Foro Global sobre Seguridad Alimentaria y Nutrición (Foro FSN)

The Fertilizer Institute (TFI) is pleased to provide comments to the Food and Agriculture Organization of the United Nations on the Zero Draft of the Code of Conduct for the Management of Fertilizers. The members of TFI are leading the way in development and implementation of new technologies and scientifically-based management for agricultural cropping systems to better meet social, environmental, and economic goals.

General Comments

While we applaud FAO for its ambition, we believe that the proposed timeline has not provided for sufficient consultation with sectors identified as key stakeholder entities within the document. The expediency of development will not result in a document which provides meaningful guidance and recommendations.

The ‘Zero Draft of the International Code of Conduct for the Use and Management of Fertilizers’ is a broad summary of tactics for sustainable use of fertilizers with the intention of allowing individual countries or stakeholders to be sure the code is appropriate for their situation. However, within the document there is a need to be more concise language and elimination of repetition of actions assigned to respective stakeholder groups. Additionally, the definition of the identified stakeholder groups changes throughout the document, making it a challenge for readers and users to interpret.

We are encouraged to see the fertilizer industry identified as an important stakeholder with roles and actions to support effective fertilizer use and management. And, we are equally pleased with the inclusion of the principles of 4R Nutrient Stewardship. In many geographic locations, the industry is a trusted advisor to farmers in the field, and the industry should be viewed as a resource for country efforts to optimize fertilizer use. Additionally, there is growing science and broad support for basing fertilizer use decision on 4R Nutrient Stewardship. Inclusion of the 4R principles can serve as an incubator for broader resource allocation and implementation efforts.  

However, while we applaud these inclusions, we believe the document would benefit from greater consultation and time for engagement with the stakeholders identified as key to successful fertilizer management. Throughout the document, there are specific tasks assigned to the fertilizer industry, not all of them may be feasible to implement and several could be improved with industry insight.

While not a complete collection of areas of concern within the fertilizer industry allocated sections, below are examples pointing to the need for great consultation and engagement.

4.11.3.   Keep records of fertilizer sales and/or fertilizer applications along with other agronomic practices, data and farm records to support governments for the purpose of statistical information on fertilizer use.

While there is need to expand and improve record keeping, the challenges of data security will limit the amount of data and farm records that can and will be shared to governments for statistical information. Further consultation with the fertilizer and ag retail industry would be beneficial to clarify this tactic.

Further, some good instruments within governance, initiatives, programs and regulations already exist in relation to fertilizer value chain (production, transport, QC, labelling, trading etc.) For lack of time, these have not been considered enough and deserve to be closer looked at. Concerns with what the fertilizer industry should do around these items occur in multiple sections of the document.

In Section 7. ‘Access, Distribution and Labelling’ there are multiple items that do not recognize the structure of departments and responsibilities within the fertilizer industry. For example:

7.2.1.     Ensure that persons involved in the sale of fertilizers along the fertilizer value chain are trained adequately to be capable of providing relevant information to the related actors in the supply chain, such safety information, advice on risk reduction, and information on the responsible and efficient use of the fertilizer products.

7.2.2.     Ensure that persons involved in the sale of fertilizers to users are trained adequately and are capable of providing sound advice on the use of the fertilizer products they are selling, and on the environmental and health risks associated with the misuse of fertilizers.

These items would be handled by multiple professionals within a company and should be addressed as such.

In summary, substantial improvements are still required to make the current draft relevant and ready for adoption. The current timeline has not allowed for proper research and consideration of existing systems and programs. Given the critical role of fertilizers, TFI would strongly recommend giving appropriate time and consultation to the development of such a significant document: it is ultimately the extend of its content that will decide if this code is truly relevant for nutrient stewardship or if it will be dismissed as superficial and too general.

The European Consortium for the Organic-Based Fertilizer Industry (ECOFI) welcomes the development of the International Code of Conduct for the Use and Management of Fertilizers and the inclusion of organic fertilizers in the zero draft. However, considering the importance of the Code’s topic, and the fact that it merits additional reflection, discussion and consultation before being launched, ECOFI calls for the adoption of the Code of Conduct to be delayed until the Committee on Agriculture of the Food and Agriculture Organization (COAG) 2020, instead of 2018. This would thus leave the FAO, ITPS, and all relevant stakeholders adequate time for appropriate consideration of the draft.

Specific points for further discussion (see attached document) include:

• The excessive emphasis on mineral fertilizers, with all other technologies cast as corrective measures or in a secondary role rather than essential parts of integrated soil fertility and plant nutrient management
• e.g. according to its current inappropriate definition of contaminants, the carbon in an organic fertilizer would be considered a contaminant;
• organo-mineral fertilizers are not mentioned in the text
• The circular economy and industrial symbiosis
• Mitigation of and adaptation to climate change
• The need to revise several of the terms and definitions

The European Biostimulants Industry Council (EBIC) welcomes the development of an International Code of Conduct for the Use and Management of Fertilizers by the FAO. EBIC considers that the Code covers an important topic that merits appropriate reflection, discussion and consultation before being launched. Therefore, the proposed timeline aiming for its adoption at the Committee on Agriculture of the Food and Agriculture Organization (COAG) 2018 is simply too short to develop a credible and comprehensive Code of Conduct for fertilizer use, particularly considering the innovative nature of the sector.

