EU CBAM Fertiliser Sector Guidance: Regulations, Monitoring, and Reporting Requirements

August 17, 2026 | Annie Nguyễn

On August 14, 2026, the European Commission published the CBAM guidance documents for the definitive period, including "Guidance Document 5C: Sector-Specific Guidance Document on Fertilisers." This document provides detailed explanations of monitoring and reporting requirements for fertiliser producers outside the EU when exporting to the bloc's market, effective from January 1, 2026.

CBAM Goods and Production Processes

CBAM Goods in the Fertiliser Sector

The CBAM goods covered in the definitive period include the following categories [document, Table 2-1]:

Functional Unit and Emissions

The functional unit for fertilisers is defined as kilograms of nitrogen (N) contained in the product [document, section 2.2.1]. Emissions must be reported as tonnes of CO₂ equivalent per functional unit, calculated separately for each type of goods and by installation or production process in the country of origin [document, section 2.2.2].

Key difference from the transitional period: in the definitive period, both direct and indirect emissions from electricity consumption must be included in the embedded emissions of fertilisers [document, section 2.2.2].

Main Production Processes

The guidance identifies four main production processes [document, section 2.2.3]:

• Ammonia - Haber-Bosch with steam reforming: Uses natural gas or biogas as feedstock to produce hydrogen, then synthesises ammonia. Hydrogen is typically fully integrated in the process, but if externally produced hydrogen is used, its embedded emissions must be accounted for [document, section 2.2.3.1].

• Ammonia - Haber-Bosch with gasification: Uses heavy feedstocks such as coal or heavy oils to produce hydrogen through gasification [document, section 2.2.3.2].

• Nitric Acid: Produced mainly via the Ostwald process – oxidising ammonia in a catalyst to form nitrogen oxide, then converting to nitrogen dioxide and absorbing in water to form nitric acid [document, section 2.2.3.3].

• Urea: Synthesised from the reaction of ammonia and CO₂ at high pressure to form ammonium carbamate, then dehydrated to urea [document, section 2.2.3.4].

• Mixed Fertilisers: Includes various products such as ammonium nitrate, calcium ammonium nitrate, ammonium sulphate, ammonium phosphates, urea ammonium nitrate solutions, and NP, NK, NPK fertilisers [document, section 2.2.3.5].

Monitoring and Reporting Requirements

Emissions to Be Monitored

For the fertiliser sector, the following emissions must be monitored [document, section 3.1.1]:

• Direct CO₂ from fuel combustion (stationary plants only, excluding vehicles)

• Direct CO₂ and N₂O from production processes:

  • In nitric acid production, N₂O emissions from ammonia oxidation and/or NOx/N₂O abatement units (but excluding from fuel combustion)

  • CO₂ transferred from ammonia production to other installations (must be considered as emitted if not meeting permanently chemically bound CO₂ requirements)

• Direct CO₂ from production of measurable heat (steam) and cooling consumed within system boundaries

• Direct CO₂ from emissions control (e.g., from carbonate raw materials like soda ash for acidic flue gas cleaning)

Important note: N₂O emissions are only relevant for nitric acid production. If nitric acid or nitrates (mixed fertilisers) are used as precursors, N₂O emissions are an integral part of embedded emissions [document, section 3.1.2].

Additional Attribution Rules

The guidance sets out important rules [document, section 3.1.2]:

• For fertilisers with kilograms of nitrogen as functional unit and sold in different composition ranges, specific embedded emissions must be averaged using Equation 65:

  • SEE₉₍ₙᵢ₎ = SEE₉ × Nᵢ

  • Where SEE₉ is specific embedded emissions (t CO₂e/kg N) and Nᵢ is the average nitrogen content

• Heat recovered from exothermic chemical processes (like ammonia or nitric acid production) is assigned zero CO₂ emissions [document, section 3.1.2]

• If electricity is produced within the process (e.g., expansion turbines in ammonia production), the emission factor for that electricity is considered zero [document, section 3.1.2]

• For N₂O monitoring, the Commission requires nitric acid producers to use Continuous Emission Measurement Systems (CEMS) at suitable measurement points [document, section 3.1.2]

Additional Reporting Parameters

Producers must provide the following additional parameters to importers [document, section 3.1.3]:

Worked Calculation Example

The guidance provides a calculation example for NPK 15-15-15 mixed fertiliser [document, Section 4]. The example assumes an installation in Türkiye, precursors (ammonia and urea) from Azerbaijan, using CBAM default values for 2026.

Embedded Emissions Calculation for NPK 15-15-15

For an import of 100 tonnes of NPK 15-15-15:

• Total embedded emissions = 100 t × 0.489 t CO₂/t = 48.9 t CO₂

Important Notes on Thresholds and Default Values

• 50-tonne threshold: Importers with total CBAM goods (cement, steel, aluminium, fertilisers) exceeding 50 tonnes per year must register as an Authorised CBAM Declarant. This threshold applies to total mass, not individual products.

• Default values: From 2026, default values have been adjusted, with significant reductions for urea (approximately 39%) and replacement of previous 10%/20%/30% mark-ups with values differentiated by production route.

• Emergency brake mechanism: The Commission may temporarily suspend CBAM for certain goods if it causes "serious injury" to the EU internal market due to price impacts.

Conclusion

Guidance Document 5C is an essential tool for fertiliser producers outside the EU to understand the monitoring, calculation, and reporting requirements under CBAM in the definitive period. Mastering the rules on functional units, system boundaries, emission attribution, and detailed reporting parameters is a prerequisite for compliance and for minimising additional costs when exporting fertilisers to the EU market.

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