Forum global sur la sécurité alimentaire et la nutrition (Forum FSN)

The Spanish National Association of Fertilizer Manufacuturers supports the initiative of FAO to develop a Code of Conduct for Fertilizers, and to create a relevant document for helping both our industry and the stakeholders that are related with the fertilizer sector. Please see our comments attached

 

Thank you very much to the FAO for giving stakeholders the possibility of sharing views and concerns regarding the zero-draft International Code of Conduct for the Use and Management of Fertilizers. 

On behalf of fertilizers Europe, I would like to underline that our association has strong concerns regarding the current draft submitted for consultation and also regarding the way the  process is handled by the FAO Secretariat. The priority should be quality and relevance of the Code, even if adoption is postponed by a couple of years. Especially, it is not acceptable that some sections of the draft have been clearly "cut and pasted" from the Code of Conduct for Pesticides. Fertilizers and pesticides have nothing in common, so using the Code of conduct for pesticides as a starting point for this exercise in very inappropriate.

Please find below and attached further comments. 

About Fertilizers Europe

Fertilizers Europe represents the majority of fertilizer producers in Europe and is recognized as the dedicated industry source of information on mineral fertilizers. The association communicates with a wide variety of institutions, policy-makers, stakeholders and members of the public who seek information on fertilizer technology and topics relating to today’s agricultural, environmental and economic challenges. “Infinite Fertilizers” guides the European fertilizer industry’s initiatives to ensure that Europe’s farmers have access to a variety of safe, high quality, locally produced fertilizers, as well as information on their use, environmental impact and nutrient recycling opportunities. We as European fertilizer industry:

• Are committed to the development of innovative products and recycling techniques to maximize the productivity and the sustainability of European agriculture.
• Are searching close collaboration with the farming community and the entire food chain to improve nutrient use efficiency and reduce the environmental footprint of food production.

Comments regarding the process

Fertilizers Europe considers that it is a great opportunity to create a truly relevant and meaningful document not only for our industry but for all key stakeholders that are closely involved in the sector of plant nutrition. However, the development of such an extensive and important document cannot be taken lightly, and should not be rushed through. Creating a substantial and impactful document, that provides true guidance, takes time.

This is why Fertilizers Europe believes that the proposed timeline (coming up with a zero draft in 6 weeks, getting it reviewed by the Intergovernmental Technical Panel on Soils (ITPS) and an Open-Ended Working Group within roughly 2 weeks, and coming up with a revised zero draft only a couple of days later for consideration at the Global Soil Partnership (GSP)’s Plenary Assembly in June) does not provide for sufficient consultation, and simply cannot result in a document which provides meaningful guidance and recommendations.

The FAO is renowned for its sound scientific, thorough and reliable work. If this document cannot benefit from more consultations and improvements, the outcome will not only affect the reputation of the FAO, but the code will ultimately not generate the adherence and support that it would be supposed to get from its target audiences.

Comments regarding the content of the Zero Draft

1. Too many approximations

What is immediately striking is the number of repetitions throughout the whole document, while there are entire areas and topics that would clearly benefit from clearer definitions and clarifications. Here, Fertilizers Europe would like to raise a few examples:

• The differentiation between organic and mineral fertilizers would deserve more thoughts. It would be useful to assess and discuss where a stronger distinction within the document would make better sense and where both nutrient sources can be combined within the same paragraph. The draft weights also differently between organic and mineral fertilizers. We strongly recommend looking at the complementarity in assessing benefits and value of both.
• The context of scientific evidence and scientific risk assessments is not fully taken into account, in particular in paragraphs referring to risks and contaminants. In general, the language is very generic and non-specific in paragraphs relating to risks in usage, handling or storage. However, these are areas where a code of conduct has to be very carefully formulated.
• As enshrined in WTO rules, a sound basis on scientific risk assessment should underpin any recommendations to governments. The notion of risk management also needs to be enshrined in the code, so as to demonstrate that potential risks can be adequately addressed. For the future relevance of the code, these chapters should not be “brushed over”.
• Some good instruments within governance, initiatives, programs and regulations already exist in relation to fertilizer value chain (production, transport, QC, labelling, trading etc.) For lack of time, these have not been considered enough in the Zero Draft yet, and deserve to be closer looked at.
• Economic considerations are also widely ignored, whereas this is of major interest and concern not only in regions that must overcome underuse of fertilizers.

