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Law Update
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The Ministry of Agriculture and Farmers Welfare has issued S.O. 5105(E), dated 17 September 2026, laying down specifications for Phosphogypsum (Granular) manufactured for commercial trials.
The Order has been issued by the Department of Agriculture and Farmers Welfare under clause 20A of the Fertiliser (Inorganic, Organic or Mixed) (Control) Order, 1985. It provides exact limits for moisture, sodium, particle size, sulphur, calcium sulphate dihydrate, fluoride and certain heavy metals.
The most important point for manufacturers is that this is not framed as an open-ended or permanent specification. The Order says that the notified specifications will apply for commercial trials for three years from the date of publication in the Official Gazette.
For businesses planning to manufacture or commercially test Phosphogypsum (Granular), the immediate requirement is to understand the technical values correctly, and check whether their material can consistently meet them.
| Particular | Details |
| Issuing authority | Ministry of Agriculture and Farmers Welfare |
| Department | Department of Agriculture and Farmers Welfare |
| Document type | Order |
| Order number | S.O. 5105(E) |
| Date | 17 September 2026 |
| Legal basis | Clause 20A of Fertiliser (Inorganic, Organic or Mixed) (Control) Order, 1985 |
| Product covered | Phosphogypsum (Granular) |
| Purpose | Commercial trials |
| Trial period | Three years from Gazette publication |
| Covered activity | Manufacturing of Phosphogypsum (Granular) for commercial trials |
| Main requirements | Chemical composition, moisture, particle size, fluoride and heavy metal limits |
| Application procedure | Not expressly specified in this Order |
| Fees | Not expressly specified |
| Testing frequency | Not expressly specified |
| Position after three years | Not expressly specified |
The Order is short, but the technical specifications are precise. That means manufacturers cannot rely on a broad product description alone. The actual composition and physical properties of the material matter.
Phosphogypsum is a gypsum-based material associated with the production of phosphoric acid. The present notification, however, is not about Phosphogypsum in every form.
It specifically deals with Phosphogypsum (Granular).
That distinction matters because the notification does not only prescribe chemical limits. It also sets a physical particle-size requirement. In other words, the material must meet both its composition criteria and the notified granule-size condition.
For a manufacturer, this means the product cannot be assessed only on the basis of sulphur or calcium sulphate content. Moisture, sodium, fluoride, heavy metals and particle size also need attention.
The Government has formally notified a technical specification for Phosphogypsum (Granular) when it is manufactured for commercial trials.
The Order does not create a long application procedure in its own text. Instead, it tells manufacturers what the product must look like from a technical point of view.
The notified areas include:
This gives manufacturers a clear technical benchmark for commercial-trial material.
At the same time, businesses should avoid describing this Order as a permanent product approval. The three-year commercial-trial wording is central to the notification.
S.O. 5105(E) has been issued under clause 20A of the Fertiliser (Inorganic, Organic or Mixed) (Control) Order, 1985.
For this notification, the legal function is straightforward: the Government has prescribed specifications for Phosphogypsum (Granular) for a limited commercial-trial period.
This Order should not be read as a complete replacement for the wider Fertiliser Control Order framework.
A manufacturer may still need to examine other requirements that apply to its unit, manufacturing activity, sale, distribution, quality control or other regulated functions under the wider law.
The safer compliance approach is to separate the two questions:
What does S.O. 5105(E) tell the manufacturer?
It tells the manufacturer what technical specifications the Phosphogypsum (Granular) should meet for the notified commercial trials.
What may need to be checked separately?
Any wider FCO requirement relating to manufacturing, licensing, authorisation, sale, testing, inspection or other compliance matters should be checked independently.
This distinction helps avoid a common compliance mistake: assuming that one short product notification contains the full regulatory route.
The notification is product-specific and activity-specific.
| Category | Covered Position |
| Phosphogypsum (Granular) | Covered |
| Manufacturing for commercial trial | Covered |
| Manufacturing unit producing the notified product | Covered |
| Other gypsum products | Not expressly covered by this Order |
| Other fertiliser products | Not covered by this product-specific notification |
| Permanent manufacture after the trial period | Not expressly dealt with |
| Separate licence or approval requirements | Need to be checked under the wider applicable framework |
The Gazette states that the notified specifications apply to Phosphogypsum (Granular) âto be manufactured by any manufacturing unitâ for conducting commercial trials.
The expression âany manufacturing unitâ should not be interpreted as a blanket exemption from other legal requirements. It indicates that the notified specification is not restricted to one named unit.
The wording of the notification is broad enough to refer to any manufacturing unit producing the product for the commercial trials covered by the Order.
However, the notification does not say that a manufacturing unit can ignore other applicable FCO requirements.
