UK CBAM for Fertilisers — What Polish Exporters Need to Know

Fertilisers in the Proposed UK CBAM — Scope and HS Codes

Understanding which products are in scope is the essential first step for Polish fertiliser exporters.

Which fertiliser products are proposed to be covered

UK CBAM (Finance Act 2026) covers the following fertiliser categories (exact HS sub-headings will be confirmed in HMRC implementing regulations):

• HS 3102 — Mineral or chemical fertilisers, nitrogenous (ammonium nitrate, urea, calcium nitrate)
• HS 3103 — Mineral or chemical fertilisers, phosphatic (superphosphates)
• HS 3104 — Mineral or chemical fertilisers, potassic
• HS 3105 — Mineral or chemical fertilisers containing two or three elements (compound/complex NPK fertilisers)

Ammonia (HS 2814) is also covered under UK CBAM. Exact sub-headings and product exclusions will be confirmed in HMRC implementing regulations. Source: Finance Act 2026; gov.uk/government/collections/carbon-border-adjustment-mechanism. This article reflects the legal position as of 2026-04-18. Implementing regulations are evolving — contact a customs broker before taking any action.

Why fertilisers are carbon-intensive — the policy rationale

Nitrogen fertilisers are among the most carbon-intensive industrial products. The Haber-Bosch process for producing ammonia (the building block of most nitrogen fertilisers) requires hydrogen — currently derived primarily from natural gas through steam methane reforming, which generates approximately 1.6–2.0 tonnes of CO2 per tonne of ammonia. The entire fertiliser sector accounts for approximately 1–2% of global energy consumption and a corresponding share of industrial CO2 emissions. The CBAM rationale for fertilisers is therefore straightforward: to prevent 'carbon leakage' where fertiliser production migrates to countries with lower carbon costs. Polish fertiliser producers operating under the EU ETS (European Union Emissions Trading Scheme) already pay a carbon price on their emissions — this existing carbon cost would be taken into account when calculating the UK CBAM charge, preventing double-charging.

Interaction with EU CBAM (already in force) and UK CBAM (proposed)

Polish fertiliser exporters face two separate CBAM frameworks depending on the direction of trade:

Exporting to the EU (domestic Polish sales or EU sales): not subject to CBAM — EU CBAM applies to imports from third countries, and Poland is an EU Member State.

Importing from the UK to Poland: EU CBAM (Regulation (EU) 2023/956) already applies to UK-origin fertilisers entering Poland. Polish importers of UK fertilisers are already in the EU CBAM transitional phase (since October 2023) and must be aware of their existing reporting obligations.

Exporting from Poland to the UK: subject to the proposed UK CBAM once enacted (proposed start: 1 January 2027). Until the enabling act passes, no obligation exists. This is the scenario this article addresses.

Embedded Carbon Methodology for Fertilisers

UK CBAM (Finance Act 2026) comes into force 1 January 2027. UK importers will need to declare the embedded carbon content of each shipment. Polish exporters will need to provide this data.

What 'embedded carbon' means for fertilisers

Embedded (or embodied) carbon is the total greenhouse gas emissions associated with producing a tonne of fertiliser, measured in tonnes of CO2 equivalent (tCO2e). For nitrogen fertilisers, this includes: (1) direct process emissions at the production facility (Scope 1) — primarily from the steam reforming of natural gas and from the catalytic oxidation of ammonia; (2) indirect emissions from purchased electricity used in production (Scope 2); and in some frameworks, (3) upstream emissions from natural gas extraction (Scope 3). The proposed UK CBAM methodology is expected to be broadly aligned with the EU CBAM methodology (Commission Implementing Regulation (EU) 2023/1773), which requires calculation of direct emissions (Scope 1) and, for some sectors including fertilisers, indirect emissions from electricity (Scope 2).

Default emission values vs installation-specific data

Under the EU CBAM framework (and expected to be similar under UK CBAM), importers can declare either: (1) installation-specific emission data, verified by an accredited verifier; or (2) default emission values published by the CBAM authority for the relevant sector and country of origin. Default values are typically set at a level higher than the best-performing installations — using installation-specific data is therefore financially advantageous for efficient producers. Polish fertiliser producers with modern, efficient plants (including those using natural gas with low carbon intensity or with process optimisation investments) should invest in installation-specific data collection and verification now, to reduce their UK CBAM exposure once the mechanism is enacted.

Practical steps for Polish fertiliser exporters

Recommended actions now that UK CBAM has been enacted (Finance Act 2026, in force 1 January 2027): (1) confirm the HS codes of your fertiliser products are within the covered scope; (2) calculate or commission a carbon footprint assessment for your main fertiliser products using the EU CBAM methodology as a reference — this data will transfer to UK CBAM with minimal adjustment; (3) engage with your UK buyers to discuss data sharing requirements and CBAM adjustment clauses in contracts; (4) monitor HMRC implementing regulations through gov.uk/government/collections/carbon-border-adjustment-mechanism and industry bodies (e.g. The Fertiliser Manufacturers' Association or equivalent). Easy Clearance can assist with customs documentation and declarations. Contact us: WhatsApp +44 7404 091503. This article reflects the legal position as of 2026-04-18. Implementing regulations are evolving — contact a customs broker before taking any action.

What the current rules say

UK CBAM was enacted through the Finance Act 2026 and covers fertilisers (HS 3102–3105 and ammonia HS 2814) from 1 January 2027. Polish fertiliser exporters to the UK should now: confirm their products' HS codes and in-scope status; calculate embedded carbon using EU CBAM methodology as a template; discuss data sharing and CBAM adjustment clauses with UK buyers; and monitor HMRC implementing regulations. This article reflects the legal position as of 2026-04-18. Implementing regulations are evolving — contact a customs broker before taking any action.

FAQ — frequently asked questions

Are Polish fertiliser exports to the UK subject to CBAM?

Yes, from 1 January 2027. UK CBAM was enacted through the Finance Act 2026. Polish fertiliser exporters to the UK should now prepare for forthcoming obligations — HMRC implementing regulations specifying registration and reporting details will be published in 2026. Monitor gov.uk/government/collections/carbon-border-adjustment-mechanism.

Which fertilisers are included in the proposed UK CBAM?

Proposed covered fertiliser codes: HS 3102 (nitrogenous), HS 3103 (phosphatic), HS 3104 (potassic), HS 3105 (compound/complex NPK). Also proposed: ammonia (HS 2814). Exact sub-headings will be confirmed in secondary legislation.

How is embedded carbon calculated for fertilisers?

The UK CBAM is expected to follow the EU CBAM methodology: direct process emissions (Scope 1) plus indirect emissions from electricity (Scope 2). For nitrogen fertilisers, the main emission source is the Haber-Bosch process for ammonia production. Installation-specific verified data gives more accurate (typically lower) figures than default values.

Does the EU ETS carbon cost paid by Polish producers count against UK CBAM?

Yes — the UK CBAM mechanism is designed to prevent double-charging. If a Polish producer already pays a carbon cost under the EU ETS equivalent to or greater than the UK ETS price for the goods' embedded carbon, no additional UK CBAM charge would apply. The exact calculation methodology will be confirmed in UK secondary legislation.

Official sources

• UK Carbon Border Adjustment Mechanism — GOV.UK
• EU CBAM — Regulation (EU) 2023/956 — EUR-Lex
• EU CBAM implementing regulation (EU) 2023/1773 — EUR-Lex