriction, prohibition, withdrawal or recall (Art. 41). Notified bodies must inform the notifying authority of refused, restricted, suspended or withdrawn certificates and take part in the sectoral group of notified bodies (Art. 34 and Art. 36).

Penalties are set nationally and must be effective, proportionate and dissuasive (Art. 48). In Denmark, executive order nr. 1135 of 9 July 2022 on fertilisers and soil improvers applies to EU fertilising products and EC fertilisers alongside national fertilisers. It was issued under the act on fertilisers and soil improvers, which was consolidated as lovbekendtgørelse nr. 16 of 4 January 2017 when the order was made and has since been reconsolidated as lovbekendtgørelse nr. 1052 of 10 July 2023; Landbrugsstyrelsen registers importers, producers, packagers and traders of fertilisers, controls compliance with the regulation, publishes its control results including company names, receives the detonation-test results for ammonium nitrate fertilisers 5 days before marketing, and punishes breaches of Articles 5, 6, 7(2), 8, 9, 11 and 12 of the regulation with fines, with companies liable under chapter 5 of the criminal code (§ 5, § 18, § 20, § 23 and § 24 of the order). The Danish product and market surveillance act (lovbekendtgørelse nr. 22 of 8 January 2026) does not list the regulation among the acts in its § 2, so fertilising products stay with Landbrugsstyrelsen rather than the general market surveillance authority.

How Conphora helps

Conphora monitors the FPR and its delegated acts and maps your products against the requirements, flagging gaps in the PFC classification, the CMC conditions of every component material, the contaminant limits, the Annex IV module and the notified-body involvement, and the Annex III label before they become enforcement problems. The platform helps you build and keep the EU declaration of conformity, the technical documentation and the 5-year records, and alerts you when a delegated act starts a requirement, such as the digital label on 1 May 2027 and the polymer rules on 17 October 2028.

See how Conphora works · See plans and pricing

Sources

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

Penalties

Enforced by National market surveillance authorities enforce the regulation with the powers of Regulation (EU) 2019/1020 (Article 37 still cites Articles 16 to 29 of Regulation (EC) No 765/2008, read as Regulation (EU) 2019/1020 since 16 July 2021), and in Denmark Landbrugsstyrelsen, the Danish Agricultural Agency under the Ministry of Food, Agriculture and Fisheries, controls compliance with the regulation under executive order nr. 1135 of 9 July 2022 on fertilisers and soil improvers, issued under the act on fertilisers and soil improvers, now consolidated as lovbekendtgørelse nr. 1052 of 10 July 2023. The toolkit is corrective action within a period commensurate with the risk, prohibition or restriction of the making available, withdrawal or recall, orders to end formal non-compliance such as a missing CE marking, EU declaration of conformity or technical documentation, the Union safeguard procedure, and national penalties that must be effective, proportionate and dissuasive, which in Denmark are fines under § 24 of the executive order, with company liability under chapter 5 of the criminal code.

Member States lay down the rules on penalties for infringements of the regulation and take all measures necessary to implement them; the penalties must be effective, proportionate and dissuasive and are notified to the Commission. Market surveillance authorities evaluate an EU fertilising product that presents a risk to human, animal or plant health, to safety or to the environment, require corrective action, withdrawal or recall within a period commensurate with the risk, and if the operator fails to act prohibit or restrict the making available, withdraw or recall the product and notify the Commission and the other Member States; the provisional measure is deemed justified if neither a Member State nor the Commission objects within three months, and only where an objection is raised, or where the Commission considers the measure contrary to Union law, does the Commission decide in the Union safeguard procedure whether the measure is justified; a compliant product that still presents a risk can be treated the same way. Formal non-compliance, such as a CE marking affixed in breach of the rules, a missing or incorrect notified-body number, a missing or incorrect EU declaration of conformity, incomplete technical documentation or missing manufacturer or importer identification, must be ended and otherwise leads to restriction, prohibition, withdrawal or recall. In Denmark, Landbrugsstyrelsen controls compliance with the regulation, the act on fertilisers and soil improvers and executive order nr. 1135 of 9 July 2022, publishes its control results including company names, and under § 24 of that order punishes breaches of Articles 5, 6, 7(2), 8, 9, 11 and 12 of the regulation with fines, with companies liable under chapter 5 of the criminal code.