2. Quite unbalanced document so far

While the preamble of the document clearly states that its goal is to “maximize benefits and reduce environmental impacts”, the current draft is unbalanced. Benefits and the need to address not only overuse but also underuse are side-lined in favor of an overwhelming strong focus on pollution. Worldwide, underuse cases are at least as widespread as overuse ones, and both are equally important from a sustainability standpoint, considering that nutrient underuse contributes to soil degradation and soil erosion. Also, the concept of “responsible use” should be clearly defined and not be limited to overuse.

3. Many remaining gaps

We would recommend a stronger focus on aspects linked to nutrition, farmers’ livelihoods and adaptation to climate change. These aspects need to be explored more, also for the benefit of policy-makers and advisors in developing countries and with a view to align the recommendations of the code with SDG targets and UNFCCC goals. The Code of Conduct should be anchored within a global framework of Agenda 2030. Also, much more emphasis should be placed on the farmer as a decision-maker. Farmers have a critical role to play in sustainable fertilizer use. More thoughts should be given to how the industry, governments, research and extension could support this role.

4. The Whole basis of the draft Code needs to be reviewed

Some wordings used in the Zero Draft risk to create misunderstanding and confusion, while some definitions should be corrected:

• Some sections are clearly “cut and pasted” from the Code of Conduct for Pesticides, which was used as starting point for developing the Zero Draft (e.g. references to “remediation measures”, “allowable limits” do not apply to fertilizers). The same goes for references to shipping, where pesticides require a completely different handling and management. This is totally unacceptable from the point-of-view of Fertilizers Europe.
• Fertilizers Europe would like to take this opportunity to emphasize that fertilizers and pesticides, besides both being important agricultural inputs, have nothing else in common. Fertilizers are aimed at feeding plants while pesticides are used to kill or control pests and diseases. As such, risks associated with fertilizer use are much lower compared to pesticides. Using the code of conduct for pesticides as a starting point for this code of conduct is very inappropriate in our view.
• Certain paragraphs seem to imply that there is a risk inherent to fertilizers itself – independently from the storage, handling and use. As mentioned above, this aspect must be very carefully worded to avoid misinterpretations once the code is published.

• The definitions used are not always aligned with already existing FAO definitions that have been approved by member states. Here again, definitions have been drafted too quickly, without the necessary consultation.
• Terminologies relating to slow- and controlled-release fertilizers, for instance, are not accurate. The fertilizer industry can provide assistance with product definitions. The code would clearly benefit from this assistance.

Concluding remarks

In summary, very substantial improvements are still required to make the current draft relevant and ready for adoption. We are of the opinion that the priority should be incorporating specific comments made during the GSP Plenary Assembly in June (by France, Germany, Jordan, Morocco, The Netherlands and the International Fertilizer Association - IFA) and submit a new draft for consultation to the COAG. It would reflect a transparent, step-wise and constructive negotiation process.

We believe that the speed with which this document had to be pulled together is the main factor for its weaknesses, flaws and gaps. One must bear in mind that fertilizers have a major role to play for the world’s future in terms of food security. 50 % of our food produced today is based on mineral fertilizers. At the same time, nobody denies that mineral and organic nutrients impact the environment and that improved management practices are of major importance.

Given the critical role of fertilizers, Fertilizers Europe strongly recommends giving appropriate weight to the development of such a significant document: it is ultimately the extent of its content that will decide if this code is truly relevant for nutrient stewardship or if it will be dismissed as superficial and too general.

As per my experience as a pesticide toxicologist with the international code of conduct for pesticides and my long observation about pesticides and fertilizer pollution I like to add my general comment: what I have observed during decades of experience all these global laws and regulations are more or less good and correct but the big problem is enforcement in the level of farmers in particular in developing countries. This is a main obstacle and need lots of work, capacity and culture making for farmers in developing countries with ever increasing demand for food toward 2050 with 2 million more people on the planet.

Dear Mr Isingoma,

Thank you for your comments and the positive response to the proposed Fertilizer Code of Conduct, particularly in relation to its function in helping rural people dependant on agriculture. Regarding your comment on formulating quantitative topics on fertilizer applications within the document, the Fertilizer Code itself will not provide recommendations as such. To support governments and institutions to implement the Fertilizer Code, we intend to develop a toolkit of examples, guidelines and other materials to help formulate fertilizer management policies and assist in making decisions for specific fertilizer management practices. Thank you for highlighting this issue.

