CBAM and Fertiliser Imports: What Nitrogen Fertiliser Importers Must Know

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

Which fertiliser products are in scope

•      Nitric acid

•      Ammonia

•      Ammonium nitrate andcalcium ammonium nitrate

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

•      Urea

•      Urea ammonium nitrate (UAN)solutions

The N2O question — the most impactful variable

Nitrousoxide emissions from nitric acid production are often the dominant source ofembedded greenhouse gases in nitrogen fertilisers — in some cases representingmore than half of the total CBAM-relevant obligation. Producers that haveinvested in N2O abatement technology — specifically catalytic reduction systemsfitted to their nitric acid plants — will have significantly lower embeddedemissions than those without.

Whenassessing suppliers, understanding whether they operate N2O abatement systemsis the single most important question. It typically has more impact on the CBAMcertificate cost than the energy source for ammonia synthesis.

Supply chain context

Asignificant proportion of nitrogen fertiliser previously supplied to EU and UKmarkets originated from Russia. Supply chain disruption has drivendiversification towards producers in Egypt, Trinidad, the Middle East, and theUnited States. The carbon intensity of these alternative sources variesconsiderably, and N2O abatement capability in particular differs widely acrossregions. Importers should not assume that a non-Russian supply chainautomatically carries lower CBAM risk.

What fertiliser importers should do now

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

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

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

4.    Factor CBAM certificatecosts into fertiliser procurement decisions — the certificate cost per tonne ismaterial at current EU ETS prices.

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