On May 19, 2026, the European Commission published the Fertilizer Action Plan: Alliance to ensure availability, affordability, and strategic autonomy in EU self-produced fertilizers (European Commission, May 19, 2026). In strategic terms, this document is probably more important for the future of biofertilizers in Europe than for the mineral fertilizer market itself. The document points to five clear trends:

1. Digestate ceases to be waste and is considered a strategic raw material.
2. Biofertilizers become a priority European sector.
3. The Commission is preparing mandatory demand mechanisms (lead markets and possible blending mandates).
4. RENURE could be extended to treated digestates, opening a huge market for recovered nitrogen.
5. Future biomethane plants must be designed as integrated energy + fertilizer plants.

The keys to the Biomethane business

If this Action Plan is implemented in the next 2–5 years, the economic value of: treated liquid digestate, recovered ammonium sulfate, struvite (magnesium ammonium phosphate), organic NPK biofertilizers, and composted solid fractions can increase significantly, to the point of becoming a material part of a biomethane plant’s revenue, similar to what has occurred with sustainability certificates in the biofuels market.

We conduct an in-depth analysis:

This document probably represents the most significant change in European fertilizer policy since the approval of the Fertilizer Products Regulation (FPR 2019/1009). Although the formal objective of the Plan is to respond to the mineral fertilizer price crisis and Europe’s strategic dependence on imported natural gas, ammonia, phosphate, and potash, a detailed reading reveals something much more relevant: the European Commission has decided to turn #Biofertilizers into a strategic sector. For the first time:

• Biofertilizers appear as a central element of European strategic autonomy.
• The creation of mandatory markets (“lead markets”) is proposed.
• The possibility of blending requirements is explicitly mentioned.
• Regulatory simplification is planned for digestates, treated manures, and derived products.
• Biomethane production is directly linked to fertilizer production.
• It is proposed to use CAP, ETS, Cohesion, Innovation Fund, and CBE-JU funds to accelerate the sector.

From the perspective of IAM Carbonzero, this document is extraordinarily positive because it turns digestate and digestate-derived fertilizers into a European strategic line and not simply a byproduct of biogas plants.

What problem is the European Commission trying to solve?

Vulnerabilities arising from dependence on imports: 25-30% of nitrogen fertilizers, 35-45% potash, and 70% phosphate fertilizers. Three vulnerabilities are identified:

1. Energy vulnerability: Nitrogen fertilizer manufacturing depends on natural gas and represents 70-80% of the production cost of nitrogen fertilizer.
2. Geopolitical vulnerability: Dependence on Russia, Belarus, and the Middle East. Areas of extreme instability.
3. Climate vulnerability: Industrial nitrogen fixation generates 50-60 MtCO₂/year, which accounts for approximately 1.5% of all European emissions.

Why are Biofertilizers becoming a strategic key in the EU?

In section 4.2.2. of the document, it literally states: “The Commission will support the development and adoption of organic fertilizers and alternatives to conventional inorganic fertilizers, in particular bio-based fertilizers…” which leads us to the current ecosystem of a Biomethane plant that applies BAT (best available techniques). That is, the following are identified as priorities: nutrient recycling, phosphorus recovery, nitrogen recovery, digestates, biogas and biomethane production, algae, and microbial solutions.

#Digestate is explicitly recognized as the Commission announces urgent measures to facilitate its use, as well as the creation of a regulatory “Sandbox” to: test new fertilizer products, validate recovery technologies, and reduce regulatory times.

It is officially recognized that a Biomethane plant is also a fertilizer plant (connecting with the term “biorefineries” that…) linking digestate, biogas, biomethane, and recycled fertilizers.

Nutrient recovery from digestates, wastewater, sludge, and bio-waste becomes a community objective.

New market rules

The Commission is studying requiring fertilizers to contain a minimum bio-based, low-carbon, recycled content fraction between 5% and 20%. In this way, a processed digestate could: replace mineral fertilizers; provide mandatory bio-based content; generate market premiums.

This could become the fertilizer equivalent of sustainability certificates for renewable fuels.

The Commission wants to create protected markets for biofertilizers, “Lead Markets,” creating demand through regulation as is already done in solar energy, electric vehicles, SAF, and biomethane.

New Waste Directive framework

The revision of “livestock digestates” is highly relevant: animal byproducts, manures, digestates, and composts. The goal is to facilitate their use, marketing, and transport. Today, a large part of the cost of digestate comes from regulatory restrictions. The Commission explicitly recognizes that these barriers must be reduced. This forces the replacement of mineral fertilizers and counting outside the nitrogen limits of the Nitrates Directive. One of the products that can benefit the most is phosphorus, as the plan explicitly includes phosphorus recovery, nutrient recycling, and wastewater recovery. If treated liquid digestates are finally included: the European potential market multiplies.

What are the financing instruments?

The document includes all available instruments:

• The CAP with Eco-Schemes, precision agriculture, nutrient recycling, and digesters.
• Cohesion Funds: to finance anaerobic digestion; sludge recovery; bio-waste recovery, and nutrient recovery.
• Innovation Funds: Biofertilizers and low-carbon fertilizers.
• Circular Bio-based Europe (CBE JU): The Commission is already funding flagship projects for the implementation of bio-based fertilizers.

The Commission’s vision is designing a second source of income for Biomethane plants based on circular biofertilizers, and defines a unique value chain that materializes in:

Waste → Anaerobic digestion → Biomethane → Digestate → Biofertilizer → Recycled nutrients → Agriculture

The Biogas Roadmap approved by Spain in 2022 already anticipated that biomethane and organic fertilizers should be developed as the same value chain. Four years later, the European Commission seems to confirm that vision. For Spain, which concentrates one of the highest biomethane production potentials in Europe and has a significant agro-livestock base, the message is unequivocal: future rural biorefineries will not only produce renewable energy, but also strategic fertilizers for Europe’s food, energy, and industrial autonomy. Those who design their projects today thinking about both markets will be better positioned to capture value in the next decade.

#Biorefineries #Biomethane #Biofertilizers #Regulation