EU fertilisers · Reg (EU) 2019/1009 (FPR)
Can your fertilising product be CE-marked?
The Fertilising Products Regulation lets you CE-mark a product and sell it EU-wide if it fits a Product Function Category and consists only of approved Component Materials — but harmonisation is optional, so a national route exists too. Find your route.
FPR route verdict
FPR CE route appears open
Your product seems to fit a Product Function Category and use only approved Component Materials, so the CE-marking route is available. This is orientation about the route — not a finding that the product complies.
Route available ≠ compliant. CE marking still requires the Annex IV conformity assessment (often via a notified body) and Annex III labelling, and the product must meet the Annex I limits (contaminants, nutrient minima) — this tool does not check those.
The rule, in one line
Since 16 July 2022, under Regulation (EU) 2019/1009, a fertilising product MAY be CE-marked and move freely across the EU if it fits one of the 7 Product Function Categories (Annex I: fertiliser, liming material, soil improver, growing medium, inhibitor, plant biostimulant, blend), consists solely of materials in the 15 Component Material Categories (Annex II), is labelled per Annex III and passes the Annex IV conformity assessment. But FPR harmonisation is OPTIONAL — a product can instead stay on a national market under national rules, and reach other EU markets via mutual recognition.
Official sources: European Commission — FPR FAQ · EC — Fertilising products · Regulation (EU) 2019/1009
- FPR applies since
- 2022-07-16
- Product Function Categories
- 7
- Component Material Categories
- 15
- Legal basis
- Reg (EU) 2019/1009
What this tool is — and isn't
This checker routes the CE-vs-national question and confirms category scope under the Fertilising Products Regulation (Reg (EU) 2019/1009), using the European Commission FPR FAQ + EUR-Lex. It is an estimate and orientation, not legal advice or a conformity assessment — it does not determine whether a product actually complies (Annex I thresholds and the Annex IV conformity assessment are out of scope) or any national-law specifics. Verify against the linked official sources.
How the determination works
1. CE or national?
FPR harmonisation is optional. If you don't CE-mark, you sell under national rules (one market) or mutual recognition (several). For EU-wide free movement, CE marking is the harmonised route.
2. The two scope gates
To CE-mark, the product must fit a Product Function Category (Annex I) AND consist solely of materials in the Component Material Categories (Annex II). Either gate failing blocks the CE route.
3. Route ≠ compliance
An open route still requires the Annex IV conformity assessment, Annex III labelling, and meeting the Annex I limits — which this tool does not check. Unsure on a gate → professional check.
CE-marked vs national: the two routes, side by side
The Fertilising Products Regulation is an optional harmonisation. It does not replace national fertiliser law and does not force any product to be CE-marked — it opens a second, EU-wide route beside the national ones. A manufacturer chooses: earn the CE mark and move the product freely across the whole single market, or stay national and reach other countries through mutual recognition. This is the fork the checker above resolves.
| Dimension | CE-marked EU fertilising product | National fertiliser |
|---|---|---|
| Legal basis | Regulation (EU) 2019/1009 (harmonised, applicable since 16 July 2022). | The national fertiliser law of each individual member state. |
| Market access | Free movement across all 27 EU member states plus EEA once CE-marked — no further national approval. | Only the member state(s) whose national scheme the product actually meets. |
| Selling into another country | The CE mark is the passport; no extra dossier per country. | Mutual recognition under Regulation (EU) 2019/515 — the destination authority can request a lawful-marketing dossier and may object on public-interest grounds. |
| What the product must meet | Fit one Product Function Category (Annex I), consist solely of Annex II component materials, carry the Annex III label and pass the Annex IV conformity route. | Whatever that country's national scheme prescribes — composition limits, registration, national labelling. |
| Is it mandatory? | No. Harmonisation is optional; you opt in to gain free movement. | The default position for any product outside — or not put through — the CE scope. |
| Cost / effort | Conformity assessment (often a notified body), technical documentation and an EU declaration of conformity. | Varies by country; a national registration or authorisation is common. |
One consequence sellers miss: a product that is perfectly legal nationally is not automatically CE-markable. The CE route is a closed system — the product has to fit a PFC and be built only from the 15 Annex II component-material categories. If a single ingredient sits outside Annex II, the CE route is shut and the national + mutual-recognition path is the only way onto other EU markets.
