Fertilizer Efficiency Products Face a Review Bottleneck Washington Could Clear

Why Enhanced-Efficiency Fertilizers Get Stuck in Review

An opinion piece from Steve Levitsky, chief administrative and sustainability officer at fertilizer-technology company Phospholutions, argues that U.S. fertilizer policy is too focused on production and supply and is ignoring a simpler bottleneck: the slow, duplicative review process that keeps enhanced-efficiency fertilizers (EEFs) out of federal cost-share programs.

Levitsky writes that recent global fertilizer market turmoil exposed how little slack the U.S. system has. Fertilizer, he notes, can decide whether a crop turns a profit, and Washington has responded with federal action on phosphate fertilizer, new investment in domestic production and farm bill negotiations. But producing more fertilizer is only half the answer; making the nutrients farmers already buy work harder matters too.

EEFs are designed to improve nutrient availability or reduce nutrient losses compared with conventional products. The Natural Resources Conservation Service (NRCS) runs programs that help growers offset the cost and risk of adopting such practices. The problem, according to Levitsky, is that an EEF can be recognized nationally under the framework maintained by the Association of American Plant Food Control Officials (AAPFCO) and then face separate, state-by-state reviews before it qualifies for certain NRCS programs.

The proposed fix is to separate the two questions. AAPFCO would decide whether a product meets national EEF criteria; NRCS and local agronomic experts would decide how it should be used — rates, timing, placement, soil conditions and local resource concerns. Levitsky says USDA and NRCS can act now by treating AAPFCO recognition as sufficient for product eligibility, preserving local guidance for use, and updating Nutrient Management Standard Code 590. This remains an opinion proposal; no policy change has been announced.

Where the Bottleneck Is — and Who Would Gain From Levitsky's Fix

The Case for Splitting Product Approval From Use Guidance

Levitsky's argument is essentially an administrative division of labor. Product-level questions — does this product meet national EEF criteria — would be answered once by AAPFCO. Agronomic questions — how should this product be applied in this field — would remain with NRCS and local experts. That distinction already exists in concept, but the op-ed says the current system blurs it, so the same product question gets re-reviewed state by state.

If adopted, the change would not loosen standards. AAPFCO criteria would still govern eligibility, and local guidance would still shape application. What would disappear is the redundant product review layer, which Levitsky says can keep technologies in limbo for years before farmers can use public funding to adopt them.

Who Would Benefit From Faster Qualification

The clearest beneficiaries are growers eligible for NRCS cost-share and conservation programs: faster product qualification means federal dollars can be applied to EEFs sooner. But the commercial upside is also concentrated. EEF manufacturers — including Phospholutions, Levitsky's employer — would likely see shorter time-to-market for products that clear AAPFCO recognition, and a bigger pool of farmers with funding available to purchase them.

That alignment of public interest and company interest is worth noting. The proposal is framed around farm resilience and program efficiency, and those goals do not depend on which company supplies the product. But any policy change that accelerates EEF adoption creates commercial winners, and an executive from an EEF producer advocating for it has a stake in the outcome.

What the Op-Ed Does Not Prove

The piece is short on evidence for the scale of the problem. It does not name a specific product that spent years in review, quantify how many EEFs are affected, or estimate the cost of the duplication. That does not mean the bottleneck is imaginary — the mismatch between national AAPFCO recognition and state-by-state NRCS qualification is a plausible source of delay. But the strength of the argument rests on that plausibility, not on documented cases.

What USDA, NRCS and Growers Can Do Next

For USDA and NRCS:

• Treat AAPFCO recognition as sufficient for EEF product eligibility in cost-share programs, as Levitsky proposes, while keeping rates, timing, placement and soil-condition guidance at the local level.
• Update Nutrient Management Standard Code 590 to codify the distinction between product eligibility and local use guidance.
• Issue clear direction to state NRCS offices that product-level reviews should not be duplicated once AAPFCO has ruled.

For EEF manufacturers and grower groups:

• Use the ongoing farm bill negotiations to push for legislative or administrative language that codifies the eligibility-guidance split.
• Document instances where an AAPFCO-recognized product is still subject to duplicative state-level review before NRCS cost-share eligibility, so policymakers have concrete examples.

For growers:

• Ask local NRCS offices whether the EEF they are considering is already eligible for cost-share funding, and whether any state-level review is still pending before the funding can be used.