Processed manure and processed frass: what does “processed” mean?

Manure is any excrement or urine of farmed animals, with or without litter. Excrement of farmed fish is not manure (Regulation (EC) No 1069/2009, Article 3(20)). Manure is Category 2 material.

Frass is a mixture of excrement from farmed insects, the feeding substrate, parts of farmed insects and dead eggs. It may contain no more than 5 % dead farmed insects by volume and no more than 3 % by weight (Regulation (EU) No 142/2011, Annex I). Frass got this definition in 2021 (Regulation (EU) 2021/1925). The same regulation aligned its rules for treatment and sale with those for processed manure.

Processed manure and processed frass must meet these conditions (Regulation (EU) No 142/2011, Annex XI, Chapter I, Section 2):

• they come from a biogas plant, a composting plant, a plant that makes organic fertilisers or soil improvers, or a plant for derived products for uses outside the feed chain;
• they have been heated to at least 70 °C for at least 60 minutes to kill harmful bacteria, and spore-forming bacteria and toxin formation have been reduced where these are a relevant hazard. For manure sold under national rules, the competent authority may allow other validated time and temperature settings. For CE-marked products, the 70 °C for 60 minutes treatment always applies;
• samples taken during or right after processing are all below 1,000 E. coli or 1,000 Enterococcaceae per gram (5 samples);
• samples taken in storage contain no Salmonella in 25 g (5 samples);
• they are stored so that contamination, secondary infection and dampness are kept to a minimum, in sealed and insulated silos, proper storage sheds or sealed bags such as big bags.

Processed manure that does not pass the bacterial tests is regarded as unprocessed.

No. CMC 10 asks for more (Regulation (EU) 2019/1009, Annex II, CMC 10):

• the end point must have been reached no more than 36 months before you sign the EU declaration of conformity;
• the material must have had extra processing on top of the 70 °C for 60 minutes treatment. This extra step is about particle size, weed seeds or stability, not about bacteria. At least one of these three options must apply:
  1. at least 90 % by dry mass passes a sieve with a 0.25 mm mesh;
  2. it has been granulated under pressure, pelletised or dried above 100 °C, or has had another treatment with the same effect, so that it contains no more than 3 viable weed seeds and plant propagules per litre;
  3. it meets one of the stability criteria for compost in CMC 3, point 5.
• it may contain no more than 6 mg/kg dry matter of PAH16;
• it must be stored protected against precipitation and direct sunlight.

The label must also give information about possible ammonia emissions to air, with an invitation to users to take remediation measures. It must also carry a warning about aminopyralid and clopyralid, unless the product contains no more than 50 µg/kg dry matter of these substances (Annex III, Part I, point 7c).

Unprocessed manure can still be used under the animal by-products rules, for example spread on land, composted or turned into biogas, when the competent authority does not see a risk of spreading a serious disease (Regulation (EC) No 1069/2009, Article 13). It cannot be used as a CMC 10 material in a CE-marked fertilising product.