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--- start_c [2026-08-04 08:41] – [Algae regulation& Legislation / NOTES & COMMENTS] robert
+++ start_c [2026-09-13 20:30] (current) – robert
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 ===== Algae regulation& Legislation / NOTES & COMMENTS =====
-Changes from the original
+==== [Sep 2026] ====
+Rearrangements:
+=== Missing areas ===
+The most significant gap is pharmaceutical and medical device applications. Alginate wound dressings and algae-derived pharmaceutical excipients fall under Regulation (EU) 2017/745 (MDR) and Directive 2001/83/EC (medicinal products), which are entirely separate regulatory worlds from food or cosmetics. Similarly, pharmaceutical-grade omega-3s (Lovaza/icosapent ethyl) come under a different authorization pathway. This doesn't need to be a full chapter, but even a short stub that orients producers hitting that boundary would be valuable — it's a common point of confusion between "food supplement" and "medicine" status.
+Plant protection products is a related gap. Algae extracts used as crop inputs can fall under Regulation (EC) No 1107/2009 (PPPR) rather than the Fertilising Products Regulation, depending on the claimed function. The PPPR has fundamentally different authorization requirements from the FPR biostimulant route. The fertiliser chapter implicitly touches on this but doesn't name it, and producers wanting to make pest-control claims on an algae extract will be completely unprepared.
+Biocides (Regulation EU 528/2012) are mentioned in passing in REACH but not named. Algae-derived preservatives in cosmetics and industrial water treatment biocides are a real application area.
+=== Organization issues ===
+Organic certification (Ch. 12) and EU Quality Schemes (Ch. 23) are conceptually neighbours — both are about voluntary standards layered on top of mandatory compliance — but they sit 11 chapters apart. Moving quality schemes closer to Ch. 12 would help readers who approach the wiki from a "how do I certify my product" angle.
+GMO (Ch. 22) comes very late. For a producer deciding at the start whether to use GM strains, this is a foundational question that shapes everything. It probably belongs closer to the production chapters (3–5).
+Internal to the Food section, the "Meat-related terms" item (Ch. 6.10) reads like an editorial note left in rather than a chapter. The provision belongs in Labelling (Ch. 6.4) with a note on the provisional agreement status.
+=== Overlaps ===
+Production/Hygiene (Ch. 5) and Food Quality and Safety (Ch. 6.1) have a fuzzy boundary — HACCP is in Ch. 5, but the microbiological criteria that define what HACCP is designed to prevent are in Ch. 6.1. This isn't necessarily wrong but users may not find what they're looking for if they go to only one of them.
+Specialised Sources (Ch. 27) will become redundant once the new bibliography page is live — they serve the same function. Worth thinking about whether to replace 27 with the new page, or fold the new page into 27.
+Two pages apparently referenced but not confirmed to exist: algae:reading_guides (mentioned in the intro) and algae:faq (Ch. 29). If those don't exist yet they should probably be removed from the start page or marked as "forthcoming" to avoid broken links.
+===Minor ===
+Textiles (Ch. 10) and Detergents (Ch. 9) are both fairly thin application areas for algae. They could plausibly be merged into a single "Other Industrial Applications" chapter, which would also make room for a short biocides section.
+Ordering:
+  - 1. General upstream downstream horizontal
+  - 2. General production Applications  horizontal
+----
+Framework (1–2 — unchanged)
+  * Purpose, Scope and Sources
+  * General on EU Legislation
+Production upstream (3–7)
+  * Aquaculture and Wild Harvesting
+  * Agriculture and Land-based Cultivation
+  * Production, Processing and Hygiene
+  * GMO Regulation ← moved here (strain choice is upstream decision)
+  * Environment and Use of Non-native Species
+Downstream — most used to least (8–17)
+  * Food (subsections; meat-related stub removed, note folded into Labelling)
+  * Feed
+  * Fertilising Products
+  * Animal By-products
+  * Cosmetics
+  * Pharma and Medical Devices ← new
+  * Plant Protection Products ← new
+  * Other Industrial Applications ← new (Textiles + Detergents + Biocides merged)
+  * Biogas and Biofuels
+Horizontal / cross-cutting (17–26)
+  * Organic Production and Certifications
+  * EU Quality Schemes ← moved next to Organic
+  * Green Claims and Greenwashing
+  * Intellectual Property
+  * REACH and Chemicals
+  * Customs and Trade
+  * Waste, Wastewater, Nutrient Recovery
+  * Greenhouse Gases and Climate
+  * Spatial Planning, Permits and Water Use
+  * Equipment and Safety
+  * Initiatives and Strategic Documents
+Resources (28–34)
+  * Legal Sources
+  * Bibliography ← actual consulted references
+  * Other Similar Resources ← new (active registers, EU guides, similar reviews)
+  * Cases and Precedents
+  * FAQ
+  * Reading Guides (forthcoming)
+----
+Framework (1–2)
+  * Purpose, Scope and Sources
+  * General on EU Legislation
+Production contexts (3–10) — how and where algae are grown
+  * Aquaculture and Wild Harvesting
+  * Agriculture and Land-based Cultivation
+  * Spatial Planning, Permits and Water Use (with explicit cross-ref to 3–4 and acknowledgement of overlap)
+  * Production, Processing and Hygiene
+  * GMO Regulation
+  * Environment and Use of Non-native Species
+  * Waste, Wastewater and Bioremediation ← reframed: bioremediation as the production rationale, nutrient recovery as the output story
+  * Biogas and Biofuels ← adjacent to 9; both are "unconventional medium / circular input" chapters
+  *
+Applications (11–19) — ordered most used to least
+  * Food
+  * Feed
+  * Fertilising Products
+  * Animal By-products
+  * Cosmetics
+  * Pharma and Medical Devices ← new
+  * Plant Protection Products ← new
+  * Other Industrial Applications ← new (Textiles + Detergents + Biocides)
+Horizontal (20–26)
+  * Organic Production and Certifications
+  * EU Quality Schemes ← moved next to Organic
+  * Green Claims and Greenwashing
+  * Intellectual Property
+  * REACH and Chemicals
+  * Customs and Trade
+  * Greenhouse Gases and Climate
+  * Equipment and Safety
+  * Initiatives and Strategic Documents
+Resources (29–34)
+  * Legal Sources
+  * Bibliography
+  * Other Similar Resources ← new (registers, guides, reviews)
+  * Cases and Precedents
+  * FAQ
+  * Reading Guides (forthcoming)
+----
+==== [JUne 2026] Changes from the original ====
 . Split "Aquaculture, Agriculture" into two separate chapters