CBAM and Fertiliser Imports: What Nitrogen Fertiliser Importers Must Know

The fertiliser sector presents some of the most technically complex CBAM calculations. Nitrogen fertiliser production generates two distinct types of greenhouse gas: CO2 from natural gas consumption in ammonia synthesis, and nitrous oxide (N2O) from the Haber-Bosch process and downstream nitric acid production. N2O is a particularly potent greenhouse gas, with a global warming potential approximately 273 times that of CO2 over a 100-year horizon.

Which fertiliser products are in scope

•      Nitric acid

•      Ammonia

•      Ammonium nitrate and calcium ammonium nitrate

•      Mixed nitrogen, phosphorus, and potassium (NPK) fertilisers where nitrogen content exceeds certain thresholds

•      Urea

•      Urea ammonium nitrate (UAN) solutions

The N2O question — the most impactful variable

Nitrous oxide emissions from nitric acid production are often the dominant source of embedded greenhouse gases in nitrogen fertilisers — in some cases representing more than half of the total CBAM-relevant obligation. Producers that have invested in N2O abatement technology — specifically catalytic reduction systems fitted to their nitric acid plants — will have significantly lower embedded emissions than those without.

When assessing suppliers, understanding whether they operate N2O abatement systems is the single most important question. It typically has more impact on the CBAM certificate cost than the energy source for ammonia synthesis.

Supply chain context

A significant proportion of nitrogen fertiliser previously supplied to EU and UK markets originated from Russia. Supply chain disruption has driven diversification towards producers in Egypt, Trinidad, the Middle East, and the United States. The carbon intensity of these alternative sources varies considerably, and N2O abatement capability in particular differs widely across regions. Importers should not assume that a non-Russian supply chain automatically carries lower CBAM risk.

What fertiliser importers should do now

1.    Confirm the CN codes of your fertiliser products against the CBAM scope list.

2.    For each supplier, establish whether their nitric acid plants operate N2O abatement systems.

3.    Request verified monitoring data covering both CO2 and N2O emissions from production.

4.    Factor CBAM certificate costs into fertiliser procurement decisions — the certificate cost per tonne is material at current EU ETS prices.

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