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RecyFert

Which module must I use for my product?

Last reviewed 5 October 2026. Source: Regulation (EU) 2019/1009, consolidated text of 1 July 2026.

In simple words

Annex IV of the regulation decides. Module A is for products made only from simple materials. Module B followed by C is for a wider list of materials. Module D1 can be used for almost every product. Module A1 is only for high-nitrogen ammonium nitrate fertilisers.

Words in this article

Module
One of the fixed routes for conformity assessment. The regulation has Module A, Module B followed by Module C, Module D1 and Module A1.
CMC (component material category)
A group of materials a product can be made from. There are 15 groups: virgin material substances and mixtures (CMC 1), plants, plant parts or plant extracts (CMC 2), compost (CMC 3), fresh crop digestate (CMC 4), digestate other than fresh crop digestate (CMC 5), food industry by-products (CMC 6), micro-organisms (CMC 7), nutrient polymers (CMC 8), polymers other than nutrient polymers (CMC 9), derived products (CMC 10), by-products (CMC 11), precipitated phosphate salts and derivates (CMC 12), thermal oxidation materials and derivates (CMC 13), pyrolysis and gasification materials (CMC 14) and recovered high purity materials (CMC 15).
PFC (product function category)
A group that says what the product does. There are 7 groups: fertiliser (PFC 1), liming material (PFC 2), soil improver (PFC 3), growing medium (PFC 4), inhibitor (PFC 5), plant biostimulant (PFC 6) and fertilising product blend (PFC 7).
Fertilising product blend (PFC 7)
A product made by mixing two or more EU fertilising products that already follow the rules.
Inhibitor (PFC 5)
A product that slows down certain microbes or enzymes in the soil. Nutrients are then released more slowly.
High-nitrogen ammonium nitrate fertiliser
A solid fertiliser based on ammonium nitrate with a high nitrogen content. It has its own route, Module A1.
Plant biostimulant (PFC 6)
A product that helps plants take up and use nutrients, whatever amount of nutrients the product itself contains.

Module A

You may use Module A if the product is made only from these materials:

  • CMC 1: virgin substances and mixtures. This does not include inhibitor compounds.
  • CMC 4: fresh crop digestate
  • CMC 6: food industry by-products
  • CMC 8: nutrient polymers
  • CMC 11: by-products (waste rules)

You may also use it for a blend (PFC 7). You may not use it for inhibitors (PFC 5), plant biostimulants (PFC 6) or high-nitrogen ammonium nitrate fertilisers.

Module B followed by Module C

You may use this route if the product is made only from these materials:

  • inhibitor compounds from CMC 1;
  • CMC 2: plants, plant parts or plant extracts;
  • CMC 7: micro-organisms;
  • CMC 9: polymers other than nutrient polymers;
  • CMC 10: derived products;
  • any material that is on the list for Module A.

You may also use it for a blend. You may not use it for high-nitrogen ammonium nitrate fertilisers.

Module D1

You may use Module D1 for any EU fertilising product. The exception is high-nitrogen ammonium nitrate fertilisers and blends with 28 % or more nitrogen from them.

Products with CMC 3 (compost), CMC 5 (digestate), CMC 12, 13, 14 or 15 are not on the lists for Module A or for Module B followed by C. So these products use Module D1.

Module A1

Module A1 is for high-nitrogen ammonium nitrate fertilisers and blends with 28 % or more nitrogen from them. RecyFert does not offer Module A1.

Common questions

Can I use Module D1 if Module A is also allowed?

Yes. Module D1 may be used for any EU fertilising product, except high-nitrogen ammonium nitrate fertilisers and some blends with them.

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