There is significant need for improvement if the FAO is to meet its ambitious objectives it has set out for this International Code of Conduct. It is essential to broaden the scope of the Code to ensure that fertilizer use and management is placed in a holistic context of plant nutrition and soil fertility management.

EBIC therefore calls for the adoption of the Code of Conduct to be delayed until the COAG meeting in 2020, which would leave adequate time for consideration of the draft and therefore the adoption of a workable and respected International Code of Conduct on the Use and Management of Fertilizers.

Specific points for furhter discussion (elaborated in the attached doucment) include:

• the role of complementary technologies
• a more holistic concept of plant nutrition and soil fertility management that goes beyond nutrient stewardship
• The role of integrated plant nutrition and soil fertility management in contribution to adaptation to climate change.

EBIC is available for further consultation on the Code at any time. www.biostimulants.org

AFCOME is a professional organization that brings together cooperatives and private companies working in the field of fertilizer distribution and blending (Bulk Blending). It represents about 75% of the market for mineral fertilizers distributed in France.

We highly welcome the project of a code of conduct for fertilizers. Having a common framework to support use and management of fertilizers worldwide is a real opportunity.

But, as it has a very high potential, the elaboration of this document needs in-depth analysis which takes time. It is very important to ensure that each topic developed in this code of conduct is accurate, complete and relevant as it will serve as a valuable guide for fertilizer management.

This zero-draft is a good starting point but it needs to be verified and completed. For example, non-accurate parallels are made between fertilizers and pesticides which could lead to misunderstandings and would not serve fertilizers.  Precise and clear definitions and the use appropriate vocabulary are also a very important as this code will provide a common baseline internationally.

Assofertilizzanti is one of Federchimica’s (National Association of the Chemical Industry) Associations that safeguards and represents all the productive divisions of the fertilizers sector in Italy.

In behalf of Assofertilizzanti, I would like to point out that we welcome the new "code of conduct for the use and management of fertilizers, but first of all a number of considerations should be made. In particular, we would highlight that the timeline proposed for the publication is not sufficient to create a thorough and reliable code of conduct. If possible we suggest to postpone the adoption in a couple of years.

For more information please find enclosed our comments.

IFOAM - Organics International appreciates the efforts made by the Global Soil Partnership Secretariat to draft the "Code of conduct for the Use and management of fertilizers”, and we do think that this Code of conduct is an essential document that was long due to the persistent problem of fertilizer overuse hindering the implementation of many of the Sustainable Development Goals.

We agree that it is imperative to consider fertilisers at "the landscape and global levels due to potential nutrient losses to the environment and the negative effect of such losses” and the chapter dedicated to “nutrient reuse and recycling” is a key part of the document.  

Moreover we consider that the first page of the document should mention "the need of an holistic approach to nutrients and to their cycle in soils, plants, animals, humans, water and environment". A new approach from all the stakeholders is needed to achieve the desired results with the code.

We truly believe that this Code should be approved at the COAG meeting this year in order to further achievements for Agenda 2030.

Every day billions of Tons of organic waste that should go back to soils are thrown into garbage, thus organic Carbon does not return to soils, but instead they are located in places with mix garbage, which turns into soil, water and air pollution. This occurs mainly in developing countries (Although industrialized countries recycle most of their waste, recycling is around 70% or even less). So this is the opportunity to ask to governments to start efficient organic waste management plans. And use those materials as organic fertilizers. There are plenty of places where those materials are highly required, among them soil eroded lands.

On behalf of the German fertilizer industry, we, the German Agrochemical Industry Association (IVA), are of the opinion that the current zero draft of the „Code of Conduct“ needs some substantial improvements. As a national association we therefore generally support the International Fertilizer Association (IFA´s) argumentation and comments to the zero draft. In particular, we support the notion that the developement of such an important document should be made with due diligence and not in an unnecessary rapidity to improve its quality and relevance for the industry and stakeholders alike.

Thank you for the opportunity of contributing to the development of the CoCoFe through this online consultation.

Please find my comments in the enclosed document.

Best regards

Cruz Ferro Vázquez

The Fertiliser Association of New Zealand supports the initiative of the FAO in developing a Code of Conduct for Use and Management of Fertilizers. There are however opportunities for further consideration to ensure wide applicability and uptake of the Code. The  Fertiliser Association of New Zealand supports the contribution by the International Fertilizer Association and further specific comment is provided in the contribution attached.