CN 3102Covered by CBAMFertilisers

CN 3102 under CBAM — Nitrogenous Fertilisers (Urea)

Mineral or chemical fertilisers, nitrogenous (including urea)

Nitrogenous fertilisers — urea (CN 3102 10), ammonium nitrate, ammonium sulphate, CAN and related products. India runs some of the world’s largest urea capacity, and while domestic demand dominates, export parcels and the heading’s coverage make CN 3102 the fertiliser exporter’s CBAM reference point.

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Covered

CBAM status of this heading

1 Jan 2026

Definitive phase — certificates due

€70–80

per tCO₂ — certificate price tracks EU ETS

up to ~40%

typical cost cut with verified actuals

Emission profile

Where the emissions in CN 3102 come from

A nitrogen fertiliser’s number is mostly its ammonia precursor — itself set by feedstock (gas at modern plants versus naphtha at older ones) — plus process energy for synthesis, prilling or granulation. Typical Indian urea runs 1.0–1.5 tCO₂/t, with CO₂ bound into the urea molecule credited under the methodology. The EU default value for this heading is deliberately conservative; efficient gas-based Indian production has a genuinely better story that only verified actuals put on record.

Why we don’t print a default value here

The EU publishes and updates specific default values per goods category separately — quoting a stale number would mislead you. What never changes: defaults are set deliberately high, and the markup escalates from 10% in 2026 to 30% by 2028 for steel and aluminium (free-allowance phase-out runs to 2034). Use the CBAM calculator for a current, product-specific estimate.

What to do

Exporting under CN 3102? Three moves, in order.

01
Identify your production route and precursors
Map the chain: own ammonia (document feedstock and energy intensity) or purchased (a precursor), CO₂ recycling into urea synthesis, and the finishing route (prilling vs granulation).
02
Collect the data you already have
Ammonia plant or purchase data, urea-plant energy balances, CO₂ transfer records, prilling/granulation utility data, production logs by product.
03
File verified actuals, not defaults
Have the numbers computed to the EU CBAM methodology and verified, then hand your EU buyer’s Authorised Declarant a filing they can use. Verified actuals typically cut the CBAM cost by up to ~40% versus default values — and the default markup only gets worse, escalating from 10% in 2026 to 30% by 2028 for steel and aluminium.

Free this quarter: We cover your first report (April–June 2026) so an inflated EU default never costs you an order. Continue only if you choose to. Free for the April–June 2026 quarter — start your report by 30 September 2026.

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Frequently asked

CN 3102 and CBAM, in plain English

Is CN 3102 covered by CBAM?

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Yes. CN 3102 — nitrogenous mineral or chemical fertilisers, with urea at subheading 3102 10 — is a covered good under the EU Carbon Border Adjustment Mechanism. Any consignment under this heading imported into the EU has carried reporting obligations since the transitional phase (1 October 2023 – 31 December 2025), and since the definitive phase began on 1 January 2026 the EU importer must buy CBAM certificates against its embedded emissions. Ammonium nitrate, ammonium sulphate and CAN fall under the same heading’s coverage.

How much CBAM cost does CN 3102 face in 2026?

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CBAM certificates track the EU ETS carbon price — roughly €70–80 per tonne of CO₂ in 2026 — so the bill is your embedded emissions multiplied by that price. For nitrogen products the bill is dominated by ammonia’s feedstock (gas vs naphtha) and, for nitric acid routes, by N₂O abatement — so plants with modern configurations have far more to gain from filing verified actuals, which typically cut the cost by up to ~40% versus defaults.

Urea locks CO₂ into the product itself. Does that lower the CBAM figure?

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It does — CO₂ captured from ammonia production and chemically bound during urea synthesis is credited under the EU methodology, which is part of why typical Indian urea lands around 1.0–1.5 tCO₂/t despite ammonia’s energy intensity upstream. As always, the credit is only real in a verified filing built on plant records of the CO₂ transfer; defaults assume the conservative case and grant nothing.

Our ammonium sulphate is a by-product of another process. How is that treated?

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By-product and co-production routes are handled by the methodology’s attribution rules — emissions are allocated across products of the installation according to defined procedures rather than dumped onto one product. The outcome can be very favourable for genuine by-product fertilisers, but it must be computed and verified, not asserted. This is a case where expert methodology work visibly changes the filed number.

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