The fertilizer and biostimulant sector is constantly evolving, seeking new sources of sustainable and safe nutrients. In this context, the use of animal by-products in the manufacture of fertilizers and soil amendments has gained relevance. However, their use is regulated by Regulation (EC) No. 1069/2009, which establishes sanitary standards to ensure safety in handling and application. This Regulation is also known as the SANDACH Regulation in Spain, but each country has its own name such as SOA (sottoprodotti di origine animale) in Italy or SPA (sous-produits animaux) in France, although at EU level the acronym ABP (Animal By-Products) is used to refer to Animal By-Products in general.

What is SANDACH?

SANDACH stands for “Subproductos Animales No Destinados Al Consumo Humano”, Animal By-products Not Intended for Human Consumption in Spanish. These are animal-origin materials that, although not fit for human consumption, can have other industrial uses, including their transformation into organic fertilizers. Proper management is key to preventing health and environmental risks while enabling resource utilization within the circular economy.

How are animal by-products classified?

Regulation (EC) No. 1069/2009 classifies animal by-products into three categories based on their level of sanitary risk:

1. Category 1 (High Risk):
   • Animals with transmissible diseases or residues of prohibited substances.
   • Animals used in experiments or with severe environmental contamination.
   • CAN NOT be used in fertilizers; must be disposed of through incineration or specialized landfills.
2. Category 2 (Medium Risk):
   • Includes manure, digestive content, and some animal-origin products.
   • Can be used in organic fertilizers after composting or anaerobic digestion.
   • Must meet strict sanitary controls before application in agricultural soils.
3. Category 3 (Low Risk):
   • Remains of slaughtered animals fit for human consumption but not marketed.
   • By-products from the dairy industry, eggshells, fish residues.
   • Can be used in fertilizer and biostimulant production after proper treatment.

What are the requirements for using Animal by-products in fertilizers?

The use of animal by-products in fertilizers is subject to strict regulations to ensure safety and traceability. Some key requirements include:

• Mandatory treatment: Materials must undergo sterilization, composting, or anaerobic digestion to eliminate pathogens.
• Facility authorization: Processing plants must be registered and comply with national animal by-products law regulations.
• Traceability and documentation: Records of origin, transformation, and final destination of the by-products must be maintained.

What is the “End Point” in fertilizer production?

The “end point” refers to the moment when a product derived from animal by-products is no longer regulated by the (EU) 2009/1069 Regulation and is instead considered a fertilizer product under Regulation (EU) 2019/1009.

To achieve this status, fertilizers must:

• Have undergone treatment according to Delegated Regulation (EU) 2023/1605.
• Be manufactured in authorized facilities.
• Comply with microbiological and contaminant safety standards.

Benefits of using Animal by-products in fertilizers

• Sustainability: Allows valorisation of animal-origin waste, reducing dependence on chemical inputs.
• Nutritional Efficiency: Some by-products, such as fish residues or processed blood, are rich in nitrogen and phosphorus.
• Circular Economy: Promotes resource utilization within the agro-industrial sector, reducing waste.
• Soil Structure Improvement: Organic fertilizers derived from animal by-products enhance water retention and soil fertility.

The use of animal by-products in fertilizer manufacturing represents an opportunity for the agrochemical sector, provided that current regulations are met. Proper management of these materials not only ensures sanitary safety but also contributes to the sustainability and efficiency of the agricultural sector.

In a market increasingly focused on sustainability and innovation, understanding and applying animal by-product regulations is essential for companies looking to differentiate themselves and invest in more ecological and responsible solutions.

March 2025

Sun Chemicals Services Team

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