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Fertiliser Law

Storing, moving and documenting organic manure

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With organic manure, most people think of spreading first. But the duties start much earlier and end much later: the material has to sit somewhere until it may be spread, it often changes hands between farms, and the tank it sits in is legally an installation with rules of its own. That produces three separate records that are easily mistaken for one – and whoever only keeps one of them gets caught out on the other two.

This article describes the legal position in Germany – the Fertilization Ordinance (DüV) and the Fertilization Act (DüngG), plus the Ordinance on Installations for the Handling of Substances Hazardous to Water (AwSV) and additional state-level law. Other countries have their own regulations.

Three duties on a single material

Slurry, solid manure, liquid manure and digestate are all subject to three sets of rules at once, each asking a different question. Fertiliser law asks whether you have enough storage space, so that you're never forced to spread at the wrong time. It also asks where the material goes, or where it came from, the moment it changes farms. And water law asks whether the tank is leak-proof and being monitored.

The three questions have different audiences. Storage capacity is of interest to the agricultural authority, the transfer concerns sender and recipient jointly, and installation safety falls under the water authority. No single document can cover all of that, and an inspection usually checks only one of the three trails at a time – but it checks that one thoroughly.

  • Storage: demonstrably sufficient capacity for the material produced and received
  • Transfers: matching records on both sides, with holding numbers and nutrient load
  • Installation: leak-tightness, recurring inspection and in-house inspection of the tank

Why storage capacity is a question of proof

Storage space is either built or it isn't – that's how the farm sees it. The authority sees it differently: it asks about the usable capacity, and that is smaller than the built volume. Freeboard, residual quantities that can't be technically pumped out, and the share added by rainfall are all deducted. Handing over the construction drawing hasn't answered the question yet.

Then there's composition: solid and liquid organic manure are assessed separately, and material received from elsewhere counts too. A farm that regularly takes on digestate from a biogas plant needs capacity for quantities it never produced itself.

In practice that means: capacity belongs on record as a figure, per storage site, with type and physical state – not as a rule of thumb in the farm manager's head. Kept that way, you can answer a query in the same minute it's asked.

Who records what in a transfer

Whenever organic manure leaves the farm or arrives on it, a record-keeping duty is triggered – on both sides. The sending farm records what it handed over, the receiving farm what it took in. This is exactly where things break down most often in practice: one side has the paperwork, the other is counting on it turning up eventually.

At the core of the record are the holding numbers of both parties. A name isn't enough, because the authority has to be able to cross-check the two records against each other. That also means date, type of material, quantity and the nutrients it contains – nitrogen and phosphate are the whole reason the transfer gets recorded in the first place. Anyone delivering across a state border has additional reporting channels to observe.

  • Date of the transfer, and its direction
  • Holding number and name of origin and destination
  • Type of material, quantity with unit, nitrogen and phosphate content
  • Carrier and document number, so the transfer stays traceable

Designated zones change what you have to prove

If a field lies in a nitrate-vulnerable zone, extra requirements apply – including for material that's received. The zone map isn't set by the federal government but by the individual Bundesland, and it gets updated. A field can be affected in one farming year and not the next.

For the record, that means two things. First, the classification isn't a permanent state but a dated figure – anyone documenting it should note which official data set they relied on. Second, the neighbour's word is worthless: what counts is your own Bundesland's map for the current farming year.

The installation is a duty of its own

A slurry tank is legally an installation for handling substances hazardous to water. That makes it subject to a separate set of rules that has nothing to do with fertiliser law: it has to be leak-proof, it gets inspected at recurring intervals by a qualified expert, and the farm itself checks it regularly. Work on such installations is reserved for certified specialist companies.

How strict the requirements are doesn't depend on the tank alone, but on its location. More applies in a water protection area or a flood zone than elsewhere, and the water hazard class of the stored substance shifts the threshold further still.

The in-house inspection is the part that's easiest to let slip – it costs little time, but only produces evidence if it's written down. A date remembered in someone's head is not a record.

Where it actually falls apart at inspection

It's noticeably rare for a wrong quantity to be the cause. It's the missing other side of a transfer, a capacity figure nobody can derive, and an in-house inspection that happened but isn't written down anywhere. All three are gaps in the documentation, not technical mistakes – and none of the three can be fixed after the fact.

The most effective step is therefore unspectacular: record every event where it happens, with the same details the other side is keeping too. Then the paperwork is already done by the time anyone wants to see it.

In short

Organic manure produces three separate records – sufficient, demonstrable storage capacity; matching records of every transfer with holding numbers and nutrient load; and the inspection plus in-house inspection of the tank as an installation. Deadlines, quantities and inspection intervals are set out in the linked sources and in your Bundesland's own law.

What FarmManager takes off your hands

Storage sites are kept on record with type, physical state, usable capacity including unit, and location. That puts capacity on file as a documented figure, not as an estimate that would first have to be worked out in conversation with the authority.

Every transfer, in either direction, is logged as a movement: direction, type of material, quantity, nitrogen and phosphate load, holding number and name of origin and destination, carrier, document number, and whether the delivery crosses a state border. Reporting status is attached to the event itself, not to a separate list next to it.

Installations handling substances hazardous to water are tracked in their own right – with water hazard class, design, leak detection, location in a water protection or flood zone, the responsible qualified expert and certified specialist company, and the intervals for inspection and in-house inspection that produce the next due date.

The zone map enters the system as an official data set per Bundesland, with version and legal status. That makes it traceable which version a classification relies on – and visible when it's due for renewal.

Sources to verify

  • Fertilization Ordinance (DüV), full text

    The binding federal text. This is where the requirements for storage capacity and the recording of transfers are set out, along with the quantities and deadlines this article deliberately doesn't name.

  • Fertilization Act (DüngG)

    The enabling statute behind the ordinance – and the place where the Länder are tasked with designating nitrate-vulnerable zones. The zone map for your fields is published by your Bundesland's authority.

  • Ordinance on Installations for Substances Hazardous to Water (AwSV)

    Governs installations for handling substances hazardous to water, including slurry tanks and silage effluent. Inspection intervals, the duties of qualified experts and the role of certified specialist companies are set out there.

These articles explain how a duty is built and what information it requires. They deliberately name no deadlines, thresholds or dates, because those change and differ by Bundesland. For the binding, current state, we link the responsible source at the end of every article. This is not legal advice.