Component Material Categories (CMC's)
A fertilising product must be made of ingredients. FPR requires each ingredient to be categorized as a component material, and must meet certain requirements.
The FPR Annex II contains requirements
Notified Body requirements
CMC's are a large part in determining if a Notified Body is required but also what type of conformity assessment procedure must be followed when you select the aformentioned Notified Body.
Certain CMC's (currently 3, 5, 12, 13, 14, & 15) don't just require you to contract a Notified Body but they also require you to follow a specific procedure, more stringent, procedure to prove your product __and__ production process is compliant.
In other cases, such as CMC 7, you can select your Notified Body and ask them to perform either a Module D1 or Module B conformity assessment. In alot of cases Module B is more economical and efficient to perform and is thus preffered, in many other cases you can also use Module A and resort to self certification.
PFC 7 exemption
A product that is categorised as a PFC 7, meaning it is a fertilising product blend, does not contain CMC's. The reason for this is that a blend can only be made up of products that themselves are a fertilising product.
Any product, even if it contains for example a Biostimulant, can be sold under Module A. The fact that a PFC 7 contains another product that required Notified
Body involvement does not mean that the PFC 7 blend also requires a Notified Bodyto be sold on the market.
CMC's contained in FPR
Below is the list of CMC's that the FPR curretly contains. This list will be updated with specific guidance or information based on specific CMC's
CMC 1: Virgin material substances and mixtures
CMC 1 is for Virgin Materials and mixtures and includes polymers under certain conditions. CMC 1 requires REACH registration for almost all ingredients and may not be used for ingredients that are for example by-products.
CMC 2: Plants, plant parts or plant extracts
CMC 2 is used for Plants, plant parts or plant extracts. CMC 2 lays down requirements for
CMC 3: Compost
CMC 3 is for ingredients obtained through aerobic composting.
Requires Module D1
CMC 4: Fresh crop digestate
An EU fertilising product may contain digestate obtained through anaerobic digestion of exclusively of a select list of input materials.
CMC 5: Digestate other than fresh crop digestate
CMC 5 applies to digestate ingredients obtained through anaerobic digestion of exclusively one or more of input materials in CMC 5.
CMC 6: Food industry by-products
CMC 6 applies to food industry by-products in the following categories:
food industry factory lime, i.e. a material from the food processing industry obtained by carbonation of organic matter, using exclusively burnt lime from natural sources;
molasses, i.e. a viscous by-product of the refining of sugarcane or sugar beets into sugar;
vinasse, i.e. a viscous by-product of the fermentation process of molasses into ethanol, ascorbic acid or other products;
distillers grains, i.e. by-products resulting from the production of alcoholic beverages;
plants, plant parts or plant extracts having undergone only heat treatment or heat treatment in addition to processing methods referred to in CMC 2; or
lime from drinking water production, i.e. resi---
CMC 7: Micro-organisms
Applies to products whereby micro-organisms are intentionally added. The micro-organisms can only be from one of the following 4 strains:
Requires Module B or D1
CMC 8: Nutrient polymers
CMC 8 applies to nutrient polymers exclusively made up of monomer substances complying with the criteria set out in points 1 and 2 of CMC 1, where the purpose of the polymerisation is to control the release of nutrients from one or more of the monomer substances.
CMC 9: Polymers other than nutrient polymers
CMC 9 applies to non-nutrient polymers where the purpose of the polymer is:
(a) to control the water penetration into nutrient particles and thus the release of nutrients (in which case the polymer is commonly referred to as a ‘coating agent’),
(b) to increase the water retention capacity or wettability of the EU fertilising product, or
(c) to bind material in an EU fertilising product belonging to PFC 4.
CMC 10: Derived products within the meaning of Regulation (EC) No 1069/2009
CMC 10 relates to dervied products within the meaning of Regulation 1069/2009, or animal by-products as its commonly known.
CMC 10 is not yet complete.
CMC 11: By-products within the meaning of Directive 2008/98/EC
CMC 11 is for products which contain by-products.
CMC 12: Precipitated phosphate salts and derivates
CMC 13: Thermal oxidation materials and derivates
CMC 14: Pyrolysis and gasification materials
CMC 15: Recovered high purity materials
CMC 15 applies to a recovered high purity material which is ammonium salt, sulphate salt, phosphate salt, elemental sulphur, calcium carbonate or calcium oxide, or mixtures thereof, of a purity of at least 95 % dry matter of the material.