A business should therefore look at this Order as the technical specification document, not as an automatic licence or general manufacturing permission.
Before starting commercial activity, manufacturers should check two things separately:
This is where a fertiliser compliance consultant or specialised fertiliser compliance services can be useful, particularly where a business is unsure whether the notification alone is sufficient for its proposed activity.
The commercial-trial period is one of the clearest features of the notification.
| Item | Position |
| Trial period | Three years |
| Starting point | Date of publication in Official Gazette |
| Order date | 17 September 2026 |
| Permanent continuation | Not expressly specified |
| Renewal procedure | Not expressly specified |
| Extension | Not stated in this Order |
The Order uses the date of publication in the Official Gazette as the starting point for the three-year period.
Manufacturers should therefore be careful when preparing internal timelines. The Order date, Gazette publication date and the date on which a business actually starts production are not automatically the same thing.
The commercial planning team should record the official Gazette publication details properly so that the trial window can be tracked accurately.
The notification clearly uses the phrase commercial trials, but it does not explain every operational step connected with such trials.
What the Order tells us is limited but clear.
The Order specifies:
The Order does not expressly specify:
Businesses should therefore avoid creating an application or testing process merely from assumption.
Where an operational question is not answered by S.O. 5105(E), the wider Fertiliser Control Order and later government directions should be checked separately.
The Gazette sets six main technical conditions before dealing separately with heavy metals.
| Parameter | Requirement | Type of Limit |
| Moisture | Maximum 15.0% by weight | Maximum |
| Sodium as Na | Maximum 0.75% by weight on dry basis | Maximum |
| Particle size | At least 90% must pass 4 mm IS sieve and remain on 1 mm IS sieve | Physical specification |
| Sulphur as S | Minimum 13.0% by weight | Minimum |
| Calcium sulphate dihydrate | Minimum 70.0% on dry basis | Minimum |
| Fluoride as F | Maximum 1.0% by weight | Minimum |
Moisture: Maximum 15%
The moisture content must not exceed 15.0% by weight.
From a manufacturing point of view, moisture control can affect product handling and consistency. If the finished material crosses the notified ceiling, it will not match the specification given in the Order.
Manufacturers may therefore need to monitor how the material is processed, stored and handled before evaluation.
Sodium Content: Maximum 0.75%
Sodium, expressed as Na, is limited to 0.75% by weight on a dry basis.
The phrase âon dry basisâ should not be dropped while reproducing this value in specification sheets or internal documents. It forms part of the technical requirement.
Sulphur: Minimum 13%
Sulphur, expressed as S, must be at least 13.0% by weight.
Unlike moisture and sodium, sulphur has a minimum requirement. A lower value would fall outside the notified specification.
This makes sulphur one of the composition parameters that manufacturers need to maintain consistently from batch to batch.
Calcium Sulphate Dihydrate: Minimum 70%
The product must contain at least 70.0% calcium sulphate dihydrate on a dry basis.
For quality-control teams, this is another floor rather than a ceiling.
The manufacturing process should therefore be capable of maintaining the required composition without allowing the figure to drop below the notified value.
Fluoride: Maximum 1%
Fluoride, expressed as F, is limited to 1.0% by weight.
This is an upper limit.
Manufacturers should keep this parameter separate from sulphur and calcium sulphate dihydrate because the compliance direction is different: sulphur, and calcium sulphate must meet minimum values, while fluoride must remain below its maximum.
Particle size is one of the more practical parts of the notification.
The Order requires that not less than 90% of the material should pass through a 4 mm IS sieve and be retained on a 1 mm IS sieve.
Put simply, most of the product should fall within the specified granular range.
What this means practically
At least 90% of the material must:
This means the manufacturer needs reasonable control over the granulation process.
If a large portion of the product is too fine or too coarse, the batch may not meet the notified particle-size specification.
The Order does not give an additional tolerance beyond this wording, so businesses should not create one themselves.
Heavy-metal control is another major part of S.O. 5105(E).
| Heavy Metal / Parameter | Maximum Limit |
| Lead as Pb | 100.0 mg/kg |
| Cadmium as Cd | 5.0 mg/kg |
| Chromium | 50.0 mg/kg |
| Nickel | 50.0 mg/kg |
| Arsenic as AsâOâ | 10.0 mg/kg |
| Mercury as Hg | 0.15 mg/kg |
The values are expressed as maximum concentrations in milligrams per kilogram.
This is important because a product may satisfy its main composition requirement but still fall outside the notified specification if one of the heavy-metal values crosses its limit.
A manufacturer cannot assess compliance by checking sulphur or calcium sulphate content alone.
The final material also needs to remain below every listed contaminant ceiling.
