Fertilisers carry a flat 1 percent CBAM mark-up on default values, not the escalating 10, 20 and 30 percent applied to cement, steel, aluminium and hydrogen. The legal text gives one line of reason: recital 6 of Implementing Regulation (EU) 2025/2621 says specific considerations apply to the fertilisers sector, where a lower mark-up should be applied.
Fertilisers get the flat 1 percent because the implementing rules set a lower mark-up for the fertilisers sector. Recital 6 of Implementing Regulation (EU) 2025/2621 says specific considerations apply to the fertilisers sector and that a lower mark-up should be applied. The flat 1 percent rate itself is set in the opening paragraph of Annex I to that Regulation, as replaced by Implementing Regulation (EU) 2026/1740. It does not reflect any difference in how fertiliser emissions are measured, because ammonia and urea are assessed under the same embedded-emissions methodology as other covered goods.
What the mark-up is actually for
The mark-up applies only when the declarant uses a default value instead of verified installation data. A CBAM default value is the country-of-origin emissions figure applied when actual installation data is absent, and the uplift is added on top of it to cover installations whose real emissions sit above their country average. For most goods that uplift escalates each year, so resting on the default grows steadily more expensive. For fertilisers it is held flat.
| Sector group | 2026 | 2027 | 2028 onward |
|---|---|---|---|
| Fertilisers | base x1.01 | base x1.01 | base x1.01 |
| Cement, steel, aluminium, hydrogen | base x1.10 | base x1.20 | base x1.30 |
As of 19 October 2026, recital 11 of Implementing Regulation (EU) 2025/2621 requires the Commission to revise default values and mark-ups by December 2027 at the latest. This schedule may change.
What the flat rate means for a fertiliser exporter
Because the fertiliser uplift stays at 1 percent, the cost penalty for using a default rather than verified data is far smaller than in steel or aluminium, and it does not grow year on year, which lowers the immediate pressure to compile verified figures. Verified installation data still helps, though: a producer whose real emissions sit below the country-of-origin default can give the declarant verified data, and the declarant can then declare the lower figure and cut the charge, and that gap is widest for installations cleaner than their national average. CBAM compliance support covers preparing the declarant application, embedded-emissions calculation and certificate planning across the covered goods. A CBAM guide sets out how the mark-up, the default value and the free allocation adjustment combine into a certificate cost.
Sources: Implementing Regulation (EU) 2025/2621 · Regulation (EU) 2023/956 · European Commission CBAM