Feedback letter on Nitrates Directive Evaluation

The transition to a circular economy is crucial for reducing the environmental impact of agricultural practices. A key component of this transition is nutrient recycling, which ensures that valuable nutrients from waste and residues are recovered and reused efficiently. This approach not only minimises waste but also aligns with the European Union’s Green Deal and Circular Economy Action Plan (CEAP).

The Nitrates Directive

A group of EU-funded projects, including NUTRI-KNOW, have joined forces under the European Sustainable Nutrient Initiative (ESNI) Community to provide feedback on the Nitrates Directive. This directive, introduced over 30 years ago, aims to protect water quality by limiting nitrate pollution from agriculture.

The purpose of this feedback letter is to address the urgent need for aligning the Nitrates Directive with other recent legislation, such as the Fertilising Product Regulation and the Animal By-Product Regulation. The letter aims to highlight the obstacles faced by valuable recycled nitrogen fertilising products in entering the market due to the current wording and interpretation of the Nitrates Directive.


One of the key concepts discussed in the feedback is ReNure (REcovered Nitrogen from manURE). This initiative focuses on the safe use of processed manure as a replacement for chemical nitrogen fertilisers. ReNure products are designed to minimise the risk of nitrate leaching while promoting nutrient recycling.

The ReNure Criterion, developed through the SAFEMANURE/ReNure research project, establishes strict guidelines for manure-derived products. These products, when adhering to the ReNure criteria, can be safely used as alternatives to chemically produced nitrogen fertilisers without increasing the risk of nitrate leaching. The implementation of this criterion would allow for the exemption of these products from the restrictions imposed by the Nitrates Directive in Nitrate Vulnerable Zones.

The feedback letter emphasises the critical need for implementing the ReNure criterion and updating the Nitrates Directive to align with current circular economy goals. By addressing these issues, the EU can foster the development of sustainable nutrient recycling technologies, reduce dependency on imported fertilisers, and contribute to a more environmentally friendly agricultural sector. Our most recent feedback on the Draft amendment of Annex II of the Nitrates Directive can be found here.