Source · Art. 48, Art. 38, Art. 39, Art. 40 and Art. 41Source · § 20, § 23 and § 24

What changed

Entry into force, amendments and Compliance Radar entries for FPR, newest first.

  1. Applies

    Polymer rules for CMC 1, CMC 9 and CMC 11 apply

    From this date the biodegradability criteria for coating agents and water retention polymers of Delegated Regulation (EU) 2024/2770 and the rewritten polymer points of CMC 1 and CMC 11 in Delegated Regulations (EU) 2024/2790 and 2024/2788 apply, aligned with the date on which the REACH microplastics restriction starts applying to national fertilising products.

    Source · Art. 2Source · Art. 2Source · Art. 2
  2. Applies

    Digital labelling of EU fertilising products applies

    Regulation (EU) 2024/2516 applies: economic operators may provide the Annex III labelling elements on a digital label under Articles 11a to 11c, with a physical label still required for end-users buying packaged products, a data carrier on the packaging, free access for 10 years, no tracking and alternative provision on request; the Commission's supplementing delegated acts are due by the same date.

    Source · Art. 1, points (4) and (5), and Art. 2
  3. Guidance

    Guide rewritten from the consolidated text of 1 July 2026

    The body was rewritten from consolidated version 02019R1009-20260701 and the fifteen amending acts: the earlier text's undated 2019 adoption, the statement that the cadmium limit is stepwise and the 'certain recovered materials' wording were replaced by the exact dates, the fixed 60 mg/kg P2O5 limit with its Article 49 review, the seven PFCs and 15 CMCs, the Annex IV module mapping, the digital-labelling and polymer amendments, the market surveillance basis of Regulation (EU) 2019/1020 and the Danish rules under Landbrugsstyrelsen.

    Source · whole text
  4. Applies

    Accredited laboratories required for Module A1 tests

    Article 1(1) of Delegated Regulation (EU) 2025/1421 applies: the thermal cycles and the detonation test for straight or compound solid inorganic macronutrient ammonium nitrate fertilisers of high nitrogen content must be carried out in laboratories accredited for those activities by a national accreditation body, the date having been corrected from 30 December 2025 by the corrigendum of 15 December 2025.

    SourceSource · Art. 1(1)
  5. Amendment

    Delegated Regulation (EU) 2025/1421 in force: notified-body audits for recovered materials

    The delegated regulation of 17 July 2025, published on 10 December 2025, amends Module D1 so that the notified body carries out annual audits and takes and analyses output material samples for CMCs 3, 5, 12, 13, 14 and 15, and adds the accredited-laboratory rule for Module A1 that applies from 1 July 2026.

    Source · Art. 1 and Art. 2
  6. Guidance

    Commission FAQ on the Fertilising Products Regulation revised

    DG GROW's Frequently Asked Questions document, dated 2 December 2025, guides national authorities and economic operators on the scope, optional harmonisation, the obligations of economic operators, notified bodies, the transitional period for EC fertilisers, the PFCs and CMCs, labelling and conformity assessment; it confirms that compliance with the harmonised rules remains optional and that national authorities cannot demand a module other than the one Annex IV prescribes.

    Source · introduction and questions 2.1, 6.1 and 10.2
  7. Amendment

    Delegated Regulation (EU) 2024/2790 in force: polymers in CMC 1

    The delegated regulation of 23 July 2024, published on 31 October 2024, rewrites point 1(f) of CMC 1 so that from 17 October 2028 virgin material polymers are allowed only if natural, degradable, soluble above 2 g/L or carbon-free under Appendices 15 and 16 of Annex XVII to REACH, with a new point (fa) for polymers covered by CMC 8 and CMC 9.

    Source · Art. 1 and Art. 2
  8. Amendment

    Delegated Regulation (EU) 2024/2788 in force: polymers in CMC 11

    The delegated regulation of 23 July 2024, published on 31 October 2024, rewrites point 1(b) of CMC 11 in the same terms as CMC 1, applying from 17 October 2028, and adds point (ba) for polymers covered by CMC 8 and CMC 9.

    Source · Art. 1 and Art. 2
  9. Amendment

    Delegated Regulation (EU) 2024/2787 in force: mulch films in CMC 9

    The delegated regulation of 23 July 2024, published on 31 October 2024, includes biodegradable mulch films in CMC 9 with at least 90 % biodegradation within 24 months plus the functionality period, the toxicity tests of other CMC 9 polymers and the labelling of the functionality period, buffer zones and handling after use in Annex III, Part I, point 1(fa).

