Ref.

Ares(2014)76860 - 15/01/2014

K+S Group Kassel, 26.9.2003

Cadmium in fertilizers
Position of the K+S Group with regard to the draft proposal
of DG Enterprise for a regulation of the EU-Parliament and
of the Council relating to cadmium in fertilizers

The K+S Group is one of the world´s leading manufacturers of mineral fertilizers for
agriculture. Along with K+S KALI GmbH, COMPO and fertiva, K+S is the second largest
provider of agricultural and speciality fertilizers in Europe.

The K+S Group opposes to the draft proposal relating to an EU-wide regulation
on cadmium in fertilizers for following reasons:

• The ecotoxical impact of cadmium in soils is based on wrong assumptions and is

overestimated.
• The proposed Cd limits in fertilizers will give preference to a monopolistic
market supply structure in Europe resulting in price increases of phosphate
fertilizers and agricultural products.
• A decadmiation technology has yet to be developed which is technical and economical
very problematic and environmentally questionable (increase of special waste and
transport distances).

1. Accumulation of cadmium in soils and the estimation of the impact of Cadmium in

fertilizers on the environment (ecotoxicology).

Cadmium is a natural element of soils. All soils contain Cd related to the geology of the parent
rock. Therefore, the Cd content is varying very much according to the parent rock. Various
studies of arable soil have shown that the good agricultural practice does not result in a
higher accumulation of heavy metals like Cd (Liebe, 1999). Additionally, various studies
showed that grassland soil contains generally a higher amount of Cd, even with less input of
Cd compared to arable land. This is mainly due to the fact, that the higher Cd content of
grassland results in the major influence of parent rock to Cd content in the soil (König, 1986;
Liebe et al. 1997). Therefore, the parent rock contributes to a great amount to the Cd content
in the soil.

Additionally, the total content of Cd in soil does not give an exact indication of the mobility of
Cd in soils and its ecological impact (Andersson 1975; Blume & Brümmer 1987). Also the
most recent studies, which were based on the average Cd exposure conditions, have not
shown any immediate Cd risk for soil biology.

This transfer mechanism is mainly based on a small quantity of soil parameters like total
content of Cd, pH-level or the mobile fraction of Cd in soils. But generally the use of such

1 of 4
function does not represent all the important soil parameters and the great variety of soil
conditions in nature. Many factors like the interaction and competition between different
elements, soil parameters and Cd-content in soil (total content or mobile fraction) are
neglected in many models. Therefore, the uncertainty of transfer models in soils are too big to
derive the assessment of risk from the basis of total content or even from the mobile fraction
of Cd in the soil including pH-value (Schütze et al.2003).

More balanced and consistent regulations on sewage sludge and other recycling products will
be an important factor for a further reduction of the total cadmium input.

In many investigations the Cd exposure pathway soil – plant – plant/animal – foodstuff – man,
total human Cd uptake and resorption were mainly calculated from food consumption. But
there was also a considerable variability in the risk characterisation of Cd impacts from P
fertilizers for both ecotoxicological and the human health assessment when different scenarios
of Cd exposure and Cd susceptibility were considered.
A general assumption or conclusion cannot be drawn and further investigations are
necessary, as various surveys are showing a lot of various diverging results.

2. Problems and impacts on the market situation in Europe:

By lowering the limit for Cd in fertilizers the manufacturers of phosphate fertilizers will depend
even more strongly on phosphate-poor raw phosphates. More than 60 % of the imported
phosphate rock cannot be used for the production of phosphate fertilizers if a limit of under 60
mg Cd/kg P2O5 is enacted!

Since there is no large-scale decadmiation technology available yet the introduction of a limit
value of under 60 mg Cd/kg P2O5 would create a selection amongst suppliers for geological
reasons (phosphate rock from magmatic rocks versus sedimentary origin). This is equivalent
thereby to the definition of Russian Kola apatite phosphate as monopoly delivery source
(phosphate rock of magmatic origin).
Despite these substantial price increases the supply meeting demand of phosphate cannot be
guaranteed, because the supplier of Kola apatite phosphate is already today no more able to
fulfil the quantity demands of the customers (capacity problems).
In the medium-term an increase of their capacities is not possible or planned.

On the raw phosphate market for Europe this monopoly situation would lead immediately to
substantial price increases, which would have to be passed on to the agriculture.

A cadmium limit of under 60 mg/kg would also refer to the finished fertilizers as MAP, DAP
and TSP. Europe imported 1,44 Mio t P2O5 of these products in 2002.
Only about 30 % of this quantity would fulfil the limit – these products are based on Russian
Kola apatite rock! We doubt, that the remaining 70 % can be replaced by “low Cd” product
from these sources. There would be an immediate increase in the a.m. price, which the
consumers of these products would have to face straight away.

