Law Updates

Subject

Summary: 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. Phosphogypsum Granular Notification 2026 at a Glance 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. What Is Phosphogypsum (Granular)? 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. What Has Changed Under the 2026 Notification? 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: moisture, sodium content, particle size, sulphur, calcium sulphate dihydrate, fluoride, and six heavy metal or contaminant limits. 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. Regulatory Framework Under the Fertiliser Control Order, 1985 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. Scope and Applicability of the Phosphogypsum Granular Order 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) “to be manufactured by any manufacturing unit” for conducting commercial trials. The expression “any manufacturing unit” 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. Who Can Manufacture Phosphogypsum (Granular) Under This Order? 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: whether the proposed product meets S.O. 5105(E), and whether the unit has met any other regulatory requirements applicable to its activity. 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. Three-Year Commercial Trial Period: What Manufacturers Need to Know 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. What Does “Commercial Trial” Mean Here? 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 product, the commercial-trial nature, the duration, the physical and chemical specifications, the heavy-metal limits. The Order does not expressly specify: a separate application form, how to apply for the trial, a trial quantity, a prescribed laboratory, how often the material should be tested, a reporting format, inspection frequency, trial-monitoring procedure, or what happens automatically after the trial period. 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. Complete Phosphogypsum Granular Specifications 2026 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 “on dry basis” 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 Requirement for Phosphogypsum (Granular) 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: pass through the larger 4 mm sieve, and remain on the 1 mm sieve. 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 Limits for Phosphogypsum Granular 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 As₂O₃ 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. Why Heavy Metal Control Matters for Manufacturers 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: variability in raw materials, contamination during processing, batch consistency, storage and handling conditions, reliability of analytical results. 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. Maximum Limits and Minimum Requirements: The Difference 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 “do not exceed” Moisture, sodium, fluoride and heavy metals need to stay at or below their notified values. Minimum means “do not fall below” 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. Quality Parameters Manufacturers Should Track For a manufacturing business, the Gazette can be converted into a simple internal quality checklist. Moisture: Check whether the material remains within the 15.0% ceiling. Sodium: Review sodium as Na on a dry basis. Granule Size: Check whether at least 90% of the product satisfies the notified sieve range. Sulphur: Confirm that sulphur is not below 13.0%. Calcium Sulphate Dihydrate: Confirm that the dry-basis value remains at or above 70.0%. Fluoride: Check that the value remains within the 1.0% maximum. Heavy Metals: Review every heavy metal separately rather than using a single combined result. 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. Is This a Permanent FCO Specification for Phosphogypsum Granular? 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: “Phosphogypsum Granular has received permanent approval under FCO.” That goes beyond what this Order says. A more accurate statement is: “The Government has notified Phosphogypsum Granular specifications for three-year commercial trials.” The difference may seem small, but from a compliance point of view it is important. What S.O. 5105(E) Does Not Tell Manufacturers 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. What Should Manufacturers Check Before Commercial Trials? 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: moisture is too high, sodium is above the limit, sulphur is below the minimum, calcium sulphate dihydrate is below the minimum, fluoride is too high, particle size falls outside the required range, or a heavy metal exceeds its ceiling. 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. Impact of the New Phosphogypsum Specifications on Manufacturers 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: sulphur content, calcium sulphate content, fluoride, sodium, and heavy-metal levels. 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 “acceptable” or “within normal range”. A useful internal report should clearly show: parameter, result, notified requirement, whether the result is above or below the relevant limit. 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: product specification sheets, test reports, batch records, raw material records, internal quality checks, copies of applicable notifications. Good documentation helps production, regulatory and quality teams work from the same information. Practical Challenges Businesses May Face 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. What Happens After the Three-Year Commercial Trial? The Gazette does not answer this question. S.O. 5105(E) does not say that the specifications will: automatically become permanent, automatically expire without any further action, automatically be extended, be converted into another product category, or result in permanent approval. A manufacturer should therefore avoid building a long-term regulatory assumption around the present notification alone. Future Government orders will need to be monitored. Regulatory Developments Manufacturers Should Monitor Businesses working with Phosphogypsum (Granular) may want to keep track of: changes to the present specifications, extension of the commercial-trial period, amendments to the Fertiliser Control Order, additional testing directions, additional reporting requirements, revised heavy-metal values, permanent product specification, if notified later, replacement or withdrawal of the commercial-trial notification. These are monitoring areas rather than new requirements created by S.O. 5105(E). Phosphogypsum Granular Manufacturer Compliance Checklist 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. What Businesses Should Do Now 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. How Corpseed Can Help with Fertiliser Compliance Services 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: Does this notification apply to our exact product? Are there other FCO requirements for our manufacturing unit? Which internal documents should be reviewed? Do our product specifications match the Gazette? What technical gaps should be corrected before moving ahead? Has any later notification changed the position? 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. Key Takeaways 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.