Am I Allowed To Import and Use This Biostimulant in Finland?

Imagine this: You are a future-oriented Finnish farmer, learning about regenerative farming practices. You're interested in testing for yourself some of the products you've heard the likes of John Kempf and Graeme Sait talk about – something a bit different from what the big agrochemical industry is marketing to you as biostimulants.

So let's say you want to test a microbial biostimulant from abroad that contains some other live microbes in addition to or instead of Azotobacter, Rhizobium, Azospirillum or arbuscular mycorrhizal fungi. A product like this is clearly not eligible for CE-mark under the EU Fertilising Products Regulation. Can you still import and use these products on your own farm?

Short, but inconclusive answer

Yes, it is possible for a Finnish farmer to buy and use on their own fields a microbial biostimulant that does not meet the EU FPR CE-mark criteria (e.g. contains other microbes than the four listed in CMC 7), provided that the product complies with Finnish national fertiliser legislation (711/2022 & 964/2023) and any other applicable rules (plant protection, ABP, GMO, plant health, etc.).

The key is that compliance is checked against Finnish law, not just FPR, when the product is non-CE and used only in Finland.

Relevant points to consider

1. CE-mark is not mandatory.

   • Since CE-marking is optional, the lack of CE mark, or failure to meet CMC7, does not in itself prohibit use in Finland.

2. The product must comply with Finnish fertiliser/biostimulant rules.

   • As an own-use importer, the farmer is treated as a “talouden toimija” (economic operator) for that product. They must ensure that the biostimulant:

     • Fits the national “biostimulant” product class, and

     • Is composed only of ingredients that fit an allowed ingredient category (including microbial ingredients) and meet contaminant/pathogen limits, etc.

3. Plant protection vs fertiliser: claims and function matter.

   • If the product (or its marketing) claims to control diseases, pests or weeds, or otherwise has a plant protection mode of action, it may fall under plant protection product legislation instead of fertiliser rules (Reg. 1107/2009, Tukes as authority).

   • Importing and using an unapproved plant protection product would be illegal, even for own use.

4. Other special regimes may bite depending on the microbe:

   • Animal by-products included in the formulation → additional ABP and border inspection rules apply; own-use derogation does not remove those obligations.

   • Quarantine / harmful organisms, GMOs, invasive species included → separate EU & Finnish rules (plant health, GMO legislation) that could prohibit import or use of certain microbes regardless of fertiliser law.

Practical checklist for a farmer in this situation

If you’re evaluating such a product, a cautious approach would be:

1. Clarify what the product legally is:

   • Is it marketed as a fertiliser/biostimulant in the exporting country, or as a plant protection product?

   • What claims are on the label (nutrient efficiency / stress tolerance vs disease/pest control)?

2. Ask the supplier for documentation:

   • Full composition (including microbial strains and concentrations).

   • Latest analysis for heavy metals, pathogens etc.

   • Any safety assessment or classification they have for use as fertiliser/biostimulant.

3. Compare against Finnish requirements:

   • Check that the product fits a national product class (biostimulant) and that its ingredients match the allowed ingredient categories (“ainesosaluokat”).

4. When in doubt, ask the authorities:

   • Ruokavirasto (fertiliser products) – for whether a given microbial ingredient or product type is acceptable as a national biostimulant.

   • Tukes – if there’s any chance the product might be seen as a plant protection product.