IMPACT AND CONSULTATIONS: The Circular Economy Act: Three Policy Priorities from CiNURGi for Closing Europe's Nutrient Loop

At the Nutrients & Organics in the EU Circular Economy Act workshop on 1 July 2026, hosted by the ESPP, Henning Lyngsø Foged from the Organe Institute presented selected policy recommendations from the Interreg Baltic Sea Region project CiNURGi. The presentation focused on three recommendations: common terminology, changes to the Waste Framework Directive (WFD) and incentives for providing environmental services.

CiNURGi has developed 33 policy recommendations aimed at accelerating the uptake of recycled nutrient fertilisers across the Baltic Sea Region. While these recommendations specifically support the objectives of the HELCOM Baltic Sea Regional Nutrient Recycling Strategy, many are equally relevant for shaping future EU legislation. Three priorities stand out as particularly important for the Circular Economy Act.

Establishing common terminology

CiNURGi has identified widespread confusion surrounding terms such as bio-based fertiliser, soil improver, nutrient-rich organic waste and even nutrient recycling itself. This lack of a common vocabulary creates uncertainty for policymakers, researchers and market actors alike. The EU Fertilising Products Regulation (EU) 2019/1009 should not be used as a reference for these broader definitions, as its primary purpose is to regulate products placed on the market rather than define concepts for circular nutrient management. Without shared terminology, coherent policy development becomes considerably more difficult.

Modernising waste legislation

According to CiNURGi, one of the most significant legislative barriers lies within the current Waste Framework Directive (WFD). CiNURGi recommends that the Circular Economy Act acknowledge the need to amend Article 2 of the Waste Framework Directive by introducing a dedicated category for non-risk nutrient-rich organic waste. Such materials could then be regulated in a similar way to livestock manure, simplifying their recovery while maintaining producer responsibility and traceability. Otherwise, many safe, nutrient-rich organic waste streams remain subject to complex and costly end-of-waste procedures before they can be recycled into fertilising products. The Danish regulatory framework was presented as an example of how this approach can function in practice.

Reward environmental performance, not simply recycling

Not all recycling value chains generate a positive overall societal value. CiNURGi’s analyses demonstrate that different recycling pathways deliver very different environmental and societal outcomes. The largest differences are linked to losses of nitrogen, phosphorus and carbon during processing, particularly in technologies relying on oxidation or thermal treatment. For this reason, CiNURGi argues that future policy instruments—including support under the Common Agricultural Policy (CAP)—  should reward verified environmental performance rather than simply financing all and any nutrient recycling activities. Public support should reflect the demonstrated societal value of nutrient recovery, creating incentives for solutions that maximise nutrient retention while reducing environmental impacts. To support this approach, the project has developed the Bio-Based Fertilizer Evaluation TOOL, which quantifies the societal costs and benefits associated with producing bio-based fertilisers from nutrient-rich organic waste streams.

As the CINURGi project is ending in October 2026 this consultation was a timely opportunity to further disseminate our results. Combined with the implementation of the Bioeconomy Strategy and the Fertilizer Action Plan the topic of nutrient recycling is on the political radar and the priority list.

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