Fertilisers are a core CBAM sector, and for importers of nitrogen products the regime bites hard: ammonia and nitric-acid production are among the most emissions-intensive processes in the chemical industry, and the supply chains often run from regions with limited emissions reporting.
Why fertilisers are in scope
The covered fertiliser goods — including ammonia, nitric acid, urea, ammonium nitrate, and mixed nitrogen fertilisers — are emissions-intensive at production. Ammonia synthesis is energy- and feedstock-heavy (typically natural gas), and nitric-acid production emits nitrous oxide, a potent greenhouse gas. The exact covered list is defined by CN code in Annex I of the regulation, so importers should confirm scope product by product (how CN-code scope works).
The threshold
The 2025 Omnibus simplification set a 50-tonne annual mass-based de minimis per importer. Fertilisers move in bulk agricultural volumes, so commercial importers will generally be over the threshold. As with every covered sector, crossing 50 tonnes at any point in the year pulls all your relevant imports into scope from 1 January of that year.
The data: production-route emissions
The embedded-emissions figure depends heavily on how the product was made — the feedstock, the energy source, and whether the producer abates nitrous oxide. That variability means a single generic number across all your fertiliser imports is usually wrong and usually expensive. Accurate, producer-specific data lowers your obligation, but only if you can collect and evidence it through a structured supplier emissions data process: a clear request, tracked follow-ups, and a visible log of what is still outstanding.
What a clean fertiliser CBAM file looks like
Your first annual CBAM declaration covers 2026 imports and is due 30 September 2027 (full timeline). Build it through the year rather than at the deadline:
- Invoices, customs declarations, and transport documents linked per consignment.
- The CN code and in-scope reasoning for each product.
- Producer emissions data and production route — or a logged gap and the default value applied.
- A traceable line from each declared figure back to a source document.
That is the evidence archive your declarant or adviser signs off against, and your defence against penalty risk.
Where CarbonBorder Desk fits
We handle the operational layer for fertiliser importers: confirming scope, building the shipment register, chasing producer emissions data, tracking gaps, and keeping the evidence archive review-ready. We do not give legal or customs opinions and we do not file declarations — we make the underlying file correct and traceable. Most importers start with a pilot diagnostic.