    Source · Art. 1 and Art. 2Source · Annex III, Part I, point 1(fa) (M11)
  10. Amendment

    Delegated Regulation (EU) 2024/2786 in force: enterococci and presumption of conformity

    The delegated regulation of 23 July 2024, published on 31 October 2024, replaces Enterococcaceae with enterococci in the Annex I and II pathogen tables, extends the presumption of conformity without verification to Annex II requirements and adjusts the quantity and inhibiting-compound tolerances in Annex III.

    Source · Art. 1 and Art. 2Source · Annex I, PFC 1(A), point 4 (M10)
  11. Amendment

    Delegated Regulation (EU) 2024/2770 in force: biodegradability criteria for CMC 9 polymers

    The delegated regulation of 15 July 2024, published on 28 October 2024, lays down the biodegradability criteria for coating agents and water retention polymers (90 % within 48 months plus the functionality period in soil, aquatic criteria and listed test methods) and lifts the disposal instruction for biodegradable binding polymers; Annex I and point 1 of Annex II of the act apply from 17 October 2028.

    Source · Art. 1 and Art. 2
  12. Amendment

    Regulation (EU) 2024/2516 in force: digital labelling

    The regulation of the European Parliament and of the Council of 18 September 2024, published on 30 September 2024, inserts Articles 11a to 11c on digital labels, the definitions of packaging and data carrier, delegated powers in Article 42(9) and (10), the Article 49a evaluation by 21 October 2031 and changes to Annexes III and IV; it applies from 1 May 2027.

    Source · Art. 1 and Art. 2
  13. Amendment

    Delegated Regulation (EU) 2024/1682 in force: processed manure in CMC 10

    The delegated regulation of 4 March 2024, published on 13 June 2024, adds processed manure as a component material in CMC 10 with additional processing, a PAH16 limit, registered additives and a storage time limit, and the ammonia, aminopyralid and clopyralid and manure-nitrogen labelling in Annex III, Part I, points 7c and 7d.

    Source · Art. 1 and Art. 2Source · Annex III, Part I, points 7c and 7d (M8)
  14. Amendment

    Delegated Regulation (EU) 2023/409 in force: 9 % calcium oxide minimum

    The delegated regulation of 18 November 2022, published on 24 February 2023, sets the minimum total calcium oxide content of a straight solid inorganic macronutrient fertiliser at 9 % by mass in PFC 1(C)(I)(a)(i), point 2(e).

    Source · Art. 1 and Art. 2
  15. Amendment

    Delegated Regulation (EU) 2022/1519 in force: inhibiting compounds and digestate

    The delegated regulation of 5 May 2022, published on 13 September 2022, introduces the term inhibiting compound with efficiency requirements for fertilisers and blends containing them, allows post-processing of digestate to extract water, removes the magnesia registration duty, adjusts polymer registration and aligns the CMC 14 PCB limit with the POPs Regulation.

    Source · Art. 1 and Art. 2
  16. Amendment

    Delegated Regulation (EU) 2022/1171 in force: CMC 15 recovered high purity materials

    The delegated regulation of 22 March 2022, published on 8 July 2022 and applying from 16 July 2022, adds CMC 15 recovered high purity materials to Annex II with the selenium and chloride declarations in Annex III and the quality-system requirements for CMCs 3, 5, 12, 13, 14 and 15 under Module D1.

    Source · Art. 1 and Art. 2
  17. Applies

    The regulation applies; Regulation (EC) No 2003/2003 repealed

    EU fertilising products can be CE marked and made available under the harmonised rules from this date; Regulation (EC) No 2003/2003 is repealed with references construed as references to the new regulation; EC fertilisers placed on the market in conformity with it before 16 July 2022 may continue to be made available, subject to Chapter V market surveillance; the first four CMC delegated acts and the first technical adaptation apply from the same date.

    Source · Art. 51, Art. 52 and Art. 53Source · Art. 2
  18. Amendment

    Delegated Regulation (EU) 2021/2088 in force: CMC 14 pyrolysis and gasification materials

    The delegated regulation of 7 July 2021, published on 30 November 2021 and applying from 16 July 2022, adds biochar and similar pyrolysis and gasification materials as CMC 14 with the manganese declaration in Annex III, Part I, point 7a, and the Module D1 provisions in Annex IV.