Dear Prof. Minggang Xu,

Thank you for taking the time to respond to our request for comments on the Fertilizer Code of Conduct. Regarding combining chemical fertilizers with manure to increase fertilizer use efficiency, we had hoped to convey this concept by highlighting and advocating for Integrated Soil Fertility Management (ISFM) practices within the Code. We will certainly look at the current text in the document to ensure that the message is clear. To support governments and institutions to implement the Fertilizer Code, we intend to develop a toolkit of examples, guidelines and other materials to help formulate fertilizer management policies and assist in making decisions for specific fertilizer management practices.

Dear Mr. Chinasa Ikelu,

Thank you for your helpful comments towards improving the Fertilizer Code of Conduct, particularly in addressing the issue of how to use technology to reach rural farmers in hard-to-reach areas. Thank you also for pointing out some areas with repetitions and redundancies, particularly in Section 8. We will certainly consider your comments when we are refining the document.

Dear Mr Edson Cagape,

Indeed, our intention with the Fertilizer Code of Conduct, along with many other initiatives in FAO, is to help preserve the environment and its biodiversity while promoting sustainable agriculture.

And, thank you for your second post highlighting your concern for, and the importance of, the health and safety aspects of fertilizers.

Dear Dr. Adalberto Benavides-Mendoza,

Your positive comments regarding the necessity of a Fertilizer Code of Conduct at this moment are indeed encouraging. Your comments provided within the text of the document will be considered when revising the current draft. Thank you for taking the time to contribute to its development.

Dear Mr. Alejandro Silva,

Your comments on the Fertilizer Code of Conduct are gratefully received.

Regarding the ‘how to do’. Again, we reiterate that we intend to support the Code with a toolkit of good policy and fertilizer management guidelines and examples which will certainly provide more specific guidance to policy makers, the fertilizer industry, advisory services and farmers on ‘how to do’.

Regarding the monitoring aspect, we will certainly take on board your comments as well as those of others to help improve the monitoring chapter of the Code.

Your point about integrating Sections 3 and 4 will also be considered, or alternatively to adjust these two sections so that there is clearer distinctions between the two.

Dear Ms Bak,

Thank you for taking the time to review the Fertilizer Code of Conduct and for your comments regarding the relevance of addressing potential impacts on human rights such as the right to adequate food and health, and that certain groups such as children, pregnant women and consumers could be subject to elevated risks associated with fertilizer use and management. We will certainly consider your comments and refer to the UN Special Procedures to help improve the Fertilizer Code of Conduct where appropriate and apt.

Dear Mr Carl Wahl,

Your comments on how to improve the Fertilizer Code of Conduct are indeed much appreciated, particularly concerning strengthening the point or topic of soil conditions that affect fertilizer applications, e.g. acidity and alkalinity and the use of soil conditioning agents such as lime. This point has also been raised by others and will be considered in the draft revision or addressed accordingly.

In addition, your recommendation to produce a simplified Code specific to iNGOs is also noted.

Dear Ms Audrey Pomier Flobinus,

Thank you for your positive comments regarding the benefits and use of the Fertilizer Code of Conduct and its potential to harmonize agricultural practices regarding the safety of products and fair market for all farmers, as well as in providing reassurance to the world population that agricultural practices are conscious of the environment and human health.

Dear Mr Mykola Miroshnychenko,

Thank you for your specific comments regarding the definition of fertilizer, and on adding an extra article to Section 3.5. Your suggestions will be taken into consideration when revising the draft Fertilizer Code of Conduct.

Dear Dr Deren Chu,

In your capacity as an expert on standards for fertilizer analysis techniques your comments regarding this topic are much appreciated. We will certainly follow your advice and look into the existing ISO standards.

Thank you also for your encouraging words highlighting that in China, multiple government institutions and ministries could benefit from this code as well as the end users, i.e. farmers.

Dear Ms Jaana Kaipainen,

Thank you very much for kindly contributing to improving the Fertilizer Code of Conduct with your specific recommendations and comments within the document, particularly regarding some of the terms and definitions and on other potential sources of contaminants in fertilizer products, namely organic substances, micro- and nanoplastics. These and other suggestions will be certainly be considered in the revision of the Fertilizer Code.

Dear Dr Robert Norton,

Thank you for your affirmation that the Fertilizer Code of Conduct is very important. Indeed, the issue of recycling nutrients and developing circular economies is a big challenge due to the temporal and spatial separation of where and when food is produced and consumed. However, there is an effort in a number of countries and regions to recycle nutrients from urban waste. In agricultural settings, there are also many examples and further opportunities to recycle nutrients at various scales. Therefore, we have included recycling nutrients within the Code along with the use of mineral fertilizers. When we give examples of certain nutrient recycling practices, we do not intend to suggest that they will provide all nutrients and replace mineral fertilizers, but rather that they be used where appropriate. Our intention is to support the advocacy and use of these techniques with technical materials and policy guidelines for assistance in implementation of the Code, and that are based on scientifically sound evidence.

