The European Commission has clarified that blending liquid fertiliser batches from different installations prevents importers from maintaining separate CBAM emissions claims through mass-balance accounting.
Blending Requires Weighted-Average Emissions
Liquid fertiliser producers and traders cannot use a mass-balance chain-of-custody model to preserve separate carbon claims once batches from different installations are blended in the same tank, according to the European Commission’s latest clarification.
When batches of the same liquid fertiliser under the same Combined Nomenclature (CN) code are mixed, embedded emissions must be reported as a weighted average for the applicable functional unit. For fertilisers, this unit is based on kilograms of nitrogen contained in the goods, rather than simply tonnes of product.
The Commission explicitly states that mass balance cannot be used as proof of traceability for this purpose.
Physical Segregation Preserves Carbon Differentiation
The clarification affects terminals, distributors and producers handling fertilisers from multiple origins. Once batches with different emissions intensities are physically blended, a book-and-claim approach cannot preserve the lower emissions value for a selected customer. The CBAM calculation instead reflects the weighted physical mix relevant to the functional unit.
Separate storage can therefore become commercially valuable for suppliers seeking to market lower-carbon fertilisers in the EU. Dedicated tanks, detailed batch records and installation-specific verification can help preserve the emissions distinction that would otherwise be lost through blending.
European Fertiliser Trade Remains Sensitive
The clarification comes as European fertiliser trade continues to face political and commercial pressures. Fertilizers Europe withdrew its anti-dumping complaint concerning Russian urea on 14 October, shifting attention back towards differences in energy, carbon and sanctions-related costs rather than that particular trade-remedy procedure.
For EU importers, procurement checks may need to extend beyond the emissions figure stated on a supplier’s certificate. How a product was stored, handled and blended can affect whether its claimed emissions value remains supportable under CBAM rules.
Storage Infrastructure Becomes a Carbon-Cost Consideration
The requirements also have financing implications for terminals seeking to market differentiated carbon grades. Additional storage capacity and stronger inventory controls may be needed to keep batches separate and preserve their distinct emissions characteristics.
The investment case for tank segregation can increasingly be assessed against the CBAM costs potentially avoided by retaining access to lower actual-emissions values.
The clarification makes physical logistics an integral part of carbon accounting for blended liquid fertilisers. Where batches are mixed, the resulting physical composition can determine the emissions value used for CBAM purposes.