    Source · Art. 1 and Art. 2
  19. Amendment

    Delegated Regulation (EU) 2021/2087 in force: CMC 13 thermal oxidation materials

    The delegated regulation of 6 July 2021, published on 30 November 2021 and applying from 16 July 2022, adds ashes and other thermal oxidation materials and derivates as CMC 13 to Annexes II, III and IV.

    Source · Art. 1 and Art. 2
  20. Amendment

    Delegated Regulation (EU) 2021/2086 in force: CMC 12 precipitated phosphate salts

    The delegated regulation of 5 July 2021, published on 30 November 2021 and applying from 16 July 2022, adds struvite and other precipitated phosphate salts and derivates as CMC 12 to Annexes II and IV.

    Source · Art. 1 and Art. 2
  21. Amendment

    Delegated Regulation (EU) 2021/1768 in force: first technical adaptation of the annexes

    The delegated regulation of 23 June 2021, published on 8 October 2021 and applying from 16 July 2022, adapts Annexes I to IV: residue and active-substance rules, micronutrient salt fertilisers, professional growing media, polymers as technical additives in CMC 1 and CMC 11, chelating agents, plant fibres, animal by-products with an end point as inputs to compost and digestate, the 5 % ingredient list by weight or volume, wider tolerances and Modules B and C for blends.

    Source · Art. 1 and Art. 2
  22. Applies

    Notified-body provisions apply

    Articles 20 to 36 on the notification of conformity assessment bodies, their requirements, the notification procedure and the coordination group of notified bodies apply from this date so that bodies could be designated before 16 July 2022.

    Source · Art. 53, point (b)
  23. In force

    Regulation (EU) 2019/1009 enters into force

    Adopted on 5 June 2019 and published in OJ L 170 on 25 June 2019, the regulation entered into force on the twentieth day after publication; Articles 4(3), 14 and 42 to 47 applied immediately, giving the Commission the delegated powers to expand the component material categories and amending the animal by-products and plant protection regulations.

    Source · Art. 53

Tools and training

What Conphora offers for FPR.

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CE-marked fertilising products under Regulation (EU) 2019/1009: function and material categories, conformity modules, declaration, labels and records.

Regulation guides

Questions people ask about FPR

When did the Fertilising Products Regulation start to apply?

Regulation (EU) 2019/1009 entered into force on 15 July 2019, the twentieth day after publication in the Official Journal of 25 June 2019, and applies in full since 16 July 2022. Articles 4(3), 14 and 42 to 47 applied from 15 July 2019 and Articles 20 to 36 on notified bodies from 16 April 2020. Regulation (EC) No 2003/2003 on EC fertilisers was repealed with effect from 16 July 2022, and EC fertilisers placed on the market before that date may continue to be made available.

Source · Art. 51, Art. 52 and Art. 53
Do I have to CE mark my fertiliser, or can I keep selling it under national rules?

You can keep selling it under national rules. The regulation applies only to EU fertilising products, meaning products that are CE marked when made available, and it leaves Member States free to regulate fertilising products that are not EU fertilising products. The Commission's FAQ explains that compliance with the harmonised rules remains optional: a manufacturer can apply the regulation and affix the CE mark so the product moves freely, follow the national rules of a Member State and rely on mutual recognition elsewhere, or do both when both sets of requirements are met.

Source · Art. 1(1), Art. 2, point (2), Art. 3 and Art. 38(9)Source · question 2.1
What are the product function categories and component material categories?

Annex I sorts EU fertilising products by claimed function into seven product function categories: PFC 1 fertiliser (organic, organo-mineral and inorganic, the last split into macronutrient and micronutrient fertilisers), PFC 2 liming material, PFC 3 soil improver (organic and inorganic), PFC 4 growing medium, PFC 5 inhibitor (nitrification, denitrification and urease), PFC 6 plant biostimulant (microbial and non-microbial) and PFC 7 fertilising product blend. Annex II lists the 15 component material categories a product may consist of: CMC 1 virgin material substances and mixtures, CMC 2 plants, plant parts or plant extracts, CMC 3 compost, CMC 4 fresh crop digestate, CMC 5 other digestate, CMC 6 food industry by-products, CMC 7 micro-organisms, CMC 8 nutrient polymers, CMC 9 other polymers, CMC 10 derived products under Regulation (EC) No 1069/2009, CMC 11 by-products under Directive 2008/98/EC, and the four added by delegated acts, CMC 12 precipitated phosphate salts and derivates, CMC 13 thermal oxidation materials and derivates, CMC 14 pyrolysis and gasification materials and CMC 15 recovered high purity materials.

