No. The escalating EU duty on Russian and Belarusian fertilisers, set by Regulation (EU) 2025/1227, is a separate trade tariff, not part of CBAM. Both measures can apply to the same nitrogen import, but only CBAM prices embedded carbon; the tariff is a conventional origin-based duty that stacks on top.
No. The two instruments are legally and functionally distinct. CBAM prices the embedded carbon of covered goods so that imports carry a cost comparable to the emissions-trading charge borne by EU producers. The duty on Russian and Belarusian fertilisers is a conventional trade measure tied to origin, not to carbon content, and it applies whether or not a CBAM obligation also arises on the same consignment.
Where the fertiliser tariff comes from
Regulation (EU) 2025/1227 entered into force on 21 June 2025. Its fertiliser duties apply from 1 July 2025 to goods that originate in, or are exported directly or indirectly from, Russia or Belarus. It sits alongside CBAM rather than inside it, with its own legal basis, its own scope and its own escalating schedule. Nothing in it changes how CBAM is calculated or reported.
How the charges stack on one nitrogen import
For an in-scope shipment of Russian or Belarusian origin, three charges can accumulate:
- the 2025/1227 duty on CN 3102, EUR 60 per tonne from 1 July 2026, EUR 80 from 1 July 2027 and EUR 315 from 1 July 2028 (EUR 70, 95 and 430 for CN 3105). The top rate applies sooner if cumulative imports reach the volume thresholds in Article 1(3);
- the 6.5 percent ad valorem rate that Article 1(2) of the same regulation sets alongside the per-tonne amount;
- any CBAM certificate cost, charged separately on the embedded emissions of the goods.
Only the last of these reflects carbon. Importers sometimes read the trade duty and the certificate cost as a single fertiliser levy, when they are billed independently and attach to different things: one to origin, the other to verified or default embedded emissions.
CBAM advisory covers declarant status, embedded-emissions calculation and certificate cost, keeping the carbon obligation distinct from origin-based trade duties. A CBAM guide sets out which measure applies to which fertiliser origin.
Sources: Regulation (EU) 2025/1227 · Regulation (EU) 2023/956 · European Commission CBAM