CBAM for Fertiliser Exporters

Carbon Border Adjustment Mechanism (CBAM) compliance for exporters of ammonia and nitrogen fertilisers to the European Union, worldwide, and for the EU importers who declare them. Embedded emissions calculated from installation data, CBAM reports prepared for verification by accredited verifiers, and certificate exposure estimated and managed, as one accountable engagement delivered from Mumbai.

Fertilisers · CN 2808 to 3105Direct and indirect emissionsWorldwide delivery

Reviewed by Team GreenSutra · Updated 20 July 2026

On recordCovered groupFertilisersCN coverageCN 2808 · 2814 · 3102 · 3105Emissions countedDirect and indirectMark-upFlat 1 percentDe minimis50 t per importer a yearMarketsEgypt
01

What CBAM means for fertiliser exporters

Fertilisers are a global trade, and the largest CBAM exposed suppliers sit outside India.

The Carbon Border Adjustment Mechanism (CBAM) prices the carbon emissions embedded in imported goods, and fertilisers are one of the six covered product groups, covering ammonia, urea and other nitrogen fertilisers. The European Union imported about 2.7 billion euro of nitrogen fertilisers and a further 1.1 billion euro of ammonia in 2024, so the definitive regime, which has applied since 1 January 2026, reprices market access for the major supplier countries.

The largest suppliers sit outside India: Egypt, Russia, Algeria and Trinidad and Tobago lead, and India is a minor exporter and a net importer of fertilisers. GreenSutra works as a CBAM consultant for fertiliser exporters worldwide and the EU importers and authorised declarants who file for them.

Exposure tracks the gas feedstock and the country of origin. The table below shows the leading suppliers of fertilisers to the EU and how CBAM bears on each.

EU fertiliser imports and CBAM exposure, leading suppliers (2024)
MarketPosition in EU imports, 2024CBAM exposure
EgyptLargest urea supplier, around 41 percent of EU urea importsModern gas based plants, so per tonne exposure varies widely by installation.
RussiaLeading ammonia supplier; with Belarus around 33 percent of EU urea importsGas based ammonia and urea, among the highest default emission origins, and separately subject to an escalating EU tariff.
AlgeriaAround 17 percent of EU urea importsGas based production; efficient plants sit below the default estimate on verified data.
Trinidad and TobagoMajor ammonia supplierGas based ammonia, exposure set by the specific plant emissions.
IndiaMinor supplier and a net importerLimited direct EU fertiliser exposure; relevant mainly for niche ammonia or nitrate shipments.

Import values from Eurostat via the Commission, 2024 (nitrogen fertilisers CN 3102, ammonia CN 2814). A separate measure, Regulation (EU) 2025/1227, adds an escalating tariff on Russian and Belarusian fertilisers on top of any CBAM cost. The CBAM cost of any specific plant turns on its production route and verified emissions, so the figures above frame exposure rather than fix a bill. A first step is the structured CBAM discovery brief, after which exposure feeds the CBAM cost calculator. The full deadlines and methods are set out in the CBAM compliance guide.

02

Fertiliser products and their default values

The India default embedded-emissions values that apply where verified data is not supplied.

Coverage follows the combined nomenclature (CN) code of each good, from nitric acid and ammonia through urea and other nitrogen fertilisers to multi-nutrient products. The India defaults below count direct and indirect emissions, and each carries a flat mark-up of 1 percent, held constant across 2026, 2027 and 2028.

The representative values below span the fertiliser range. Each is a single country-of-origin default; the figure for a specific plant turns on its own gas feedstock and production route and, where supplied, its verified emissions.

Reading the defaults, the straight nitrogen products such as ammonia and urea carry the most embedded carbon, driven by the natural gas feedstock, while downstream and blended products sit lower. With only a flat one percent mark-up, the exposure per tonne is smaller than for the metals, so verified plant data and the tonnage shipped to the European Union set the scale.

India default embedded-emissions values, representative fertiliser products
ProductRepresentative CNIndia default (tCO2e/t)
Anhydrous ammoniaCN 2814 10 003.28
UreaCN 3102 102.17
Nitric acidCN 2808 00 002.01
Diammonium phosphate (DAP)CN 3105 30 000.81

Values are the India totals of direct and indirect emissions, specific to the country of origin, so the set differs elsewhere. Source: Implementing Regulation (EU) 2025/2621, Annex I. The fertiliser mark-up is a flat 1 percent, not the 10 to 30 percent applied to other goods. Estimate a specific product, volume and route in the CBAM cost calculator.

