EEB feedback to the Commission initiative to extend the RENURE act

The EEB would like to expresses deep concerns regarding the Commission’s initiative to extend the RENURE act to include digestate. The RENURE act and its proposed expansion allows the application of an additional 80 kg nitrogen of certain processed manure products above the limit set in the Nitrates Directive. This represents a near 50% increase in the amount of nitrogen from manure that can be authorised in Nitrogen Vulnerable Zones, i.e. areas identified as polluted or at risk of being polluted by nitrogen from agricultural sources.

The initiative lacks robust scientific backing and risks exacerbating the already acute environmental and human health impacts of high nitrogen emissions from excessive manure production, making it more difficult to achieve the objectives of the Nitrates Directive and the Water Framework Directive. Furthermore, it goes directly against the unequivocal findings of the Commission’s Evaluation of the Nitrates Directive that “the manure application limit is effective, scientifically sound and cost-efficient, although, in polluted areas, it may not be sufficient to achieve the Directive’s objectives”.

We recommend that the Commission withdraws not only this draft act, but also the adopted RENURE act, and instead:

• works with Member States to improve the implementation of the Nitrates Directive;
• supports farmers to improve their nutrient use efficiency and to integrate legumes in their crop rotations and pastures;
• explores solutions to “support extensification in regions with high livestock concentrations” as proposed in the Vision for Agriculture and Food and;
• promotes the use of processed manure within safe ecological boundaries that protect water, as part of the Integrated Nutrient Management Action Plan that should be published as soon as possible;
• ensures that any future initiative on this topic is informed by a proper Impact Assessment (also informed by a risk assessment), public consultation and climate consistency assessment.