COMPO GmbH & Co. KG Münster, 17.02.

2005
Werk Münster

Cadmium in fertilizers
The COMPO GmbH & Co. KG opposes to the ‘Draft Proposal’ relating
to an EU-wide regulation on Cadmium.

The COMPO GmbH & Co. KG is a fertilizer producer with production site in Germany and is
supplier of fertilizers worldwide.

We wish to explain with this document some of our views.

1. Problems and impacts on the market situation in West-Europe:

The manufacturers of fertilizers containing phosphate would have to be limited with a sinking
of the limit value ever more strongly to phosphate-poor raw phosphates. More than 60 % of
the imported Phosphate Rock cannot be used for the production of Phosphate fertilizer if a
limit of under 60 mg Cd/kg P2O5 is enacted.

The introduction of a limit value of under 60 mg Cd/kg P2O5 would be equivalent thereby to
the definition of Russian Kola apatit phosphate as monopoly delivery source.
Despite these substantial price increases the supply meeting demand of phosphate cannot be
guaranteed, because the supplier of Kola apatit phosphate is already today no more able to
fulfil the quantity demands of the customers.
In the medium-term an increase of their capacities is not possible or planned.

On the raw phosphate market for Western 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 would also refer to the finished fertilizers as MAP, DAP and
TSP. West 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 Apatit 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 would lose their home market
in West Europe. 58 % of the Algerian Rock, 31 % of the Tunisian Rock and 26 % of the
Moroccan Rock are delivered to West Europe in the form of Rock, MAP, DAP, TSP or
Phosphoricacid. More than 50 % of the imports of these products to WE come from these
countries.

After imposing a limit of under 60 mg Cd, the Phosphate business between North Africa and
West Europe - as one of the most important economical factors of the region - would break
down. The Phosphate market in West Europe would be dominated by a monopoly of Kola-
Apatit 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

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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 Western Europe would have to be closed.
As the result of these, shut downs and more than a 1,000 jobs would disappear.

2. 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) indicates 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 Marocco. 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, Marocco
and other providers with sedimentary rock phosphate will be out of the scenario as an EU
main supplier, being replaced by Russia or South Africa.

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 (out of the EU borders by
the suppliers, or in the EU by the fertilizers producers) would not change the situation for the
agriculture, because finally, the European farmer 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).

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

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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.

3. Accumulation of cadmiumd in soils and the estimation of the impact of Cadmium in

fertilizers on the environment (ecotoxiicology).

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 are 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
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).

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.

4. Conclusion

The COMPO GmbH & Co. KG is fully supporting the efma position paper for a regulation on
cadmium in fertilizers.

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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.

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