03

How a fertiliser CBAM engagement runs

From exposure assessment to a prepared, declared and managed certificate position.

Consultant mapping fertiliser export goods against the European border on a wall chart
01

Assess CBAM exposure

Fertiliser products, CN classification, production route, export destinations and volumes mapped against the definitive regime, the de minimis threshold and the authorised declarant requirement.

Engineer measuring embedded emissions at a fertiliser plant with a tablet showing emission factors and process units behind
02

Calculate embedded emissions

Direct and indirect embedded emissions of each product quantified from actual installation and production route data following the EU methodology, in place of default values that carry a mark-up, then prepared for verification.

Accredited verifier reviewing embedded emissions data on screen with fertiliser goods bound for the European market
03

Prepare for accredited verification

Installation data and the monitoring methodology behind it prepared for confirmation by an accredited verifier, so the declared embedded emissions stand on evidence rather than marked up default values.

Compliance analyst before a CBAM registry ledger sharing verified emissions data with EU importers beside a night port
04

Report through the CBAM registry

Verified data shared with EU importers and authorised declarants through the central CBAM registry, and the annual declaration prepared so every covered consignment is accounted for.

Consultant reviewing CBAM certificate exposure under a desk lamp with a rising EU ETS price line and a falling emissions pathway
05

Manage CBAM exposure and reduce

Certificate exposure tracked against the EU ETS price, any carbon price paid at origin deducted, and a reduction pathway built to lower the embedded emissions and the cost over time.

04

How CBAM works for fertilisers

The border mechanism follows the embedded emissions of a fertiliser from the plant across the European border to the certificate that is surrendered.

How CBAM works for fertilisersTechnical drawing of the CBAM border mechanism for fertilisers. A fertiliser plant in an exporting country, Egypt shown, produces nitrogen fertilisers, among the six Annex I goods covered by CBAM. Direct and indirect embedded emissions are measured from installation data, verified by an accredited verifier and shared through the CBAM registry. The goods cross the European Union border past customs control, an authorised declarant files the annual CBAM declaration, and CBAM certificates priced off the EU ETS are surrendered, with any carbon price already paid at origin deducted.1122334455667788AABBCCDDEEFFREGULATIONCBAM REGULATIONOMNIBUS IIMPLEMENTING REGEU ETS LINKFERTILISER PLANT · EGYPTFERTILISERS01EMBEDDED EMISSIONSACTUAL OR DEFAULT02EU BORDERGOODS CROSS THE FRONTIER03AUTHORISED DECLARANTEU IMPORTER04CERTIFICATES SURRENDEREDPRICED OFF THE EU ETS05CEMS · INSTALLATION DATAFERTILISERSMECHANISM SPINE · NTSEMBEDDED tCO2e · VERIFIEDBACTUAL DATADEFAULT VALUEEMBEDDED tCO2eDETAIL B · NTSTHIRD COUNTRYEUROPEAN UNIONCUSTOMS CONTROLANNUAL DECLARATIONCBAM REGISTRYREPORTING YEAREU ETS PRICEEUR/tCO2ePRICE PAID AT ORIGINDEDUCTEDSURRENDERKEYCONSIGNMENTSURRENDERDATA LINKDRAWINGCBAM MECHANISMSTATUSDWG NOGS·CBAM·02REVCDATE2026·06
01Installation · gas feedstock

An ammonia or nitrogen fertiliser plant produces the good. Natural gas is the feedstock and the main emissions source, so a gas based plant carries high embedded emissions.

02Embedded emissions · direct and indirect

Both direct and indirect, electricity related emissions are counted for fertilisers, measured from installation data or estimated with a country and product specific default value. The fertiliser mark-up is a flat 1 percent, lower than the 10 to 30 percent applied to other goods.

03Verified and shared

An accredited verifier confirms the actual data, which is shared with the European importer through the central CBAM registry.

04Border · declarant

The good crosses the European border, where an authorised CBAM declarant reports the embedded emissions for the year above the 50 tonne de minimis.

05Certificates surrendered

CBAM certificates are surrendered for the embedded emissions, priced off the EU ETS, with any carbon price already paid at origin deducted.

Direct and indirect embedded emissions are measured at the plant, verified and shared through the CBAM registry, then declared at the European border by an authorised declarant who surrenders certificates priced off the EU ETS. Fertilisers count both direct and indirect emissions and carry a flat 1 percent mark-up. First surrender, covering 2026 imports, falls on 30 September 2027.

