New analysis reveals multi-billion-euro potential in recycled phosphorus

Phosphorus is fundamental to the European Union’s food security and is listed by the EU as a Critical Raw Material. Yet Europe remains heavily dependent on imports, including from Russia. Increased recycling could reduce this dependency and open new economic opportunities, according to the analysis.

“The findings suggest that Europe may be overlooking a significant opportunity,” says Magnus Ericsson, co-founder of RMG Consulting, Adjunct Professor at Luleå University of Technology and one of the authors of the report, Societal Benefits of Recycling Phosphorus in the EU. “Relatively limited regulatory changes could unlock substantial investments while supporting Europe’s ambitions on competitiveness, resilience and access to strategic raw materials, and limit European reliance on Russian phosphorus.”

EU dependent on imports 

During the first nine months of 2026, European companies imported phosphate rock worth 170 million euros from Russia. Russia remains the EU’s largest supplier, accounting for 38 per cent of the bloc’s phosphate rock import spending, according to an analysis of European Commission trade data carried out by Ragn-Sells.

“Food security starts with phosphorus,” says Pär Larshans, Chief Sustainability Officer at Ragn-Sells Group. “For a nutrient as essential to our food supply as phosphorus, Europe cannot afford to rely entirely on imports when the technology to recover more phosphorus at home already exists.”

A resource Europe already has 

Every year, large amounts of phosphorus pass through Europe’s wastewater systems. Today, technologies exist that can recover phosphorus from incinerated sewage sludge.

Yet an annex in EU animal feed legislation prevents recycled phosphorus recovered from sewage from entering the feed market. The restriction originates from rules introduced after the BSE crisis (mad cow disease) in the 1990s, when waste-based materials were broadly excluded from feed production.

Since then, technologies capable of recovering high-purity phosphorus from incinerated sewage sludge have been developed and brought to market.

One example is Ash2Phos, developed by Ragn-Sells’ innovation company EasyMining, which is now being deployed at industrial scale in Europe. The resulting product, RevoCaP, is approved for use as a fertiliser in organic farming in the EU. 

A new assessment by Aarhus University found that the recovered phosphorus has characteristics that make it suitable for future use as a phosphorus supplement in animal feed, while a 2023 assessment by the Swedish National Veterinary Institute (SVA) found a negligible probability of infectious animal pathogens.

“Recovered resources should be assessed based on their quality and safety, not their origin. EU rules should not prevent high-quality recycled phosphorus from being used in animal feed simply because it originates from wastewater. That needs to change,” says Pär Larshans.

What the report found 

The new report by RMG Consulting examines the potential effects of allowing recycled phosphorus recovered from sewage sludge ash to enter the European feed market. According to the analysis, removing current regulatory barriers could unlock more than EUR 9 billion in investments and create more than 7,400 jobs across the EU and the UK. 

The report also identifies wider potential benefits, including increased resource resilience, reduced dependence on Russian phosphate imports and support for Europe’s agricultural and food industries.

“Recovering phosphorus from sewage sludge ash could strengthen resource security, support industrial investment and contribute to a more resilient food system. One of the main barriers identified is regulatory rather than technical,” says Magnus Ericsson. 

Why this matters for the EU  

The analysis comes at a time when the European Union is seeking to strengthen competitiveness, resilience and access to strategic raw materials. The European Commission’s Fertiliser Action Plan recently highlighted nutrient recycling as a tool for strengthening food security and resource resilience. Sweden has also urged the EU Commission to request a new risk assessment from the European Food Safety Authority (EFSA) as a step towards revising the feed legislation. 

“At a time when food supply chains are becoming more uncertain, the EU’s dependence on imported phosphate should be a wake-up call for policymakers. By simply updating an annex in the feed legislation, the EU could unlock significant investment, strengthen its competitiveness and reduce its dependency on Russia,” says Jonas Hagman, CEO of EasyMining. 

The report was commissioned by Ragn-Sells and produced by RMG Consulting. Read the full report here. 

Key findings from the report 

According to the report, large-scale phosphorus recovery from sewage sludge ash in the EU, Norway and the UK could generate: 

• More than 9 billion euros in new investments.
• More than 7,400 new jobs across the value chain.
• More than 850 million euros in annual revenues.
• Reduced dependence on imported phosphorus by making better use of resources already available within Europe.
• Increased food security and supply resilience.
• Environmental and public health benefits through improved phosphorus management.

Source: “Societal benefits of recycling phosphorus in the EU”, report by RMG Consulting 

What needs to change? 

The report Societal Benefits of Recycling Phosphorus in the EU concludes that regulatory barriers are limiting Europe’s ability to make use of recycled phosphorus. Based on the report’s findings, Ragn-Sells proposes the following changes to EU legislation: 

1. Revise Annex III of the Feed Regulation. Remove the ban on phosphorus recovered from incinerated sewage sludge ash in animal feed, in line with the proposal submitted by the Swedish government. A new EFSA risk assessment should be initiated as a basis for reviewing the current restrictions. 
2. Classify phosphorus as a strategic resource. Today, phosphorus is classified as a Critical Raw Material, but not as a Strategic Raw Material under the Critical Raw Materials Act, despite its essential role in food production. High-quality recycled phosphorus should be recognised as a strategic resource for Europe’s resilience and food security. 
3. Assess resources by quality, not origin. Recovered resources should be assessed according to their quality, safety and performance – not solely according to where they come from. This principle should guide the EU’s work on the Circular Economy Act. 
4. Set ambitious requirements for phosphorus recovery. Establish ambitious requirements for phosphorus recovery from wastewater treatment plants under the Urban Wastewater Treatment Directive, drawing on experience from countries such as Germany and Austria.
5. Enable the recycling of nutrients from fish sludge. Aquaculture releases significant quantities of nutrients, including phosphorus, that today are largely lost to the environment. New technologies make it possible to capture and recycle these nutrients, but regulatory barriers continue to prevent their use. The EU should establish a clear definition of fish sludge and create a regulatory pathway for its use in fertilisers, feed, and other circular applications.