CBAM for Fertiliser Importers: Nitrogen and Ammonia

CN code 3102 covers nitrogenous fertilisers — mineral or chemical fertilisers containing nitrogen. This includes urea (3102.10), ammonium sulphate (3102.21), ammonium nitrate (3102.30), calcium ammonium nitrate (3102.40), and other nitrogenous fertiliser mixtures. CN code 3105 covers mineral or chemical fertilisers containing two or three of the fertilising elements nitrogen, phosphorus and potassium — these are the compound or NPK fertilisers.

CN codes 3103 (phosphatic fertilisers) and 3104 (potassic fertilisers) are excluded from CBAM scope. This means PK fertilisers containing only phosphorus and potassium with no nitrogen content are not covered. The rationale is that nitrogen fertiliser production is highly emissions-intensive — the Haber-Bosch process consumes large quantities of natural gas — while phosphate and potash mining and processing have significantly lower emissions.

Importers of compound NPK fertilisers under 3105 must calculate the embedded emissions of the nitrogen component specifically. The phosphate and potassium components are not subject to CBAM, but the nitrogen component is. This requires understanding the composition of your NPK fertiliser and apportioning emissions to the nitrogen content only.

Ammonia (CN 2814) is a critical precursor for nitrogenous fertilisers. Most nitrogen fertilisers are produced from ammonia via the Haber-Bosch process, which combines nitrogen from the air with hydrogen from natural gas. The ammonia production step accounts for approximately 60-70% of the total embedded emissions of the finished nitrogen fertiliser.

If you import ammonia separately (CN 2814) and use it to produce fertiliser in the UK, the ammonia import is itself a CBAM-covered good. If you import finished fertiliser, the ammonia emissions are embedded in the fertiliser product and included in the fertiliser's emissions data. In both cases, the ammonia precursor emissions must be accounted for.

The production route for ammonia matters significantly. Grey ammonia produced from unabated natural gas has emissions of approximately 1.8-2.0 tonnes CO2e per tonne of ammonia. Blue ammonia with carbon capture reduces this to approximately 0.5-0.8 tonnes. Green ammonia from electrolysis-based hydrogen can achieve near-zero emissions but is currently rare in commercial volumes.

Imports under CN 3103 (phosphatic fertilisers) such as basic slag, superphosphates, and other phosphate fertilisers are excluded from CBAM. Similarly, imports under CN 3104 (potassic fertilisers) such as potassium chloride, potassium sulphate, and other potash-based fertilisers are excluded. If you import only PK fertilisers with zero nitrogen content, you have no CBAM obligation.

However, be careful with blended fertilisers. If you import a physical blend of ammonium phosphate and potassium chloride under 3105, the nitrogen content triggers CBAM coverage even if the blend is primarily PK. The entire product falls under 3105 because it contains nitrogen, and you must report emissions attributable to the nitrogen component.

Oremly's fertiliser importer module handles this automatically. It identifies your fertiliser imports by CN code, determines whether they are in scope, and for NPK fertilisers under 3105, calculates the emissions attributable to the nitrogen component using the correct apportionment methodology.