The European Commission is moving towards a significant expansion of Component Material Category 10 (CMC 10) under Regulation (EU) 2019/1009 on EU fertilising products.
The draft Delegated Regulation published in April 2026 proposes allowing eight new groups of products derived from animal by-products to be used in fertilisers, biostimulants, soil improvers and other CE-marked fertilising products.
The proposal has not yet been definitively adopted. However, its content allows manufacturers using raw materials of animal origin to anticipate new opportunities for placing their products on the European market in accordance with Regulation (EU) 2019/1009.
What is CMC 10?
Regulation (EU) 2019/1009 classifies the materials that may form part of an EU fertilising product into different Component Material Categories, or CMCs.
CMC 10 covers derived products falling within the scope of Regulation (EC) No 1069/2009 on animal by-products not intended for human consumption.
For one of these materials to be used directly as a component of a CE-marked fertilising product, two separate conditions must be fulfilled:
- The material must have reached an end point in the manufacturing chain in accordance with animal by-product legislation.
- The material must be expressly included in CMC 10 of Regulation (EU) 2019/1009.
The end point is the stage from which the derived product is no longer subject to the veterinary controls established under animal by-product legislation and becomes regulated by the legislation applicable to its intended final use.
Processed manure validation
The first material included in CMC 10 was processed manure, added by Delegated Regulation (EU) 2024/1682.
The new draft Regulation does not propose its approval again. Instead, it expands CMC 10 by adding eight further groups of materials for which conditions for reaching an end point have already been established under Delegated Regulation (EU) 2023/1605.
The eight new materials proposed
1. Processed frass
The draft proposes including processed frass from farmed insects.
Its inclusion is particularly relevant for the development of organic fertilisers and products associated with industrial insect farming. However, the frass will have to comply with the treatment and end-point conditions laid down in Delegated Regulation (EU) 2023/1605.
The proposal also introduces specific labelling requirements. Where the selenium content exceeds 10 mg/kg of dry matter, it must be declared on the label. Information must also be provided on possible ammonia emissions, together with a warning that processed frass may provoke sensitising reactions.
2. Glycerine from Category 2 and Category 3 materials
The proposal would also allow glycerine obtained from Category 2 and Category 3 materials, provided that it complies with the conditions established under animal by-product legislation.
One of the main risks identified is the possible presence of methanol resulting from certain biodiesel production processes. For this reason, the draft establishes a maximum methanol concentration of 0.5% by mass.
3. Processed animal protein
The proposal includes processed animal protein derived from Category 2 materials, under the conditions established in Delegated Regulation (EU) 2023/1605.
This addition could expand the possibilities for using protein materials of animal origin as components of EU fertilising products. However, the manufacturer will have to provide documentary evidence that the material has undergone the required treatment and has reached the relevant end point.
4. Meat-and-bone meal
Category 2 meat-and-bone meal is another of the proposed additions.
This type of material can provide nutrients of agronomic interest, particularly nitrogen and phosphorus. Its future inclusion in CMC 10 would allow it to be incorporated directly into certain CE-marked formulations, provided that the applicable requirements concerning origin, processing, safety and traceability are fulfilled.
5. Category 3 blood products
The draft also includes blood products derived from Category 3 materials.
To be used in EU fertilising products, these materials will have to comply with the processing conditions established under animal by-product legislation and reach the end point before being incorporated into the product. Their inclusion in CMC 10 would facilitate their use in fertilising product formulations throughout the European Union, without relying exclusively on different national legislative frameworks.
6. Hydrolysed proteins
One of the proposed additions of greatest interest to the biostimulant sector is hydrolysed proteins.
The proposal is not limited to hydrolysed proteins obtained from residues from the leather or textile industries. It covers hydrolysed proteins that comply with the conditions established in Delegated Regulation (EU) 2023/1605, while expressly mentioning those derived from residues from these industries. This category may therefore include hydrolysed proteins obtained from different animal by-products, including certain poultry by-products, as well as those derived from leather or textile industry residues.
As hydrolysed proteins derived from leather and certain poultry by-products may contain chromium, the proposal establishes that any EU fertilising product containing hydrolysed proteins as a component material must not exceed 400 mg/kg dry matter of total chromium.
This limit applies to the final EU fertilising product and not only to hydrolysed proteins derived from leather or textile residues. The chromium content must therefore be assessed taking into account the origin of the raw material and the manufacturing process, particularly where leather residues treated with chromium compounds are used.
7. Dicalcium phosphate and tricalcium phosphate
Dicalcium phosphate and tricalcium phosphate of animal origin are also among the proposed materials.
Their inclusion would allow phosphorus and calcium sources derived from animal by-products to be recovered and used, provided that they have been manufactured in accordance with authorised processes and have reached the applicable end point.
Not every dicalcium or tricalcium phosphate will automatically be covered. It will be necessary to verify its origin, the manufacturing process used and its exact correspondence with the conditions established in Delegated Regulation (EU) 2023/1605.
8. Horns, horn products, hooves and hoof products
Finally, the proposal includes horns, horn products, hooves and hoof products.
These materials may be of interest as organic nutrient sources and may contribute to the greater recovery of animal-derived material streams. As in the previous cases, their acceptance will depend on compliance with the treatment and end-point conditions established under animal by-product legislation.
General requirements applicable to CMC 10 materials
The future inclusion of these materials will not constitute an unconditional authorisation.
The draft establishes that the treatment required to reach the end point must have been carried out no more than 36 months before the EU declaration of conformity for the fertilising product is signed.
Certain subsequent processes would also be permitted, including:
- Mechanical separation of solid and liquid fractions.
- Biological treatments involving nitrification and denitrification.
- Recovery of nutrients or organic carbon.
- pH modification.
- Drying, concentration, pelletisation, granulation or other changes to the physical form.
- Certain physical processes included in CMC 2.
Additives used during these processes will have to comply with the corresponding CMC 1 requirements and must not exceed 5% of the total weight of the input material in each process. The materials must also be stored in a manner that protects them from precipitation and direct sunlight.
Thermochemical processes involving high temperatures or pressures, such as pyrolysis, gasification, combustion, hydrothermal carbonisation or liquefaction, are not covered by these provisions, as they are regulated under other Component Material Categories.
What does this proposal mean for manufacturers?
The expansion of CMC 10 could create a harmonised route for placing fertilising products on the market throughout the European Union where those products currently depend on national authorisations or cannot obtain CE marking because of the nature of their raw materials.
However, the inclusion of a raw material in CMC 10 will only be one part of the assessment. Manufacturers will also need to verify:
- The exact correspondence of the material with the legal definition.
- The animal by-product category of origin.
- The processing method applied.
- Evidence that the end point has been reached.
- The applicable contaminant limits.
- The Product Function Category, or PFC, of the finished product.
- Labelling requirements.
- Technical documentation and the applicable conformity assessment procedure.
Furthermore, until the Delegated Regulation has been adopted, published and entered into force, these eight materials must not yet be considered authorised CMC 10 components for an EU fertilising product.
A regulatory opportunity that requires preparation
The proposal represents an important step forward for the circular economy and for the safe recovery of animal by-products in the fertiliser and biostimulant sector.
At Sun Chemicals Services, we support manufacturers and importers in assessing the regulatory feasibility of their raw materials, interpreting the requirements of Regulation (EU) 2019/1009 and preparing the documentation required to place fertilisers and biostimulants on the European Union market.
For more information about our services, please contact our team.
July 2026
Sun Chemicals Services Team
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