Material flow balance enables polluter-pays fertilisation

24. Juni 2025

Several environmental associations, ver.di and the BDEW criticise the abolition of the material flow balance in a fast-track procedure.

The Ministry of Agriculture, Food and Rural Affairs plans to repeal the regulation on the preparation of a material flow balance in a fast-track procedure. The BDEW, several environmental associations and ver.di criticise this step backwards in the monitoring of nitrate pollution. This is to be done without the approval of the Bundesrat and Bundestag – and thus bypassing the Fertiliser Act, which requires approval. In addition, the planned abolition of the material flow balance will cause more bureaucracy. The EU’s mandatory monitoring regulation requires a solid, reliable and robust database. However, this is lacking without the documentation of operational nutrient flows in accordance with material flow accounting.

Water management and environmental associations are calling for a fertiliser policy that is fair to the polluter and protects water resources. Individual farm nutrient accounting must be digitised and made accessible to the authorities. This will enable it to be used to reduce bureaucracy. There is a risk that the watering down of fertiliser legislation will lead to an increase in nitrate inputs in many regions. As the material flow balance regulation has only been in force in its current form since 2023, its abolition in 2025 would massively impair planning security for both agriculture and water management.

The undersigned associations therefore call on the Federal Government to:

1. Respect the obligation to prepare a nutrient balance sheet as enshrined in the Fertiliser Act and refrain from abolishing it.
2. Take into account the requirement for approval and coordinate amendment processes with the Federal Council and the Federal Parliament, as well as with associations and affected parties, within a reasonable time frame.
3. Implement individual, nationally uniform nutrient balancing in fertiliser policy in order to enable polluter pays.
4. Applying the ‘once-only’ principle to data collection would significantly simplify bureaucracy, reduce reporting requirements, save resources, improve data quality and optimise the efficiency of administration.

Responsible persons in the associations:
Jutta Sundermann – aktion agrar – co-founder
Martin Weyand – BDEW – Chief Executive Officer Water/Wastewater
Patrick Müller – BUND – Agricultural Policy Officer
Björn Pasemann – DNR – Nature Conservation and Agricultural Policy Officer
Sascha Müller-Kraenner – DUH – Federal Managing Director
Cäcilia von Hagenow – NABU – Agricultural Policy and Rural Areas Officer
Clivia Conrad – ver.di – Head of Federal Water Management Specialist Group