Dear Ms. Madeleine Kaufmann,

Thank you for your contributions on behalf of you and your colleagues at the Federal Office for Agriculture Switzerland. Your inputs and comments will be indeed be helpful for revising the Fertilizer Code of Conduct as well as in providing further comments to the Committee on Agriculture in October when the Code will be presented to FAO member countries.

Online Consultation for review and comments on the zero-draft International Code of Conduct for the Use and Management of Fertilizers

Comments from the International Fertilizer Association (IFA) pertaining to the zero draft, which will be presented to FAO’s Committee on Agriculture at its session in October 2018 

(general comments below and attached, plus specific comments attached)

At IFA, we have always welcomed the idea to have a Code of Conduct for Fertilizers, and we have been very supportive of this project right from the beginning.

We consider this a quite unique opportunity to create a truly relevant and meaningful document not only for our industry but for all key stakeholders that are closely involved with our sector.

But the development of such an extensive and important document cannot be taken lightly: Creating a substantial and impactful document, that provides true guidance, takes time.

While we applaud FAO for its ambition, we believe that the proposed timeline (coming up with a zero draft in 6 weeks, getting it reviewed by the Intergovernmental Technical Panel on Soils (ITPS) and an Open-Ended Working Group within roughly 2 weeks, and coming up with a revised zero draft only a couple of days later for consideration at the Global Soil Partnership (GSP)’s Plenary Assembly in June) does not provide for sufficient consultation, and simply cannot result in a document which provides meaningful guidance and recommendations.

The FAO is renowned for its sound scientific, thorough and reliable work. If this document cannot benefit from more consultations and improvements, the outcome will not only affect the reputation of the FAO, but the code will ultimately not generate the adherence and support that a code is supposed to get from its target audiences.

What is immediately striking are the number of repetitions throughout the whole document, while there are entire areas and topics that would clearly benefit from clearer definitions and clarification.

For example:

• The differentiation of organic and mineral fertilizers would deserve more thoughts; it would be useful to assess and discuss where a stronger distinction within the document would make better sense and where both nutrient sources can be combined within the same paragraph. The draft weights also differently between organic and mineral fertilizers. We would recommend complementarity in assessing benefits and value of both.
• The context of scientific evidence and scientific risk assessments is not fully taken into account, in particular in paragraphs referring to risks and contaminants. In general, the language is very generic and non-specific in paragraphs relating to risks in usage, handling or storage. However, these are areas where a code of conduct has to be very carefully formulated as it is of absolute necessity to all users involved, to understand well these areas.
• As enshrined in WTO rules, a sound basis on scientific risk assessment should underpin any recommendations to governments. The notion of risk management also needs to be enshrined in the code, so as to demonstrate that potential risks can be adequately addressed. For the future relevance of the code, we cannot afford to “brush over” these chapters.
• Some good instruments within governance, initiatives, programs and regulations already exist in relation to fertilizer value chain (production, transport, QC, labelling, trading etc.) For lack of time, these have not been considered enough and deserve to be closer looked at.
• Economic considerations are also widely ignored, whereas this is of major interest and concern not only in regions that must overcome underuse of fertilizers.

The document is still quite unbalanced:

• While the preamble of the document clearly states that its goal is to “maximize benefits and reduce environmental impacts”, the current draft is unbalanced. Benefits and the need to address not only overuse but also underuse are side-lined in favour of an overwhelming strong focus on pollution. We should keep in mind that, worldwide, underuse cases are at least as widespread as overuse ones, and both are equally important from a sustainability standpoint, considering that nutrient underuse contributes to soil degradation and soil erosion.
• “Responsible use” should be defined and not be limited to overuse.

We noticed some gaps:

• We would recommend a stronger focus on crucial areas relating to nutrition, farmers’ livelihoods and adaptation to climate change. These aspects need to be explored more, also for the benefit of policymakers and advisors in developing countries and with a view to align the recommendations of the code with SDG targets and UNFCCC goals and objectives. The Code of Conduct should be anchored within a global framework of Agenda 2030.
• More emphasis could be placed on the farmer as a decision-maker. Farmers have a critical role to play in sustainable fertilizer use. More thoughts should be given to how the industry, governments, research and extension could support this role.