Official sources: European Commission — FPR FAQ (rev. 16 June 2025) · Regulation (EU) 2019/1009 (EUR-Lex consolidated) · Regulation (EU) 2019/515 — mutual recognition
The seven Product Function Categories (Annex I)
A CE-marked product must fit exactly one of seven function categories. The category decides the safety and quality requirements that apply and, together with the component materials, the conformity route. These are the buckets the tool asks you to place your product in.
| PFC | What it covers |
|---|---|
| PFC 1 — Fertiliser | Provides nutrients to plants or mushrooms. Split into organic, organo-mineral and inorganic fertilisers, each further divided into macronutrient and micronutrient sub-types. |
| PFC 2 — Liming material | Corrects soil acidity; declared for neutralising value, reactivity and particle size. |
| PFC 3 — Soil improver | Added to soil to maintain, improve or protect its physical or chemical properties — organic or inorganic. |
| PFC 4 — Growing medium | Material other than soil in which plants are grown (e.g. peat, coir, mineral-wool substrates). |
| PFC 5 — Inhibitor | Nitrification, denitrification or urease inhibitor that improves nutrient-release patterns of another fertilising product. |
| PFC 6 — Plant biostimulant | Stimulates plant nutrition processes independently of nutrient content — microbial and non-microbial variants. |
| PFC 7 — Blend of EU fertilising products | A physical mix of two or more CE-marked products, each of which already conforms on its own. |
Official sources: Regulation (EU) 2019/1009, Annex I (EUR-Lex consolidated) · EC — Fertilising products
Conformity assessment: which module, and when a notified body steps in (Annex IV)
The CE route is not one procedure but four, set by Annex IV. Which one applies is fixed by the component materials and function category — you do not pick freely. The dividing line that matters commercially is whether a notified body has to be involved: Module A is the only route a manufacturer can self-certify; every other material class pulls a notified body into the file.
| Module | Notified body? | Typically applies to |
|---|---|---|
| Module A — Internal production control | No | Products made solely of lower-risk materials: virgin substances/mixtures (CMC 1, excluding inhibitors), fresh crop digestate (CMC 4), food-industry by-products (CMC 6), micro-organisms (CMC 7), nutrient polymers (CMC 8) and by-products under the Waste Framework Directive (CMC 11). |
| Module A1 — Internal control + supervised testing | Yes (supervised tests) | Mandatory for straight or compound solid inorganic macronutrient ammonium nitrate fertilisers of high nitrogen content, and blends carrying 28% or more nitrogen from them — detonation-resistance testing is required. |
| Module B+C — EU-type examination + conformity to type | Yes | Inhibitors (PFC 5), plant biostimulants (PFC 6), and any product containing plants/plant extracts (CMC 2), non-nutrient polymers (CMC 9) or animal-by-product derivatives (CMC 10). |
| Module D1 — Production quality assurance | Yes (annual audit) | Products containing compost (CMC 3), digestate other than fresh crop digestate (CMC 5) or recovered / waste-derived materials (CMC 12–15). May also be used for any product except high-nitrogen ammonium nitrate. |
Two practical rules follow. First, a product built from several component materials takes the strictest module any of its materials requires — a biostimulant that also contains an animal-by-product derivative cannot drop below Module B+C. Second, only Module A carries the CE mark with no notified-body number; wherever Annex IV brings a notified body in (A1, B+C, D1) the CE mark on the label must be followed by that body's four-digit identification number. Annex IV Part I is the authority for the exact combination — treat the table above as the map, not the statute.
Official sources: Regulation (EU) 2019/1009, Annex IV (EUR-Lex consolidated) · AGES — conformity assessment of EU fertilising products · EC — FPR FAQ (rev. 16 June 2025)
What the CE label must carry — and the digital label arriving in 2027
Annex III fixes the label. It is prescriptive, and the particulars are what market-surveillance authorities check first because they are visible without opening the pack.
The core particulars
The PFC/product designation, the declared nutrient content with the forms and solubilities of each nutrient, the physical form, the net mass or volume, and instructions for intended use, dosage and storage. Where a member state requires labelling in its national language(s), the Annex III information must follow that requirement — a pack cleared in one market can fail in the next purely on language.
The CE mark and the notified-body number
The CE marking is affixed visibly, legibly and indelibly. Where Annex IV brings a notified body in (Module A1, B+C or D1) the CE mark is followed by that body's four-digit identification number; Module A products carry the CE mark with no number. The EU declaration of conformity sits behind it in the technical file.
Tolerances and honest claims
Declared values must fall inside the Annex III tolerance bands (which run both negative and positive). Voluntary information added to the label must not mislead the end user and must relate to verifiable factors — the FPR's own honesty rule, separate from the Green Claims regime.
The digital label (Regulation (EU) 2024/2516) — from 1 May 2027
A voluntary digital label reached by a QR or bar code becomes available from 1 May 2027. It stays voluntary, and for products supplied to end-users in packaging the content is duplicated on the physical label — only the elements asterisked in Annex III may live online alone. Safety information and the minimum agronomic-efficiency and correct-use information always stay printed on the physical label.
Official sources: Regulation (EU) 2019/1009, Annex III (EUR-Lex consolidated) · Regulation (EU) 2024/2516 — digital labelling
The rules a fertiliser CE mark does NOT cover
A CE mark answers the FPR question and nothing else. Several other regimes attach to the same product, and for online sellers they are the ones that actually trigger listing takedowns. The triggers below reflect the position as of July 2026.
