The EU’s “Expert Group for Technical Advice on Organic Production” (EGTOP) has confirmed its positive opinion (2016) that “recovered struvite” should be authorised in Organic Farming, but now widens this to other recovered precipitated phosphate salts (coherent with the EU Fertilising Products Regulation CMC12 definition - here). EGTOP recommend that for precipitated salts from animal manure, this shall not be of “factory farming” origin. This new EGTOP Opinion thus recommends a wider and simpler inclusion of recovered precipitated phosphate salts into Organic Farming than did the EGTOP 2016 Opinion, which covered only struvite from municipal wastewater. The new Opinion effectively recommends that any recovered phosphate salt corresponding to the criteria of the EU Fertilising Products Regulation 2019/1009 CMC12. However, it is NOT clear to ESPP whether EGTOP recommends (a) that also “derivates” (as defined in CMC12) should be included and (b) that the product must have obtained the CE-Mark (i.e. undergone Conformity Assessment as defined in 2019/1009 Annex IV. ESPP hopes that the European Commission (DG AGRI) will now move rapidly to add recovered precipitated phosphate salts to Annex II of the EU Organic Farming Regulation. ESPP does not understand why recovered “calcined phosphates” are not included in this new EGTOP Opinion, despite they were positively approved by EGTOP in 2016 at the same time and under the same conditions as recovered struvite
EGTOP “Final Report on Plant Protection (VII) and Fertilisers (V)”, adopted 8-10 June 2022 at this LINK 

Source: ESPP