Source · Annex I, Part I, and Annex II, Part I
What is the cadmium limit for phosphate fertilisers?

An inorganic macronutrient fertiliser or an organo-mineral fertiliser with a total phosphorus content of 5 % phosphorus pentoxide equivalent or more by mass counts as a phosphate fertiliser and may contain at most 60 mg of cadmium per kg of P2O5; below 5 % the limit is 3 mg/kg dry matter. Organic fertilisers, inorganic soil improvers, growing media and plant biostimulants are limited to 1,5 mg/kg dry matter and liming materials and organic soil improvers to 2 mg/kg. A Member State that held a cadmium derogation on 14 July 2019 may keep its stricter national limits, and the Commission had to review the phosphate limit in its report due by 16 July 2026.

Source · Annex I, PFC 1(A) point 2, PFC 1(B) point 3, PFC 1(C)(I) point 2, PFC 2 point 2, PFC 3 points 2, PFC 4 point 2 and PFC 6 point 2Source · Art. 3(2) and Art. 49
Do I need a notified body?

It depends on the component materials and the category. Module A internal production control, with no notified body, may be used for products composed solely of CMC 1 virgin materials other than inhibiting compounds, CMC 4 fresh crop digestate, CMC 6 food industry by-products, CMC 8 nutrient polymers and CMC 11 by-products, and for blends of PFC 7. Ammonium nitrate fertilisers of high nitrogen content and blends with 28 % or more nitrogen from them must use Module A1, where a notified body supervises the product testing. Inhibitors and plant biostimulants, and products containing CMC 2 plant materials, CMC 7 micro-organisms, CMC 9 polymers or CMC 10 derived products, need Modules B and C or Module D1, and products with compost, digestate other than fresh crop digestate or the recovered materials of CMCs 12 to 15 can only use Module D1, where the notified body audits the production process every year and samples the output.

Source · Annex IV, Part I, points 1 to 4, and Part II, Module D1, point 6.3.2
Can compost or digestate made from waste be used in a CE-marked product?

Yes, under the conditions of CMC 3 and CMC 5, which list the allowed input materials and the composting or digestion process, and the recovery operation must be completed before the material ceases to be waste. The regulation itself lays down the end-of-waste criteria: material contained in a compliant EU fertilising product is considered to meet Article 6 of the Waste Framework Directive and ceases to be waste from the moment the EU declaration of conformity is drawn up, and the Commission's FAQ confirms that such products may be placed on the market in any EU country even where national end-of-waste criteria differ.

Source · Art. 19, Art. 42(3) and Annex II, Part II, CMC 3 and CMC 5Source · question 8.26
What must the label of an EU fertilising product contain?

The PFC designation from Annex I (all component PFCs for a blend), the quantity by mass or volume, instructions for use with application rates, timing, frequency and target plants, recommended storage conditions, the functionality period for products with CMC 9 polymers, risk-management information, and a list of all ingredients above 5 % by weight or volume with their CMC designations, plus the PFC-specific declarations in Annex III, Parts II and III, within the stated tolerances. Products with derived animal products other than manure, ricin, cocoa shells, processed manure or high purity materials carry the specific warnings and declarations of points 4 to 7d. The label sits on the package, or in a leaflet for unpackaged products, in a language easily understood by end-users as determined by the Member State, together with the manufacturer's and importer's name, address and batch number; from 1 May 2027 a digital label is allowed under Articles 11a to 11c.

Source · Art. 6(5) to 6(7), Art. 8(3) to 8(4) and Annex III, Part ISource · Art. 1, point (4)
How long must I keep the documentation?

Manufacturers keep the technical documentation and the EU declaration of conformity for 5 years after the product was placed on the market, authorised representatives keep both at the disposal of the authorities for the same period, importers keep a copy of the declaration for 5 years and ensure the documentation can be produced, and an importer or distributor that repackages keeps the original labelling for 5 years. All economic operators must be able to identify who supplied them and whom they supplied for 5 years. A digital label must stay available for 10 years.

