Recent shocks, including the energy crisis and growing geopolitical instability, have shown that fertilizer supply can quickly become a strategic vulnerability. Excessive dependence on external suppliers therefore poses a serious risk to Europe’s food security.

a. Comprehensively assess the impact of current and new legislative proposals on the fertilizer industry.

b. Enable targeted, sector-specific policies that take into account the unique role of fertilizers, an industry at the crossroad of agriculture, chemicals and energy-intensive.

c. Reduce external dependencies for critical inputs to safeguard long-term stability.

d. Avoid disruptions in domestic fertilizer production to prevent knock-on effects on farm output and food security.

• Identify production sites of ammonia and fertilizers as critical.

e. Address the risks of capacity closures in the sector, with fertilizer assets as vital part of key chemical complexes.

f. Consider how upcoming regulatory requirements across the value chain may, in aggregate, create disproportionate pressures that risk negatively affecting the affordability of mineral fertilizers.

g. Create demand for lower-carbon, renewable-based, and recovered mineral fertilizers to support sustainable European production.

European producers face increasing unfair competition from third countries. Competitive disadvantages led to shutdowns and reduction of industry’s output, making European farmers increasingly dependent on imported products.

a. Ensure a level playing field on energy and carbon costs (see points 3 and 4).

b. Ensure economic competitiveness of the entire agri-food chain.
Relief for farmers in high price scenarios should not be addressed by worsening competitive position of EU producers.

•  Instead, targeted support for farmers should prioritise EU-made products.

c. Ensure technological neutrality to secure necessary investment and reduce the costs of the transition.

d. Develop new legislation focused on incentives across the entire value chain and de-risking investments instead of penalties.

e. Reduce red tape – eliminate excessive reporting and ensure regulatory consistency.

• For example, the implementation of the Packaging and Packaging Waste Regulation (PPWR) should be assessed whether the specific characteristics of fertilizer production and distribution justify a targeted reuse exemption for fertilizer producers and related packaging.

The fertilizer industry is the largest industrial user of natural gas, which is used as both a feedstock and raw material. Around 80% of the operating costs are attributed to gas. Meanwhile, EU faces gas costs 4–5x higher than the USA and 2–3x higher electricity costs compared to other regions.[5] High energy costs threaten EU industrial competitiveness: in the short term, this leads to temporary shutdowns and even permanent closures. In the mid- to long-term, this undermines incentives to invest in long-term, low-carbon production capacity in Europe.

a. Restore gas competitiveness.
In the short term, the EU and Member States can reduce the gas costs by providing temporary state aid, diversifying supply, increasing domestic gas supply.
• Put in place a Stop-the-Clock Mechanism to provide time for workable solutions for targeted adjustments to the EU Methane Regulation to avoid severe disruptions to Europe’s gas supply.
• In the mid- to long-term, policy responses must acknowledge the above-mentioned realities and avoid creating additional, disproportionate burdens under EU or national control.
• Ensure that taxes, grid fees, and other cost elements set or influenced at EU and national level remain proportionate and predictable throughout the transition.

A robust framework is needed to ensure that EU producers compete under fair conditions with imports. This requires effective use of trade defence instruments and policy coherence across trade, energy, and climate measures to prevent unfair practices and regulatory imbalances.

a. Consider all policy instruments combating unfair competition to ensure a real level playing field for EU fertilizer industry both on the domestic and international markets.

b. Use all trade defence instruments to address dumping and to prevent circumvention practices.

c. Maintain trade defence measures, even in case of temporary geopolitical shock and trade disruptions.

• The antidumping/antisubsidy proceedings are lengthy, purely technical processes, based on criteria described in detail in EU regulations – they provide long lasting defence against third countries’ harmful and unfair practices.

d. Align trade, energy, and climate policy across Commission services.

