Which fertiliser products are covered by CBAM?

QuestionsCategory: CBAMWhich fertiliser products are covered by CBAM?
1 Answers
Best Answer
Team GreenSutra Staff answered 1 week ago
Night-vector clerk sorting urea sacks and ammonia cylinders at a customs desk, showing CBAM fertiliser scope

CBAM covers nitrogen fertilisers and their feedstocks across five combined-nomenclature headings: nitric acid at CN 2808, ammonia at CN 2814, potassium nitrates at CN 2834 21, urea and other nitrogenous fertilisers at CN 3102, and nitrogen-containing multi-nutrient blends at CN 3105, excluding CN 3105 60.

What CBAM captures across the nitrogen chain

Fertilisers are one of the six product groups CBAM covers, and the scope follows the whole nitrogen chain rather than a single finished line. The mechanism reaches the ammonia and nitric acid that feed production as well as the urea, potassium nitrates and multi-nutrient blends that leave the gate. Because natural gas is both the feedstock and the main emissions source for ammonia and urea, the embedded carbon concentrates in these upstream products. One multi-nutrient sub-heading, CN 3105 60, sits outside the boundary.

Fertiliser products and their CN codes

Split chart of five CBAM fertiliser CN codes in scope beside the excluded CN 3105 60 heading
Five fertiliser CN headings in CBAM scope; CN 3105 60 sits outside
CN code Products covered
CN 2808 Nitric acid
CN 2814 Ammonia
CN 2834 21 Potassium nitrates
CN 3102 Urea and other nitrogenous fertilisers
CN 3105 (excluding 3105 60) Multi-nutrient fertilisers containing nitrogen

How the coverage shapes the charge

Three features distinguish fertiliser coverage from the other sectors:

  • Both direct and indirect emissions count, so grid electricity is added to process emissions.
  • The de-minimis of 50 tonnes per importer each year applies, unlike hydrogen and electricity.
  • A flat 1 percent mark-up sits on default values, held constant across 2026, 2027 and 2028, rather than the escalating ramp used for cement, steel, aluminium and hydrogen.

Because ammonia and nitric acid are captured as feedstocks, a producer of intermediates carries a CBAM obligation alongside the finished-fertiliser exporter, a point easily missed when only finished bags are reviewed. CBAM advisory covers declarant status, embedded-emissions calculation and certificate exposure across each of these headings. A CBAM guide lists the headings before a declaration is filed.

Sources: Regulation (EU) 2023/956 · Implementing Regulation (EU) 2025/2621 · European Commission CBAM