Source · Art. 6(3), Art. 7(2), Art. 8(8), Art. 11 and Art. 12Source · Art. 1, point (4) (Article 11b(4)(e))

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Sources

  1. Regulation (EU) 2019/1009 on EU fertilising products, consolidated text of 1 July 2026 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1009-20260701
  2. Regulation (EU) 2019/1009 as published in OJ L 170, 25 June 2019 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1009
  3. Document information, dates and relationships for CELEX 32019R1009 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32019R1009
  4. Commission Delegated Regulation (EU) 2021/1768 adapting Annexes I to IV to technical progress (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R1768
  5. Commission Delegated Regulation (EU) 2021/2086 adding precipitated phosphate salts and derivates, CMC 12 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R2086
  6. Commission Delegated Regulation (EU) 2021/2087 adding thermal oxidation materials and derivates, CMC 13 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R2087
  7. Commission Delegated Regulation (EU) 2021/2088 adding pyrolysis and gasification materials, CMC 14 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R2088
  8. Commission Delegated Regulation (EU) 2022/1171 adding recovered high purity materials, CMC 15 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022R1171
  9. Commission Delegated Regulation (EU) 2022/1519 on inhibiting compounds and the post-processing of digestate (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022R1519
  10. Commission Delegated Regulation (EU) 2023/409 on the minimum calcium oxide content (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R0409
  11. Commission Delegated Regulation (EU) 2024/1682 adding processed manure as a component material (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1682
  12. Regulation (EU) 2024/2516 on the digital labelling of EU fertilising products (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R2516
  13. Commission Delegated Regulation (EU) 2024/2770 on biodegradability criteria for coating agents and water retention polymers (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R2770
  14. Commission Delegated Regulation (EU) 2024/2786 on enterococci and presuming conformity without verification (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R2786
  15. Commission Delegated Regulation (EU) 2024/2787 including mulch films in CMC 9 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R2787
  16. Commission Delegated Regulation (EU) 2024/2788 on polymers in CMC 11 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R2788
  17. Commission Delegated Regulation (EU) 2024/2790 on polymers in CMC 1 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R2790
  18. Commission Delegated Regulation (EU) 2025/1421 on the conformity assessment procedures (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R1421
  19. Corrigendum of 15 December 2025 to Delegated Regulation (EU) 2025/1421, application of Article 1(1) from 1 July 2026 (EUR-Lex) https://eur-lex.europa.eu/eli/reg_del/2025/1421/corrigendum/2025-12-15/oj
  20. Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020
  21. Fertilising products (European Commission, DG GROW) https://single-market-economy.ec.europa.eu/sectors/chemicals/fertilising-products_en
  22. Regulation (EU) 2019/1009, the Fertilising Products Regulation, Frequently Asked Questions, revision of 2 December 2025 (European Commission, DG GROW) https://single-market-economy.ec.europa.eu/document/download/5fbae838-7749-4828-a92a-73a0e4e489db_en?filename=FAQs+11.0_revised+on+16+June+2025.pdf
  23. New EU rules prepare the ground for more use of organic and waste-based fertilisers, 15 July 2022 (European Commission) https://single-market-economy.ec.europa.eu/news/new-eu-rules-prepare-ground-more-use-organic-and-waste-based-fertilisers-2022-07-15_en
  24. Bekendtgørelse nr. 1135 af 9. juli 2022 om gødning og jordforbedringsmidler m.v. (Retsinformation) https://www.retsinformation.dk/eli/lta/2022/1135
  25. Lovbekendtgørelse nr. 1052 af 10. juli 2023 af lov om gødning og jordforbedringsmidler m.v. (Retsinformation) https://www.retsinformation.dk/eli/lta/2023/1052

About this guide

Reviewed by
Conphora compliance team, Compliance editors, Conphora
Reviewed
24 September 2026
Next review
12 March 2027

Written from the official text on EUR-Lex and the Commission’s guidance, with a source for every fact. It is not legal advice.

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Cite this page 
Conphora (2026). FPR: Fertilising Products Regulation (Regulation (EU) 2019/1009), explained. Retrieved 13 October 2026 from https://www.conphora.com/regulations/fpr/
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