Paloma Perez Sanchez and Pierre Jaouen talk to Brian Johnson about why they believe a cadmium limit of 80 mg strikes the right balance between health and environmental risk, and the EU’s agricultural, geopolitical, and trade interests.
How do you rate the European Parliament discussions on cadmium limits?
The lack of substance has been disappointing. Placing this file in the exclusive competence of the Parliament's ENVI committee has meant that several important areas (agricultural, international, geopolitical and employment) were omitted from the discussions.
Even key environmental and health issues succumbed to the committee's political divide, preventing any serious consideration of key facts and science. The decadmiation workshop organised by ENVI rapporteur Elisabetta Gardini, for example was not attended by any of the MEPs arguing for low limits.
There appears to have been no real interest in learning the key facts of this dossier.
Haven't European Commission studies shown that cadmium is toxic and should be reduced in our food?
There is no dispute that cadmium is toxic. But this alone does not resolve the issue. The question is, first, how severe and urgent the problem of cadmium in food is and, second, whether the limits proposed will achieve a meaningful reduction of it in our food.
So is there an urgent problem with cadmium in food?
The European Food Safety Authority (EFSA) investigated that question in 2009 and 2011. Dietary exposure to cadmium is below the tolerable weekly intake. Nevertheless, certain sub-populations exceed that level and given the lack of data, EFSA recommended that more data should be generated in order to refine their assessment.
In 2016, the French food safety agency ANSES, published a study on dietary exposure of children to chemical contaminants. Although similar conclusions were drawn and a recommendation for reducing exposure levels was formulated, cadmium was not identified in the group of contaminants identified as worrying. A similar outcome was reached in Spain.
Another issue is imported food. The EFSA study was based on food present on the EU market, not necessarily EU-grown.
Grains for example, which account for much of the cadmium exposure in our diet, are imported in large quantities from outside the EU. Reducing cadmium in fertilizers will not address this problem. This aspect has, in our opinion, been clearly avoided in the impact assessment and during most of the parliamentary debate.
The Commission argues that a limit of 80 mg Would not lead to any reduction of cadmium in soils. Is this correct?
This assertion is misleading and we regret that the real facts and figures have not been properly presented.
Cadmium levels in EU soils are already falling without any limits, as validated by the Commission's scientific committee in 2015. Recent scientific studies clearly show cadmium levels in EU soils would fall with an average cad 80 mg. A maximum limit of 80 mg will lead to much lower average levels and therefore result in a clear reduction in EU soils.
There is disagreement about the availability and effectiveness of decadmiation technologies. Why is this?
First, not all phosphate fertilizers can be decadmiated: there is no known technology for nitrophosphates, phosphate rock and Single Super Phosphate (SSP) which represents 30 per cent of the EU market.
Second, there is a misunderstanding about how new technologies are implemented at industrial levels. Just because technologies exist on paper or in laboratories, does not make them "available".
Large-scale chemistry is very different. We support R&D in decadmiation technologies but the current funding options favour foreign producers at the expense of EU producers.
Essentially, the Commission is helping our foreign competitors. Finally one major question is still unanswered: how do we all manage the cadmium waste that would be generated?
What about utilising recycled phosphorus and organic fertilizers as sources of phosphorus?
While both have an important role, they will not substitute mineral fertilizers simply because they don't have the same fertilizing properties and are not used for the same agronomic purposes. Organic fertilizers are generally lower in phosphorus.
To replace mineral phosphate fertilizers, they would have to be applied in much larger quantities and that could lead to imbalances in other parameters like nitrate or organic matter, as well as some contaminants.
The Commission's own impact assessment makes it very clear that there is no sufficient supply of recycled material (including struvite) to cover EU needs. Also, the carbon footprint of these products is much higher, due to the emissions in the transportation of low nutrient content products.
So what would the consequences of reducing cadmium limits below 80 mg be?
An increase of the cost of phosphate fertilizers is the most obvious consequence, which is why EU farmers are calling for a 15 year moratorium on limits. The price increase would result from the drastic reduction of companies able to supply the EU, which would also endanger Europe's access to that critical material. The vast majority of sources compatible with such limits are located in Russia and owned by fertilizers producers that compete with EU producers.
In addition, such limits would have severe consequences on the economy of countries that currently supply the EU such as Tunisia and Morocco and for which phosphate exports to the EU represent a significant part of their GDP.
This would clearly not help the already difficult political situation in North Africa, and, when the EU is placing migration and security issues at the top of its priorities, this is something we should not ignore.
Why then do you think that some MEPs and member states support a low cadmium limit?
The most vocal proponents of low limits come from countries that are not affected: they simply do not produce much agriculture nor use fertilizers. Countries with low national cadmium limits account for only 19 per cent of all EU phosphate fertilizer consumption.
We are also under the impression that MEPs have been misled on the applicability of national limits. The vast majority of phosphate fertilizers are sold in the EU as EC fertilizers for which national limits are not applicable. According to our analysis, only five per cent of fertilizers placed on the EU market experience a cadmium limit below 80 mg.
The problem of cadmium affects mostly those countries and industries that are major agricultural and fertilizer producers - Bulgaria, France, Poland, Portugal, Romania, Spain and the United Kingdom, and they support a limit of 80 mg.
Pierre Jaouen is Director of Regulatory Affairs at animal, human and plant nutrition specialists, Groupe Roullier
Paloma Pérez Sánchez is Secretary General of ANFFE the Spanish National Association of Fertilizer Producers