The phosphate rock producers in Algeria, Morocco and Tunisia (source of sedimentary
phosphates) would lose their home market in Europe. 58 % of the Algerian rock phosphate,
31 % of the Tunisian rock phosphate and 26 % of the Moroccan rock phosphate are delivered
to Europe in the form of rock phosphate, MAP, DAP, TSP or phosphoric acid. More than 50 %
of the imports of these products to Europe come from these countries.

After imposing a limit of under 60 mg Cd, the phosphate business between North Africa and
Europe - as one of the most important economical factors of the region - would break down.

2 of 4
The phosphate market in Europe would be dominated by a monopoly of Kola-apatite
phosphate and its derivatives, leading to huge price increases of these products.

In addition to this, the required quantities for the industry and the farmers cannot be supplied
by the “remaining suppliers”. The actual production capacities of these companies are not big
enough and a slowly but surely increasing demand within the FSU states will also absorb
increasing quantities of the local producers there leading to limited export availability.

If more of 60 % of the imported phosphate rock does not fulfil a limit of under 60 mg Cd/kg
P2O5 a lot of fertilizer plants in Europe would have to be closed.
As the result of these, shut downs and more than a significant amount of jobs would
disappear.

3. Decadmiation technology: technical and economical problematic

Actually, there are two possibilities to remove cadmium from the phosphor fertilizers: removing
cadmium from phosphate rock (calcination method) and removing cadmium from wet process
phosphoric acid (being co-crystallisation the most promising method). From an economical
point of view, the second method is the more practicable. Nevertheless, since there is no
decadmiation plant actually running, it is difficult to estimate the cost resulting from the
decadmiation. The estimation vary between US$ 20 and US$ 45/ ton P2O5 at the primary
production stage (not taking into account the costs derived from the residual cadmium). It is
very difficult to establish the cost consequences of a technology that is still in laboratory scale
and not yet commercially viable. Some sources (Davister, 1996) indicate that in best case
(anhydrite co-crystallisation) the operating costs are still 20 to 30% of the wet process acid
operating costs. In other methods the costs are over 75% of the WPA operating costs.

The macro-economical consequences of the proposed measure will lead to market

segmentation and will have a very negative consequence in countries like Morocco. There the
decadmiation plant has already been tested in laboratory scales, but without commercial
continuity. That means that since there is no technology ready to be implemented, Morocco
and other providers with sedimentary rock phosphate will be out of the scenario as an EU
main supplier, being replaced by suppliers of phosphates with magmatic origin such as
Russia.

It cannot be assumed that the farmer should hold the extra-costs resulting from this measure
easily. In many cases, farmers are already in a very difficult situation, mainly in extensive
crops areas with a high dependence of EU aids, so that it will be hard to transfer the costs to
the farmers. It is difficult to define the elasticity of phosphor consume to price increase, but it
will probably induce a reduction in P fertilization, mainly in the less profitable extensive crops.
The possible negative effect of phosphor fertilizer, with regard to environmental cadmium,
must be balanced against their importance in agriculture.

The discussion where the decadmiation process has to take place (outside of the EU borders
by the suppliers, or within the EU by the fertilizers producers) would not change the situation
for the agriculture, because finally, the European farmers will have to pay the bill.

Decadmiation technology: an environmentally correct solution?

In addition, it has to be taken into account that the decadmiation method produces a by-
product containing cadmium, which will have to be treated as a hazardous waste, the costs
resulting from its treatment have to be defined. (This problem appears when the decadmiation
is applied to phosphoric acid, in case of the calcination of rock phosphate the cadmium is
volatilizated).

3 of 4
On the other hand, assuming that the decadmiation of phosphoric acid is the most efficient
option, it will probably induce the fertilizer industry to use the phosphoric acid route as much
as possible. That means that the main alternative method, the “Odda” process, will be less
applied (it is a process that does not allow decadmiation). Taking into account that the
implementation of this method was in response to environmental pressure, we come to a
contradiction.

Finally, the use of the phosphoric acid route will lead to an important increase of waste
gypsum enriched with cadmium. Today waste gypsum is already an important problem (due to
cadmium content, other impurities, and radioactivity), which will be strongly increased by the
proposed limitation of cadmium in phosphate fertilizers. That is, we are trying to solve a
problem just by transferring the problem to another field.

A reduction of the maximum level of cadmium should be postponed to the moment in which
the implementation of a decadmiation technology is viable from the technical and economical
point of view, and to the moment in which it is clarified what to do with the resulting
contaminated waste gypsum.

4. Conclusion

The K+S Group is fully supporting the position of the European Fertilizer Manufacturers´
Association for a regulation on cadmium in fertilizers.

Strong doubts and reservations remain with regard to the technical justification of the planned
measures. Still there is no evidence about the ecotoxicological behaviour of cadmium, and the
risk assessment of cadmium in the food chain are not yet clearly defined.

At the moment there is no realistic process available for the decadmiation. Also there is no
practicable solution coming up in the foreseeable future.

Even after decadmiation processes being applied cadmium is still a residue which has to be
treated as such, and so remains as a problem to be solved.

4 of 4