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Samenvatting

Nitrogen (N) use in EU countries is regulated by so-called Action Programmes (APs) set by member states in response to the EU Nitrates Directive (ND). APs apply specifically to 'Nitrate Vulnerable Zones' (NVZs) within countries. More generally, the ND asks countries to define a Code of Good Agricultural Practice (GAP), outlining for their entire national territory what is considered responsible management of manures and fertilisers. This paper compares regulations on N use as precipitated in the APs (applicable in 2009) of Belgium (Flanders, FL), Denmark (DK), Germany (GE), France (FR) and The Netherlands (NL). For some countries, the AP includes maximum allowable N rates. Such statutory limits are called N application standards (NASs). NASs were derived from N fertiliser recommendations. Other elements addressed are 'closed periods' for animal manures; and the N fertiliser value (NFV) of manures, representing an equivalent amount of fertiliser-N relative to manure-N. Together, these elements (NASs, closed periods, and NFVs) constitute the core of rules and regulations. FL, DK, GE, and NL have designated their entire territories as NVZ and so their APs apply throughout. Limits to N use differ considerably between respective APs, both in definition and values. DK and NL have fixed, crop specific NASs regulating the sum of N in manures and fertilisers. NASs in FL are specified for total-N and fertiliser-N separately, and apply to crop groups. The German system is based on GAP and holds no NASs. It applies to all states. Nitrogen surplus on arable farms in GE, however, should not exceed 90 (2008) and 60 kg N per ha (2011). Legislation in FR does not hold limits on N input in general, nor in NVZs. Only in zones where the groundwater or surface water is used for drinking water - while nitrate concentration is high - is total N input (manures + mineral fertilisers) limited to 140-210 kg N per ha. Some regions (FL; Baden-W├╝rttemberg in GE) have separate limits for inorganic soil mineral N allowed in the autumn. NL, FL, DK, and GE have derogations for animal manures, allowing maximum rates between 200 and 250 kg N per ha. All derogations except for FL refer to grassland-dominated farms only.