Skip to content
RecyFert

EU Fertilising Products Regulation 2019/1009

Your regulatory team stays lean. Your dossiers stay audit-ready.

We take the dossier workload off your team. We build and finalise Module A, Module B and Module D.1 dossiers on the Gilbert FPR software, keep them for you with our archiving option, and send them to an auditor or surveillance authority within 24 hours.

Book a callSee fixed prices
24 h
to deliver an archived dossier to an auditor or authority
5 yr
archiving of your dossier
27 states
documents in the language each Member State requires
2
revisions in every setup fee

How it works

We work in the Gilbert FPR app. You see everything.

RecyFert Consulting Services is a regulatory advisory firm. Gilbert RegTech builds the FPR software we use. The two are related companies and we say so up front.

  1. Step 1

    A 30-minute scoping call

    We confirm your module, your products and what data you already hold. You get a fixed price after the call.

  2. Step 2

    You send your product data

    Formulation, ingredient specifications, lab reports, supplier certificates and safety data sheets.

  3. Step 3

    We build and finalise the dossier

    We enter the information, check it against the regulation and close the gaps with you. Two revisions are included.

  4. Step 4

    You review, then the auditor does

    You get viewing rights to your dossier at all times. Your file is ready for the notified body or the surveillance authority.

Book your scoping call

Fixed prices

Choose who holds the software licence.

Prices are per dossier, in euro, excluding VAT, and include two revisions. Each further revision is quoted separately.

Notified body fees are not included. Prices for Module B and Module D.1 exclude the fees of the notified body, which you pay to the notified body directly.

We work in our licence. You get viewing rights.

RecyFert pays for the FPR app and adds all information to the system. You look in, comment and approve.

  • No software to buy or maintain
  • Viewing rights to your own dossier
  • You can move to your own licence later

  1. Months 0 to 6

    Full access to your dossier in the Gilbert FPR app. Generate the EU declaration of conformity (DoC) and the technical documentation (TD) in different languages.

  2. After 6 months: choose archiving

    € 100 per dossier per year. Generating the DoC and TD stays available to you.

  3. No archiving: access closes

    If you need access later, it is treated as a new dossier.

Paid once
Dossier setupFee
Module AInternal production control. Includes 2 revisions.€ 600per dossier
Module B, followed by Module CEU-type examination and conformity to type. Includes 2 revisions.€ 1,000per dossier
Module D.1Production process quality assurance. Includes 2 revisions.€ 1,800per dossier
QMS documentation setupModule D.1 onlyRecyFert writes and sets up the QMS documentation system. Includes 12 months of the QMS software licence. One price per company, regardless of the number of products.€ 9,500per company

You buy the app. We build the dossier.

You buy your licence directly from Gilbert RegTech. RecyFert gets edit rights in your system. You keep the freedom to work in it yourself and you keep the system up to date.

  • Your licence, your data, your system
  • RecyFert builds the dossier inside it
  • Take over editing whenever you want
  • Archiving is included in your Gilbert licence
Paid once
Dossier setup by RecyFertFee
Module AIncludes 2 revisions.€ 300per dossier
Module B, followed by Module CIncludes 2 revisions.€ 700per dossier
Module D.1Includes 2 revisions.€ 1,500per dossier
QMS documentation setupModule D.1 onlyRecyFert writes and sets up the QMS documentation system. Needs the QMS licence below. One price per company, regardless of the number of products.€ 8,000per company

You pay Gilbert RegTech directly

Dossier licence, per dossier per month
€ 50
QMS licence Module D.1 only, per company per month. RecyFert needs it for the QMS documentation setup
€ 250

Optional services, done by RecyFert

You do not need to build this capacity in house. Our team does the work.

One-off options

Paid once
  • On-premises audit preparation€ 4,500

    For 1 production site + travel costs. For Module D.1. RecyFert:

    • prepares your site and your team for the audit;
    • attends the audit with you;
    • handles the initial correspondence with the notified body.

