ZuivelNL provided all data for phosphate reduction

The agreements are contained in the so-called processing agreement between both parties, which was requested in reliance on the WOO (Open Government Act).
At the time, both parties committed to a reduction in phosphate production, which was then considered necessary to meet the emission requirements. In retrospect, the necessity of the fairly drastic intervention was doubted with reference to the precise data.

GDPR rules
Because both parties committed to the reduction plan, it was perhaps understandable that they both made an effort, but the question is whether ZuivelNL should have provided the requested data without first asking permission from the farmers. The conduct appears to be contrary to privacy legislation, even though the board had also given permission. From a legal perspective, the government could have obtained the data better, but this takes more time.
The processing agreement formed the basis of the phosphate rights control in the years that followed.

Disadvantage of extensive farms, advantage of intensive ones
The data also shows that very extensive farms, with a low milk yield per cow per year, were disadvantaged by the control and enforcement system, while very intensive farms with a high milk yield per cow per year were advantaged. "There are farms that have a very low or very high milk yield per cow. The phosphate excretion of these farms is determined on the basis of the average milk yield in 2015. These are farms with low milk yield: less than 4.000 kg per cow per year and farms with high milk yields of more than 13.000 kg per cow per year," the enforcement analysis of phosphate rights for dairy cattle states.

Companies that produced well above their phosphate ceiling could be prosecuted, but enforcement action could also be taken through an administrative process. RVO could hold companies to a daily ceiling, it was agreed. As far as we know, little work has been done on this.