CBAM by sector
CBAM and Fertilisers
Fertilisers are one of the six sectors covered by the EU Carbon Border Adjustment Mechanism (CBAM). If you import nitric acid, ammonia, nitrates, urea or mixed fertilisers, you may have CBAM obligations once your annual imports cross the 50-tonne threshold. For fertilisers, both direct and indirect emissions are counted. This page explains what is covered and what to do.
Fertilisers
Direct + indirect emissions · 50 t threshold
TL;DR
- Fertilisers are in scope under Regulation (EU) 2023/956, defined by the CN codes in Annex I.
- Covered products include nitric acid, ammonia, nitrates, urea and mixed (NPK-type) fertilisers.
- Both direct and indirect (electricity) emissions are counted for fertilisers.
- Fertilisers count toward the cumulative 50-tonne annual de-minimis threshold; importers under 50 tonnes/year of covered goods are exempt.
In scope
What CBAM covers for fertilisers
- Nitric acid and sulphonitric acids.
- Ammonia (anhydrous or in aqueous solution).
- Nitrates, including potassium nitrate and other nitrate-based products.
- Urea.
- Mineral or chemical nitrogenous fertilisers and mixed (multi-nutrient, NPK-type) fertilisers.
Annex I lists each product by its CN code, so confirm scope by matching your customs code rather than the general product description.
These products are listed in Annex I of Regulation (EU) 2023/956 by their CN code, so you confirm scope by matching your product code, not the product name alone. Use the goods & CN-code reference to check a specific code.
Emissions
How embedded emissions are counted
Both direct and indirect emissions are counted. For fertilisers, CBAM counts both direct emissions from production and indirect emissions from the electricity consumed in making the goods. This wider boundary reflects the energy-intensive ammonia and nitric-acid chemistry behind nitrogen fertilisers. Regulation (EU) 2023/956
Actual, verified emissions data is preferred and usually cheaper than the conservative default values. Where you cannot get verified figures, you can fall back to the published default values, which carry a mark-up. See the CBAM default-values reference for the figures and mark-up rates.
The 50-tonne threshold
Does the de-minimis exemption apply?
Fertilisers counts toward the 50-tonne threshold
The hard part
The hard part for fertilisers
- Both direct and indirect emissions count, so you need a fuller emissions picture than for steel or aluminium.
- Complex chemical chains (ammonia → nitric acid → nitrates/urea → mixed fertilisers) make installation-level data harder to assemble.
- Default values for fertilisers carry a smaller mark-up (around 1%) than other sectors, but using actual data still requires verification. [VERIFY exact mark-up against the implementing regulation on default values.]
- Tracking cumulative tonnage across all four mass-counted sectors to know when you cross 50 tonnes.
What to do
What to do for fertilisers
- Confirm scope by matching every fertiliser and precursor (ammonia, nitric acid) product line against the CN codes in Annex I.
- Add up your annual net mass across steel, aluminium, cement and fertilisers to see whether you cross the 50-tonne threshold.
- Gather both direct and indirect emissions data from suppliers, or use the published default values (lower mark-up for fertilisers).
- If you import above the threshold, become an authorised CBAM declarant (or use an indirect customs representative who is) via the CBAM Registry.
- Gather embedded-emissions data from your suppliers, or fall back to the published default values, then file your annual CBAM declaration and surrender certificates by 30 September of the following year.
For the roles and how to apply, see the CBAM declarant guide; for when you need a verifier, see CBAM verification; and for collecting data from suppliers see the supplier data guide.
FAQ
Fertilisers and CBAM: common questions
- Is urea covered by CBAM?
- Yes. Urea is listed among the in-scope fertiliser products in Annex I of Regulation (EU) 2023/956, alongside ammonia, nitric acid, nitrates and mixed fertilisers. Confirm your specific product by its CN code.
- Are both direct and indirect emissions counted for fertilisers?
- Yes. Fertilisers are one of the two sectors (with cement) where CBAM counts both direct emissions from production and indirect emissions from the electricity used in production.
- Is there a fertiliser exemption under CBAM?
- There is no fertiliser-specific exemption, but fertilisers count toward the cumulative 50-tonne annual mass threshold. If your combined annual imports of steel, aluminium, cement and fertilisers stay at or below 50 tonnes, you are exempt from the main obligations.
- When do fertiliser importers have to comply with CBAM?
- The definitive period began on 1 January 2026. If your annual imports cross the 50-tonne threshold you must be (or use) an authorised CBAM declarant. The first annual declaration and surrender for 2026 imports is due 30 September 2027.
Get ready for CBAM
Work through the CBAM Readiness Checklist, then explore the tools and guides built for your role.
This is guidance, not legal advice
Sources
- [1]Regulation (EU) 2023/956, consolidated text including Annex I (EUR-Lex)retrieved 8 Jun 2026
- [2]European Commission (DG TAXUD): Carbon Border Adjustment Mechanismretrieved 8 Jun 2026
- [3]DG TAXUD: Simplifications for CBAM (Regulation (EU) 2025/2083)retrieved 8 Jun 2026
- [4]EUR-Lex: Carbon Border Adjustment Mechanism (summary)retrieved 8 Jun 2026
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