This creates a practical need to watch the quality of incoming material and understand how the production process affects the final composition.
Manufacturers may need to review:
These are sensible manufacturing controls.
They should not be confused with a statutory testing frequency, because S.O. 5105(E) does not prescribe how often these parameters must be tested.
The specification becomes much easier to understand when it is divided into three groups.
| Category | Parameters |
| Maximum limits | Moisture, sodium, fluoride and heavy metals |
| Minimum requirements | Sulphur and calcium sulphate dihydrate |
| Physical specification | Particle-size requirement |
Maximum means âdo not exceedâ
Moisture, sodium, fluoride and heavy metals need to stay at or below their notified values.
Minimum means âdo not fall belowâ
Sulphur and calcium sulphate dihydrate need to remain at or above their notified levels.
Particle size is different
The sieve requirement looks at how much of the material falls within a particular size range.
This simple distinction can help production and quality teams prepare more useful internal specification sheets.
For a manufacturing business, the Gazette can be converted into a simple internal quality checklist.
A business using manufacturer compliance services or fertiliser regulatory compliance services can also map these values against its internal product specifications and identify where technical gaps exist before commercial production planning moves further.
The wording of S.O. 5105(E) does not support describing the present specification as permanent.
The Order specifically says the specifications are being notified for conducting commercial trials for a period of three years.
That means a website, technical note or sales presentation should avoid statements such as:
âPhosphogypsum Granular has received permanent approval under FCO.â
That goes beyond what this Order says.
A more accurate statement is:
âThe Government has notified Phosphogypsum Granular specifications for three-year commercial trials.â
The difference may seem small, but from a compliance point of view it is important.
The notification contains the technical specification, but it does not answer every business question.
| Question | Position in This Order |
| Is there a separate application form? | Not expressly specified |
| What is the application fee? | Not expressly specified |
| Is there a fixed trial quantity? | Not expressly specified |
| How often must testing be done? | Not expressly specified |
| Which laboratory must be used? | Not expressly specified |
| What sampling method applies? | Not expressly specified |
| Is there a prescribed reporting format? | Not expressly specified |
| Is inspection mandatory under this Order? | Not expressly specified |
| Are packaging requirements given here? | Not expressly specified |
| Are labelling requirements given here? | Not expressly specified |
| Is a specific penalty stated? | Not expressly specified |
| Is there a renewal procedure? | Not expressly specified |
| Will permanent approval follow automatically? | Not expressly specified |
This section is important for manufacturers because the absence of information from this Order should not be confused with an exemption from other applicable law.
Manufacturers do not need a complicated checklist to begin their internal review. They need a correct one.
Step 1: Confirm the exact product
Make sure the material being manufactured is genuinely covered by the description Phosphogypsum (Granular).
Step 2: Prepare a specification comparison
Compare the proposed product against each notified parameter.
Step 3: Look for technical gaps
A gap may exist where:
Step 4: Review production consistency
Passing one internal test does not necessarily mean every batch will have the same result.
Businesses should understand where variation can occur.
Step 5: Keep technical evidence
Maintaining analytical reports, batch sheets and specification records can help the company track whether the material remains within the notified values.
This is a practical internal recommendation. The Order itself does not prescribe a particular record format.
Step 6: Check wider FCO compliance
Do not stop with S.O. 5105(E).
The manufacturing unit should separately review any wider legal requirement applicable to its activity.
Step 7: Monitor later notifications
Because the present specification is time-bound, businesses should monitor official updates during the commercial-trial period.
The notification may look like a small technical table, but for a manufacturer it can influence several day-to-day decisions.
Production Planning
The plant may need to maintain suitable process conditions so that composition and particle size stay within the required range.
The production team therefore needs clear internal specifications, rather than depending only on the Gazette once production begins.
Raw Material Control
Variation in incoming material may affect:
Manufacturers may therefore need better visibility over the quality of incoming material used in the process.
Quality Control
The notification gives exact numerical limits.
Quality-control teams should therefore be able to compare results directly with those limits rather than using broad descriptions such as âacceptableâ or âwithin normal rangeâ.
A useful internal report should clearly show:
Laboratory Coordination
S.O. 5105(E) does not name a particular laboratory or prescribe a testing frequency.
Still, reliable analytical data will matter for internal decision-making because the product specifications are numerical.
A product testing compliance support provider may assist a business in understanding what parameters should be captured and how supporting technical records can be organised, subject to the applicable regulatory framework.
Documentation and Record Keeping
Even where this Order does not create a separate record format, businesses may find it useful to maintain:
Good documentation helps production, regulatory and quality teams work from the same information.
Different manufacturing units may face different issues, but a few practical areas deserve attention.