    Additional production sites: ask us for a price.

Recurring options

Paid every year
  • Archiving€ 100 per dossier per year
    RecyFert keeps a copy of your dossier for the 5 years the regulation requires after your product is placed on the market, and supplies it to an auditor or surveillance authority within 24 hours. You can keep generating the DoC and TD in different languages.
  • Quality records logging€ 300 per dossier per year
    Module D.1 requires quality records. RecyFert logs and keeps them for you.
  • Annual internal audit€ 3,000 per year
    For 1 production site + travel costs. RecyFert carries out the yearly internal audit of your quality system and attends the notified body's audit by conference call. In-person attendance and additional production sites: ask us for a price.
  • QMS software licence€ 3,600 per company per year from month 13
    The first 12 months are included in the QMS documentation setup. From month 13, RecyFert keeps your QMS system active in the Gilbert FPR app. One price per company, regardless of the number of products.
Book a call about your dossier

All prices are in euro and exclude VAT. Prices for Module B and Module D.1 exclude the fees of the notified body, which you pay to the notified body directly.

Conformity modules

Which module is yours?

The regulation gives each product a route to CE marking, called a module. The route depends on what your product is made of. Every ingredient falls into a legal category, a CMC (component material category). We confirm your module with you before we quote.

Module A

You check your own product

You build the technical dossier and declare conformity yourself. No notified body reviews it before you sell. Authorities can ask to see it afterwards.

Module A is available only when the product is made entirely from these ingredient categories:

  • virgin substances and mixtures, but not inhibitors of nitrification, denitrification or urease (CMC 1)
  • fresh crop digestate (CMC 4)
  • food industry by-products (CMC 6)
  • nutrient polymers (CMC 8)
  • industrial by-products as defined in the EU Waste Framework Directive (CMC 11)

Blends of such products are also allowed.

Module A cannot be used for plant biostimulants, inhibitors or high-nitrogen ammonium nitrate fertilisers.

Module B + C

A notified body checks the product type

An independent notified body examines a sample of your product and your technical dossier, and issues a certificate. After that, you keep production in line with the certified type (Module C).

Module B + C is available for products that contain:

  • inhibitors of nitrification, denitrification or urease (CMC 1)
  • plants, plant parts or plant extracts (CMC 2)
  • food industry by-products (CMC 6)
  • micro-organisms (CMC 7)
  • polymers other than nutrient polymers (CMC 9)
  • products derived from animal by-products (CMC 10)

Product types that cannot use Module A, such as inhibitors (PFC 5) and plant biostimulants (PFC 6), can use Module B + C.

Module D.1

A notified body checks your quality system

The notified body audits your production site and your quality management system, then keeps auditing it. You keep quality records and run an internal audit every year.

Use it for any product, including inhibitors (PFC 5) and plant biostimulants (PFC 6). It is the only route when the product contains:

  • compost (CMC 3)
  • digestate other than fresh crop digestate (CMC 5)
  • recovered phosphate salts, thermal oxidation materials, pyrolysis and gasification materials or recovered high purity materials (CMC 12 to 15)

Not possible for high-nitrogen ammonium nitrate fertilisers, or blends containing 28% or more nitrogen from them.

Those products follow Module A1, which we do not cover.

Source: Reg. (EU) 2019/1009, Annex IV, Part I (consolidated version of 01.07.2026) and Annex II for the CMC names.

Not sure which module? Book a callRead the module guide

Audit readiness

The auditor asks. An archived dossier reaches them within 24 hours.

We keep your dossier current and complete. We do not promise a result, because the notified body decides. We promise the file is ready to be assessed. Notified bodies we currently work with: Certrust and EFCI.

