Fertilisers

Your business imports ammonium nitrate or urea for farm supply, compound fertilisers for blending, ammonia for refrigeration or water treatment, or nitric acid for metal finishing. The list is a nitrogen list: every entry is either a nitrogen compound or a fertiliser whose nitrogen is the reason it is caught. Two entries catch businesses that never sell fertiliser. Ammonia under heading 2814 is caught whether it is bound for a fertiliser plant, a refrigeration system or a water treatment works, and nitric acid under 2808 00 is caught whether it is bound for a nitrate plant or an electroplating line. The Table looks at the commodity code and not at the use.

Retail packs are covered. Heading 3105 expressly includes goods of chapter 31 in tablets or similar forms or in packages of a gross weight not exceeding 10 kilograms, so there is no small-pack exemption.

The system boundary and the gases

Table 1c of the System Boundaries Document maps the entries to four categories: nitric acid, ammonia, urea for 3102 10, and mixed fertilisers for the rest of 3102, for 2834 21 and for 3105 except 3105 60. Nitrous oxide counts alongside carbon dioxide for nitric acid and mixed fertilisers, and regulation 8 of SI 2026/995 converts one tonne of nitrous oxide into 265 tonnes of carbon dioxide equivalent. Point 3.8 requires monitoring of every source of nitrous oxide from nitric acid production, abated and unabated, so a plant with abatement and one without will show very different intensities, and because nitric acid is the precursor for the nitrate fertilisers the difference flows into every product made from it.

Point 3.9 sets the boundary for ammonia by the steam reforming and the gasification routes, with all fuels counted whether used as energy or as feedstock and with separately produced hydrogen as a precursor where used. Point 3.11 covers urea, where carbon dioxide received from another installation as a process input is treated as an embodied emission, with ammonia as the precursor. Point 3.10 covers mixed fertilisers, whether made by mixing, neutralisation, granulation or prilling, with ammonia, nitric acid, urea and mixed fertilisers as the precursors where used. The chain for a bag of ammonium nitrate therefore runs from mixed fertilisers back to nitric acid and ammonia, and a compound plant that buys from three installations carries three precursor intensities.

Nitrogen content is the figure to hold

The document provides that for fertilisers the kilograms of nitrogen contained in the goods constitute the functional unit, so a supplier's intensity is per unit of nitrogen. Regulation 5(4) and (5) of SI 2026/995 then apply a conversion equation set out in a Treasury notice to produce the intensity per tonne of the good as imported, and the guidance note on mixed fertilisers requires the nitrogen in the product to be recorded by form, as ammonium, as nitrate, as urea and in other organic forms. As at 13 September 2026 no Treasury notice under regulation 5(5) had been published. HMRC's draft Emissions and Verification notice of 9 September 2026 contains conversion equations that multiply the intensity per unit of nitrogen by the nitrogen content of the goods; the draft notice does not currently have force of law and is due to take effect when commenced on 1 January 2027. Whether the nitrogen functional unit or tonnes of product applies to ammonia and nitric acid, which are sector goods rather than fertilisers, is a matter for the notice.

Regulation 4 of SI 2026/802 fixes the weight as net of packing at the time of import. Aqueous ammonia and urea ammonium nitrate solutions are declared at the weight of the solution as imported. Carbon price relief applies where the plant sits in a jurisdiction with a qualifying scheme and form CarbonVP1 can be obtained, and regulation 12(3) of SI 2026/809 requires a separate effective carbon price for each precursor from another jurisdiction.

Questions for a fertiliser supplier

For an ammonia plant: which production route, are all fuels counted as feedstock and as energy, and is any hydrogen bought in counted as a precursor. For a nitric acid plant: does the intensity include every source of nitrous oxide, abated and unabated, and is the ammonia precursor counted as 100 per cent ammonia. For a urea plant: is any carbon dioxide received from another installation counted as an embodied emission. For a mixed fertiliser plant: which precursors were used and from which installations, and is the nitrogen content of each product recorded by form. For every supplier of a fertiliser: what is the nitrogen content of each grade shipped. For every supplier in a jurisdiction with a carbon price: can form CarbonVP1 be completed for each installation in the chain.

The check to run

Take the twelve months of customs declarations for goods under 2808 00, 2814, 2834 21, 3102 and 3105, sort them by eight-digit code, and set against each the category from Table 1c, the gases that count, the functional unit and the installation. Lines under 2814 need an ammonia plant's figure. Lines under 2808 00 need a nitric acid plant's figure with nitrous oxide in it. Lines under 3102 10 need a urea plant's figure with any imported carbon dioxide counted. Lines under the rest need a mixed fertiliser plant's figure with every precursor traced and the nitrogen content of the product by form. Chapter 26 of UK CBAM for Importers sets out the sector in full.