Pyrolysis material — commonly referred to as biochar — is a stable, carbon-rich product derived from the thermal decomposition of plant biomass and/or food-grade animal bones in the absence of oxygen. It is legally recognized in the EU as a chemically modified substance, and may serve as:
- a solid organic fertilizer,
- a solid organo-mineral fertilizer, and/or
- an organic soil improver.
Depending on the input feedstock, pyrolysis materials may be classified as either UVCB substances (Unknown or Variable Composition, Complex Reaction Products or Biological Materials) or well-defined mono-/multiconstituent substances under the REACH Regulation.
All biochar/pyrolysis materials placed on the EU market must meet the following core requirements:
- Mandatory EU and Member State authorisations for import, manufacturing, marketing, and application above 1 tonne/year.
- REACH registration (according to Regulation EC 1907/2006). REACH+ requirement of FPR applies for substances to be used in EU fertilising products even below one tonne.
- Proper labelling and safe handling throughout the value chain, ensuring product traceability and compliance with extended producer responsibility (EPR) obligations.
- Sustainable sourcing of input materials, ensuring no competition with human food, animal feed, or essential plant nutrients, and no land-use conflicts.
- Alignment with EU Circular Economy objectives, including waste valorisation and reduced environmental footprint.
Legal and Functional Criteria
A safe biochar/pyrolysis material must fully meet the following four criteria:
- Functional Use: It is commonly used for specific agricultural or environmental purposes, such as an organic fertilizer or soil amendment.
- Market Demand: There is demonstrated market demand for the safe use of biochar.
- Legal Compliance: It fulfills all relevant legal, technical, and quality standards applicable to its specific application.
- No Adverse Effects: Its use must not result in negative environmental or human health impacts.
Material-Specific Applications
- ABC Animal Bone Char Bio-Phosphate:
A high-mineral-content pyrolysis material made from food-grade animal bones. It functions as a recovered organic phosphorus (P) and calcium (Ca) fertilizer, typically applied at rates of 100–600 kg/ha. It is widely used in horticultural growing media and specialty crop systems. - Plant-Based Biochar:
A high-carbon-content material derived from plant biomass, primarily used as a soil improver. It is applied at rates between 5,000–20,000 kg/ha for its water and nutrient retention properties and carbon sequestration benefits. However, it does not provide significant macronutrient (NPK) content of agronomic value.
Both types of pyrolysis material may offer additional co-benefits, such as:
- improved soil structure,
- reduced greenhouse gas emissions,
- increased microbial biodiversity,
- and enhanced long-term soil carbon storage.
Legal Notice
Soil application of biochar/pyrolysis materials is irreversible. Therefore, all actors in the value chain — including producers, importers, distributors, and end-users — bear joint and several liability for compliance and responsible use. In addition to the mandatory EU and national permits, operators must observe the precautionary and preventive principles in line with international, EU, and Member State legal frameworks.