Delivery to auditors
Within 24 hours, for archived dossiers
Retention
5 years archiving
Languages
As each Member State requires
Your access
Viewing rights, always
Get your dossier audit-readyAudit readiness checklist

Who is behind it

RecyFert Consulting Services B.V. advises on EU fertiliser regulation. Our founder has 20 years of specialty fertiliser experience and takes part in the European Commission expert group on fertilising products.

Related companies

The FPR software is built and sold by Gilbert RegTech B.V. Our founder is a co-founder of Gilbert. If you buy your own access you contract with Gilbert directly, and you can ask us any question about that arrangement.

Talk to us

Frequently asked questions

Questions we hear most.

What does RecyFert do?

RecyFert builds and finalises EU FPR dossiers (Module A, Module B followed by C and Module D.1) in the Gilbert FPR software and keeps them ready for notified body and government surveillance audits. The economic operator stays responsible for the product, its technical documentation and its EU declaration of conformity.

Read more: What does RecyFert do?

Which conformity assessment module do I need?

It depends on the component material categories (CMCs) in your product and its product function category (PFC), as set out in Annex IV, Part I of Regulation (EU) 2019/1009. Module A is for simple materials, Module B followed by C widens that to inhibitors, plants, micro-organisms, polymers and derived products, and Module D.1 can be used for any product except high-nitrogen ammonium nitrate fertilisers.

Read more: Which conformity assessment module do I need?

How much does an FPR dossier cost?

On the RecyFert licence: Module A € 600, Module B followed by C € 1,000 and Module D.1 € 1,800 per dossier. With your own Gilbert licence: Module A € 300, Module B followed by C € 700 and Module D.1 € 1,500 per dossier, plus the Gilbert licence of € 50 per month per dossier. Prices are in euro, exclude VAT and exclude notified body fees. Each price includes 2 revisions.

Read more: How much does an FPR dossier cost?

Who is responsible for the dossier?

The manufacturer or other economic operator. By drawing up the EU declaration of conformity, the manufacturer assumes responsibility for compliance (Article 16(4)). RecyFert prepares and archives. Conformity decisions rest with the notified body or the competent authority.

Read more: Who is responsible for the dossier?

How long must the dossier be kept?

The regulation requires the technical documentation and the EU declaration of conformity to be kept for 5 years after the product is placed on the market (Article 6(3)). RecyFert's archiving option costs € 100 per dossier per year and includes delivery to an auditor or authority within 24 hours.

Read more: How long must the dossier be kept?

What happens to my dossier after 6 months?

On the RecyFert licence you have full access for 6 months and can generate the EU declaration of conformity and the technical documentation in different languages. After that you choose archiving, or access closes. If you need access later, it is treated as a new dossier.

Read more: What happens to my dossier after 6 months?

Are notified body fees included?

No. Prices for Module B and Module D.1 exclude the fees of the notified body, which you pay to the notified body directly. RecyFert's on-premises audit preparation helps you get ready for the audit, attends it with you and handles the initial correspondence.

Read more: Are notified body fees included?

Can I edit the dossier myself?

Yes, on the second route. You buy your own access to the Gilbert FPR software and give RecyFert edit rights. You can take over editing whenever you want, and archiving is included in your Gilbert licence.

Read more: Can I edit the dossier myself?

In which languages can you deliver documents?

The EU declaration of conformity must be translated into the language or languages required by each Member State where the product is placed on the market. RecyFert can deliver documents for all 27 EU Member States.

Read more: In which languages can you deliver documents?

Do you cover Module A1?

No. Module A1 is used for high-nitrogen ammonium nitrate fertilisers and certain blends containing them. RecyFert covers Module A, Module B followed by C and Module D.1.

Read more: Do you cover Module A1?
Book a callBrowse the knowledge base

Book a call

Tell us what you place on the market.

We reply with two time slots for a 30-minute scoping call. After the call you receive a fixed quote and a payment link.

Our general terms and conditions apply.

Prefer to pick a time yourself? Book a 30-minute call in our calendar
Module
Licence option

We use these details only to arrange your call and quote. See the privacy notice.