Language needs to be carefully reviewed, as some areas risk to create misunderstanding and confusion:

• Some sections are clearly “cut and pasted” from the Code of Conduct for Pesticides, which was used as starting point for developing the zero-draft (e.g. references to “remediation measures”, “allowable limits” do not apply to fertilizers). The same goes for references to shipping, where pesticides require a completely different handling and management.
• IFA would like to take this opportunity to emphasize that fertilizers and pesticides, besides both being important agricultural inputs, have nothing else in common. Fertilizers are aimed at feeding plants while pesticides are used to kill or control pests and diseases. As such, risks associated with fertilizer use are much lower compared to pesticides. Using the code of conduct for pesticides as a starting point for this code of conduct is inappropriate in our view.
• Certain paragraphs seem to imply that there is a risk inherent to fertilizers itself – independently from the storage, handling and use. As mentioned above, this aspect must be very carefully worded to avoid misinterpretations once the code is published.

Definitions need further review:

• They are not always aligned with already existing FAO definitions that have been approved by member states. Here again, definitions have been drafted too quickly, without the necessary consultation.
• Terminologies relating to slow- and controlled-release fertilizers, for instance, are not accurate. The fertilizer industry can provide assistance with product definitions. The code would clearly benefit from this assistance.

In summary, substantial improvements are still required to make the current draft relevant and ready for adoption. We are of the opinion that the priority should be incorporating specific comments made during the GSP Plenary Assembly in June (by France, Germany, Jordan, Morocco, The Netherlands and IFA) and submit a new draft for consultation to the COAG. It would reflect a transparent, step-wise and constructive negotiation process.

We believe that the speed with which this document had to be pulled together is the main factor for its weaknesses, flaws and gaps. One must bear in mind that fertilizers have a major role to play for the world’s future in terms of food security. 50 % of our food produced today is based on mineral fertilizers. At the same time, nobody denies that mineral and organic nutrients impact the environment and that improved management practices are of major importance.

Given the critical role of fertilizers, IFA would strongly recommend giving appropriate weight to the development of such a significant document: it is ultimately the extend of its content that will decide if this code is truly relevant for nutrient stewardship or if it will be dismissed as superficial and too general.

__________

About IFA

The International Fertilizer Association (IFA) is a trade association representing the global fertilizer industry, which provides the crop nutrients that allow farmers everywhere to meet the world's growing food, feed, fiber and bioenergy needs in a sustainable manner. IFA member companies represent all activities related to the production and distribution of every type of fertilizer, their raw materials and intermediates. IFA’s membership also includes organizations involved in agronomic research and training. IFA has some 501 members in about 68 countries.

I was perusing the code of conduct for the use and management of fertilizers and was surprised that there was no mention of agroforestry and the use of trees and agroforestry systems to help reduce or even replace fertilizer usage. The closest that the code gets to this is perhaps in reference to the use of green manures. I would think that any practice the can be used to improve soil fertility, structure and health while reducing the need for and some of the negative aspects of fertilizer usage would also be included. As you know, the World Agroforestry Centre (ICRAF) has been working in this area for many years, as are others.

Would be useful for farmers to know that in some cases fertilizer usage can be reduced and soil structure and health improved, by using appropriate agroforestry systems. In some cases yields under agroforestry systems can be higher or equal to monocultures, but even if they are not, they should be promoted more widely as part of a climate smart approach that is sustainable, reduces risk and improves biodiversity and resilience.

Simply something for you to consider if nobody else has raised this.

Thanks for your attention.

Dear GSP-Secretariat

Dear Mister Mansur

The Federal Office for Agriculture of Switzerland (FOAG) welcomes the work achieved so far in the zero-draft of the International Code of Conduct for the Use and Management of Fertilizers (CoCoFe), and expresses gratitude for having been given the opportunity to provide feedback on it. We are very pleased to send in attachment our contribution in response to the open second round of e-consultation on the draft V0 of the report.

Please find attached our feedback directly in track in the uploaded document.

Among the comments we made, here a short summary:

• This extensive document covers topics on fertilizer use and management in its entirety. However, the document misses a clear structure, the numeration appears rather random. Is the absence of a table of contents and headings on purpose?
• First Paragraph (last sentence): Addition of soil pollution
• Definition of Fertilizer (Page 4, "What is a fertilizer?"): We would prefer synthetic or mineral fertilizer, rather than chemical and mineral fertilizer. 
• Chapter 7, Point 7.1.6.3: We are of the opinion that if a certain contaminant is present below the respective national limit value, there is no need for declaration of the exact content of this contaminant

We remain at your disposal should you require any further information.