Keeping Granule Size Consistent
The 1 mm to 4 mm sieve condition means the granulation process cannot be treated casually.
Too much undersized or oversized material may affect conformity.
Controlling Moisture During Storage
A product may leave production with one moisture level and change during storage or handling.
Businesses may therefore need to understand where moisture variation is occurring.
Maintaining Minimum Sulphur and Calcium Sulphate Levels
These are minimum requirements.
A manufacturing process that produces wide batch-to-batch variation could make it harder to maintain the notified values consistently.
Keeping Fluoride and Heavy Metals Below Their Limits
These parameters work as maximum limits.
Manufacturers may need to identify whether the source of variation is the incoming material, processing conditions or contamination at another stage.
The Gazette does not answer this question. S.O. 5105(E) does not say that the specifications will:
A manufacturer should therefore avoid building a long-term regulatory assumption around the present notification alone.
Future Government orders will need to be monitored.
Businesses working with Phosphogypsum (Granular) may want to keep track of:
These are monitoring areas rather than new requirements created by S.O. 5105(E).
| Check | What to Review | Status |
| Product identification | Is the material Phosphogypsum (Granular)? | Review |
| Moisture | Maximum 15.0% | Review |
| Sodium | Maximum 0.75% dry basis | Review |
| Particle size | Minimum 90% within specified sieve range | Review |
| Sulphur | Minimum 13.0% | Review |
| Calcium sulphate dihydrate | Minimum 70.0% dry basis | Review |
| Fluoride | Maximum 1.0% | Review |
| Lead | Maximum 100.0 mg/kg | Review |
| Cadmium | Maximum 5.0 mg/kg | Review |
| Chromium | Maximum 50.0 mg/kg | Review |
| Nickel | Maximum 50.0 mg/kg | Review |
| Arsenic | Maximum 10.0 mg/kg | Review |
| Mercury | Maximum 0.15 mg/kg | Review |
| Wider FCO requirements | Check separately | Review |
| Future Government updates | Monitor during trial period | Ongoing |
This table can be used as an internal starting point, but it should not be presented as an official government form.
Manufacturers interested in this product should focus on a few immediate actions.
First, review the notified specification line by line.
Second, compare existing, or proposed product data with every parameter in S.O. 5105(E).
Third, separate technical conformity from wider regulatory compliance. Meeting the product specification does not automatically answer every licensing, or manufacturing question.
Fourth, keep proper technical records showing how the material has been assessed.
Finally, monitor the Ministry of Agriculture and Farmers Welfare for any later order affecting the commercial-trial period or permanent regulatory position.
For manufacturers, the real difficulty usually begins after reading the notification.
A business may know that sulphur must be at least 13% or that lead must remain below 100 mg/kg, but still have questions such as:
Corpseed can support businesses through relevant fertiliser compliance services, including:
1. FCO Applicability Review
Corpseed can review the product, activity and regulatory position to help businesses understand which provisions may apply.
2. Technical Specification Review
The notified limits can be mapped against the manufacturer's internal product specification to identify gaps.
3. Manufacturer Compliance Services
Businesses can obtain support in reviewing the broader regulatory requirements connected with their manufacturing activity.
4. Product Compliance Services
Technical parameters, product documents and regulatory references can be checked before the business proceeds further.
5. Regulatory Compliance Assessment
Corpseed can help identify which requirements arise from S.O. 5105(E) and which need to be checked separately under the wider FCO framework.
6. Technical Document Review
Specification sheets, available test reports and related compliance documents can be checked for consistency with the notified values.
7. Product Testing Compliance Support
Where testing is relevant, Corpseed can assist with coordination and documentation support based on the applicable regulatory requirement.
8. Ongoing Regulatory Monitoring
Because the present notification is linked to a three-year commercial-trial period, future orders may change the position. Businesses can use ongoing fertiliser regulatory compliance services to keep track of those changes.
Corpseed does not replace the regulator or guarantee approval. The role of professional compliance support is to help manufacturers understand the applicable requirement, prepare the right documents and avoid proceeding on an incorrect interpretation of the notification.
The Phosphogypsum Granular specifications 2026, have been notified through S.O. 5105(E), dated 17 September 2026, by the Department of Agriculture and Farmers Welfare.
The Order is specifically linked to commercial trials for three years from Gazette publication.
The product must meet notified limits for moisture, sodium, sulphur, calcium sulphate dihydrate, fluoride and particle size.
Separate maximum limits apply to lead, cadmium, chromium, nickel, arsenic and mercury.
Manufacturers should not treat this Order as a permanent specification or a complete manufacturing approval process.
The safest approach is to assess the product technically, review wider FCO obligations separately and continue monitoring official notifications during the commercial-trial period.
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