Blending prevents separate mass-balance CBAM claims
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. The clarification applies when batches are combined in the same tank, according to the Commission.
Liquid fertiliser producers and traders cannot rely on a mass-balance chain-of-custody model to preserve distinct carbon claims after such blending. The Commission’s latest position addresses how emissions information can be carried through the supply chain once physical mixing occurs.
Weighted-average emissions for mixed batches under the same CN code
When batches of the same liquid fertiliser are mixed under the same Combined Nomenclature (CN) code, embedded emissions must be reported as a weighted average. The applicable functional unit is based on kilograms of nitrogen contained in the goods, rather than tonnes of product.
The Commission also states that mass balance cannot be used as proof of traceability for this purpose. As a result, emissions reporting reflects the combined characteristics of the mixed input rather than separate origins.
Physical mixing shifts how lower emissions values can be used
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.
Instead, the CBAM calculation reflects the weighted physical mix relevant to the functional unit. Separate storage is therefore positioned as commercially relevant for suppliers seeking to market lower-carbon fertilisers in the EU.
Storage handling and documentation requirements for CBAM supportability
The Commission’s clarification points to dedicated tanks, detailed batch records and installation-specific verification as tools to preserve emissions distinctions that would otherwise be lost through blending. 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. This includes scenarios where different origins are brought together before import-related reporting.
Financing implications for terminals marketing differentiated carbon grades
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 distinct emissions characteristics.
The investment case for tank segregation can increasingly be assessed against CBAM-related costs potentially avoided by retaining access to lower actual-emissions values. The clarification links carbon accounting for blended liquid fertilisers directly to physical logistics outcomes.
Fertiliser trade pressures continue alongside CBAM compliance focus
The clarification arrives as European fertiliser trade continues to face political and commercial pressures. Fertilizers Europe withdrew its anti-dumping complaint concerning Russian urea on 14 October.
The withdrawal shifts attention back towards differences in energy, carbon and sanctions-related costs rather than that specific trade-remedy procedure. Within this context, CBAM compliance considerations extend to operational handling that can influence reported emissions values.