Best regards

Madeleine Kaufmann

Federal Department of Economic Affairs, Education and Research EAER

Federal Office for Agriculture FOAG

International Affairs and Food Security Unit

[email protected]

I have read some of the contributions to the on-line debate as I develop my response to the issues raised in the CoCoFe. Any information that contributes to such an important code must be supported by robust science and not just be opinions and ideas. While the incorporation of recycling nutrients is very important both in an environmental and economic sense, the fact remains that agriculture and food production is essentially still an open system - because production and consumption are temporally and spatially separated. Composting, worms, P reclamation all have a small role in helping develop a circular economy but the fact remains that nutrients will still be needed from mineral fertilizers to sustain production of food for humanity. 

Developing these guidelines is too important to have junk science driving the practices to be recommended.

Thanks for the opportunity to contribute. Please see our comments in the attachment below.

With kind regards,

Jaana Kaipainen

Is an International Code of Conduct for the Use and Management of Fertilizers beneficial and useful? To whom, and why?

A: Yes, the International Code of Conduct for the Use and Management of Fertilizers is beneficial and useful for various stakeholders, including:

1. For governments and policy makers, the code offers a guideline for effectively administrate the fertilizer industry and market via standards, laws and regulations with the spirit of a better use and management of fertilizers in future, and thus assist them in the establishment of systems for monitoring the production, trade, distribution, quality control, management and use of fertilizers on the country level. For Chinese Government, specially, the National Development and Reform Commission and Ministry of Industry and Information Technology is in charge of the policy making and standardization of fertilizer; the State Administration of Market Supervision is in charge of production and marketing activities of fertilizers; the Ministry of Agriculture and Rural Affairs is in charge of the distribution, use and management of fertilizers; the Ministry of Transport is in charge of the transport of fertilizers, they will all be benefit from the International Code of Conduct for the Use and Management of Fertilizers.

2. For fertilizer industry, the code encourages them to provide appropriate products in according with global principles of plant nutrient management such as integrated soil fertility management (ISFM) and 4R nutrient stewardship.

3. For academic & research institutes, agricultural extension & advisory services, the code encourages them to develop and promote new products, techniques and management stewardships based on the principles described in this code.

4. For nutrient recycling industry, the code's emphasizing on the nutrient reuse and recycling (Sec. 5) as well as the concerning of environment protection and sustainable growth globally will bring prosperity on the related field. For Chinese Government, specially, the Ministry of Ecological Environment is in charge of the nutrient recycling and environment protection, and they will be benefit from the International Code of Conduct for the Use and Management of Fertilizers.

5. For end users (farmers included), this code educated them on the effectively use and management of fertilizers by maximize the benefits from utilizing fertilizers while minimizing any negative impacts.

Does this Fertilizer Code of Conduct address all aspects necessary to ensure the responsible use of fertilizers, optimizing benefits while minimizing risks?

A: No; The importance role and engagement of national/international standardization systems in the responsible use of fertilizers, optimizing benefits while minimizing risks is not fully expressed in the code.

Are there any topics or subject matter missing from this Fertilizer Code of Conduct? If so, what are they?

A: Yes; The international standardization committee on fertilizers, such as ISO/TC 134 "Fertilizers, soil conditioners and beneficial substances" , CEN/TC 260 " Fertilizers and liming materials" have deeply engaged in the international fertilizer, soil conditioners and beneficial substances vocabulary\analytical methods\products unification and standardization for nearly 40 years, with more than 40 international standards published and 17 more ongoing, ISO/TC 134 and their national mirror standardization committees has great influence on the effective use and management of fertilizers. The emphasizes of the standardization unit as a individual stakeholders, or as a major representative of policy makers in the responsible use of fertilizers, optimizing benefits while minimizing risks should be mentioned in this International Fertilizer Code of Conduct.

Are there redundancies or unnecessary items or subjects within this Code of Conduct? If so, what are they?

A: No.

Do you have any other suggestions or comments not covered in the above questions? If so, please elaborate.

A: We suggest the editors (FAO and ITPS) to consult with ISO central secretary or ISO/TC 134 "Fertilizers, soil conditioners and beneficial substances" for more details on the engagement and contribution of national/international standardization systems in the responsible use of fertilizers, optimizing benefits while minimizing risks. of the standardization unit as a individual stakeholders, or as a major representative of policy makers in the responsible use of fertilizers, optimizing benefits while minimizing risks should be mentioned in this International Fertilizer Code of Conduct.