Low-carbon and renewable fertilizers come with a significantly higher price tag, presenting new market barriers especially among end-users in agriculture. Therefore, public support and regulatory frameworks that encourage demand are essential to accelerate the transition.

a. Create a regulatory framework that boosts the uptake and gradual demand increase for low-carbon fertilizers.

• Create downstream demand side incentives for low-carbon products, such as targeted quotas, mandates, tax incentives, and support schemes, and that facilitate market access for sustainable solutions
• Develop an EU-wide certification and labelling system for low-carbon agricultural inputs, complemented by an EU-harmonized consumer label that clearly identifies low-carbon products will build trust and stimulate uptake

b. Simplify the regulatory framework for circular products. Nutrient recycling plays a critical role, but it is not a silver bullet because its implementation at scale can be complex.

• Enable safe use of waste‑ and recycled‑derived materials as inputs and support the recovery and recycling of industrial by‑products.
• Streamline and fast-track legislative proposals that would allow industry players to extract and recycle key nutrients from by-products, such as phosphorus from fish sludge and potassium from ashes.
• Boost innovation by removing practical bottlenecks under the EU’s waste regulatory framework.
• Enable temporary permit exemptions for circular pilot projects. Adjust waste‑shipment rules to deliver major simplifications for fertilizer manufacturers.

c. Create a regulatory framework for the uptake of innovative plant nutrition products, including circular mineral fertilizers, that reduce EU dependency on critical raw materials.

d. Provide support to farmers for the uptake of new technologies, circular fertilizers through CAP subsidies and other financial incentives.

e.Exempt existing ammonia installations from the RED III RFNBO industry targets.Given the structural design constraints and operating limitations of current SMRsites, plants cannot feasibly operate at 60% capacity to enable partial switching to RFNBO hydrogen for RED III compliance.

• Ensure that the targets are technology neutral, also by allowing lowcarbon and circular hydrogen under the denominator.
• Reassess the 2030 and 2035 targets based on recent capacity forecast as well as infrastructure rollout. Incorporate the ammonia exemption recital directly into the legally binding provisions of RED III would acknowledge the sector’s technical challenges, support technology‑neutral decarbonization investments across Member States, and accelerate the effective implementation of the Directive.

f. Ensure technology neutrality in the decarbonization pathway of the European fertilizer sector.

Delivering the low-carbon transition in the fertilizer sector requires a supportive and predictable policy framework. Significant investments will be needed to deploy low-carbon technologies, develop new infrastructure, and scale up innovative production pathways. EU policies must therefore enable the conditions necessary for industry to transition while maintaining production in Europe.

a. Develop sectorial funding schemes to finance the transition.

• Combine CAPEX and OPEX support.
• Apply technology neutrality principles on the chosen decarbonization route.
• Ensure coordination between European and national grants.

b. Build infrastructure for CO2 management and to transport low-carbon resources.

c.  Develop a labelling scheme for low-carbon products.

d. Provide financial incentives to boost the uptake of low-carbon and circular products.

Improving nutrient use efficiency requires a broad range of practical tools and solutions available to farmers. EU policies should support a comprehensive toolbox that enables efficient nutrient management while reducing losses and emissions.

a. Develop tools and solutions to improve productivity while reducing nutrient losses and emissions.
• Expand support for nutrient management through CAP funding, including different tools and solutions.

b. Include NUE as part of the sustainability benchmarking and On-Farm Sustainability Compass.
• Studies show that improving NUE is a practical and measurable pathway to maintain yields while reducing nutrient losses and protecting water and air quality.[6]

c. Emphasize the importance of technologies that can reduce losses to the air, soil and water (Precision agriculture, biostimulants, enhanced efficiency fertilizers, inhibitors, etc.).

d. Promote fertilizer best practices and complementary use of inputs.

e. Develop decision-support tools to help farmers choose fertilizing products that enhance nutrient use efficiency and reduce nutrient losses under their specific agronomic conditions.

f. Include all agricultural methods and solutions that promote lower carbon emissions rather than fertilizer replacement.