Embedded emissions follow each fertiliser from the plant to the European border, and a readiness review turns that path into a measured, verified compliance plan.

Request a CBAM readiness review
05

What CBAM readiness earns a fertiliser exporter

The gains of moving from marked up default values to verified installation data.

B·01

Market access retained

Verified embedded emissions data keeps fertiliser products moving into the European market under the definitive regime without compliance friction.

B·02

Lower certificate cost

Actual verified data replaces the conservative default, so the certificate obligation reflects the real gas feedstock and plant rather than a penalty estimate.

B·03

Trusted supplier status

Sharing verified data through the CBAM registry positions the plant as a preferred supplier to European importers and declarants.

B·04

Decarbonisation advantage

A reduction pathway lowers embedded emissions over time, an advantage that grows as the payable share climbs toward 100 percent in 2034.

Fertiliser goods crossing a port toward the European market beside a falling emissions trend line and a certificate
Verified data protects market access
06

CBAM for fertiliser exporters, answered

Q·01Which fertiliser products does CBAM cover?
CBAM covers fertilisers as one of its six product groups, spanning nitric acid under combined nomenclature heading 2808, ammonia under 2814, potassium nitrates under 2834 21, urea and other nitrogenous fertilisers under 3102, and multi-nutrient fertilisers containing nitrogen under 3105, excluding 3105 60. Coverage follows the CN code of each good, so Annex I of Regulation (EU) 2023/956 is the reference for any specific product.
Q·02What are the CBAM default values for fertilisers, and how is the mark-up different?
Default embedded-emissions values are specific to the country of origin and count both direct and indirect emissions for fertilisers. For goods of Indian origin the default for anhydrous ammonia is 3.28 tonnes of CO2e per tonne, with urea at 2.17, nitric acid at 2.01 and diammonium phosphate at 0.81. The fertiliser mark-up is a flat 1 percent held constant across 2026, 2027 and 2028, rather than the 10 to 30 percent that rises for other goods, published in Commission Implementing Regulation (EU) 2025/2621.
Q·03Does CBAM count indirect, electricity emissions for fertilisers?
Yes. Fertilisers, along with cement, count both direct and indirect embedded emissions under the definitive regime, unlike iron and steel, aluminium and hydrogen, which count direct emissions only. For fertilisers the indirect, electricity related emissions of production are added to the direct emissions when the certificate obligation is calculated.
Q·04Which countries are most affected, and where does India sit?
The largest suppliers of fertilisers to the European Union sit outside India. Egypt is the largest urea supplier at around 41 percent of EU urea imports, Russia leads ammonia and with Belarus accounts for around a third of EU urea, and Algeria supplies around 17 percent, with Trinidad and Tobago and the United States also significant. India is a minor exporter and a net importer of fertilisers, so its direct CBAM fertiliser exposure is limited. Russian and Belarusian fertilisers additionally face a separate escalating EU tariff under Regulation (EU) 2025/1227, which is distinct from CBAM.
Q·05How much will CBAM cost fertiliser exporters?
The cost depends on the country of origin, the product, the gas feedstock and production route, the volume and the import year, and the payable share rises from 2.5 percent of the certificate obligation in 2026 to 100 percent in 2034. Because default values reflect a conservative estimate, published per tonne cost figures vary widely, so a specific position is best estimated year by year rather than taken from a single headline number. The CBAM cost calculator estimates a specific product and volume.
Q·06Does verified data really lower the CBAM cost for fertilisers?
Usually, yes. Default values carry a mark-up and reflect a conservative estimate, while verified actual installation data reflects the specific gas feedstock and process. An efficient modern ammonia or urea plant can declare below the default on verified data, so the certificate obligation reflects the real installation rather than a conservative proxy.
Q·07Who verifies the emissions data, and can a verifier in India do it?
The final CBAM declaration must be verified by a verifier accredited under the EU CBAM accreditation rules set out in Commission Delegated Regulation (EU) 2025/2551. An accredited verifier in India, such as a body accredited by NABCB under the Quality Council of India to ISO 14065 and ISO/IEC 17029, supports and assures the underlying data, but does not by itself replace EU CBAM verification. GreenSutra works as a CBAM consultant that calculates and prepares the data for that verification; it is not itself the accredited verifier.
08

Request a CBAM readiness review for fertilisers

A short conversation about fertiliser products, gas feedstock, export volumes and the European buyers involved turns into a tailored CBAM plan. Schedule a call directly or send a written brief.

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