Explosives-precursor reporting for high-nitrogen ammonium nitrate
Under Regulation (EU) 2019/1148, applicable since 1 February 2021, ammonium nitrate containing 16% or more nitrogen by weight is a reportable explosives precursor (Annex II). It is not prohibited to the general public, but every economic operator in the chain must report suspicious transactions and any significant disappearances or thefts. Marketplaces flag these ASINs, and a listing that ignores the reporting duty is a compliance risk independent of the CE mark.
A GPSR responsible person
Since 13 December 2024 the General Product Safety Regulation (EU) 2023/988 requires a consumer product sold into the EU to have an economic operator established in the EU who answers for its compliance, with contact details shown to buyers. Amazon and other marketplaces collect these per product and deactivate EU listings that lack them — the most common takedown for non-EU fertiliser sellers.
The dangerous-goods (hazmat) review
Liquid fertilisers, acidifiers, descaling agents and some micronutrient chelates routinely trigger a marketplace dangerous-goods review. Until a compliant Safety Data Sheet is on file the listing sits blocked — a missing or out-of-date SDS is a silent delisting that a valid CE mark does nothing to prevent.
Listing content that contradicts the label
Restricted-products policies allow removal where the listing itself is non-compliant — product images missing required particulars, or claims that conflict with the SDS or the physical label. Keep the image gallery and bullet points consistent with the pack you actually ship.
Official sources: Regulation (EU) 2019/1148 — explosives precursors · Regulation (EU) 2023/988 — GPSR · Amazon Seller Central — dangerous goods · Amazon restricted-products policy
Frequently asked questions
- Is CE marking mandatory for fertilisers?
- No. The FPR is optional harmonisation. You can CE-mark to sell EU-wide, or stay on national markets under national rules and reach other markets via mutual recognition.
- What are the Product Function Categories?
- The seven Annex I categories: fertiliser, liming material, soil improver, growing medium, inhibitor, plant biostimulant, and a blend of EU fertilising products.
- What are the Component Material Categories?
- The 15 Annex II categories of input materials an EU fertilising product may consist of — virgin substances, compost, digestates, by-products, recovered materials and more. Materials outside them block the CE route.
- Does an open route mean my product is compliant?
- No. It means the CE route is available. You still need the Annex IV conformity assessment, Annex III labelling, and to meet the Annex I limits (contaminants, nutrient minima) — which this tool does not check.
- How do I reach other EU markets without CE?
- Via mutual recognition (Regulation (EU) 2019/515): a product lawfully marketed in one Member State can, in principle, be marketed in others — subject to that route's conditions.
- Is this legal advice?
- No. This tool routes the CE-vs-national question. It is orientation, not legal advice or a conformity assessment. Verify against the linked official sources.
- Do I have to CE-mark my fertiliser to sell it in the EU?
- No. The Fertilising Products Regulation is an optional harmonisation — it does not replace national fertiliser law. You can keep the product national and reach other EU countries through mutual recognition (Regulation (EU) 2019/515). CE-marking buys one thing: free movement across the whole single market without per-country approval, provided the product fits a Product Function Category and is built only from Annex II component materials.
- Does a CE-marked fertiliser always need a notified body?
- No. Products made solely of the lower-risk component materials — virgin substances (CMC 1, excluding inhibitors), fresh crop digestate, food-industry by-products, micro-organisms, nutrient polymers and by-products — can self-certify under Module A with no notified body. Ammonium nitrate fertilisers, plant biostimulants, inhibitors, compost, digestate and waste-derived materials all pull a notified body in through Module A1, B+C or D1.
- My product mixes several component materials — which conformity module applies?
- The strictest that any of its materials requires. Annex IV Part I fixes the module from the CMC/PFC combination; you do not choose it freely. A product that would qualify for Module A on most of its content but also contains, say, an animal-by-product derivative (CMC 10) is pushed up to Module B+C by that ingredient alone.
- Can I sell my national fertiliser in another EU country without CE-marking it?
- Yes — through mutual recognition. Regulation (EU) 2019/515 lets goods lawfully marketed in one member state be sold in another, and you can prepare a voluntary lawful-marketing declaration to support it. But the destination authority can still request a dossier and may object on grounds of public interest, so mutual recognition is not automatic the way free movement under a CE mark is.
- When does the digital label for fertilisers start, and can I drop the paper label?
- Regulation (EU) 2024/2516 makes a voluntary digital label available from 1 May 2027. You cannot drop the physical label for packaged consumer products: the digital content is duplicated on the pack, and safety plus minimum agronomic and correct-use information always stays printed. Only the elements asterisked in Annex III may live online alone.