CBAM fertilizer imports 2026/2027 – CN 3102/3105, 50-tonne threshold and emissions data | Word/PDF/Excel

Does your company import nitrogen fertilizer or other fertilizer products from countries outside the EU? The definitive CBAM period began 1 January 2026. For affected fertilizers, the importer must check CN codes, origin, authorized declarant, and embedded emissions. A particularly important change is the 50-tonne threshold: it applies to the combined net mass of affected goods in fertilizers, cement, iron and steel, and aluminium per importer and calendar year – not 50 tonnes per fertilizer product.

This specialized document package for CBAM fertilizer imports contains ready-made Swedish working templates for commodity code checking, aggregated 50-tonne monitoring, supplier letters on CO₂/N₂O emissions, annual CBAM declaration readiness, and non-compliance and import ban tracking. It also includes a fully functional Excel workbook with nine tabs, a Swedish user guide, and an English User Guide.

What Applies to CN 3102 and 3105?

The Swedish Environmental Protection Agency's commodity code list includes, among others, 2808 00 00 (nitric acid), 2814 (ammonia), 2834 21 00 (potassium nitrate), 3102 (mineral/chemical nitrogen fertilizers) and certain 3105 products. CN 3105 60 00 is exempt from the listed fertilizer sector. For fertilizers, both CO₂ and nitrous oxide (N₂O) may be relevant greenhouse gases. The actual 8-digit CN code, product contents, origin, and customs procedure must be verified. A product name on the invoice is not sufficient for legal classification. See the Swedish Environmental Protection Agency's CN list.

50 Tonnes is a Combined Threshold – Not 50 Tonnes per Fertilizer Shipment

According to amending regulation (EU) 2025/2083, the mass-based de minimis threshold is 50 tonnes per importer and calendar year, aggregated for affected goods in fertilizers, cement, iron/steel, and aluminium. The threshold is only exceeded at more than 50 tonnes. Exactly 50,000 tonnes is therefore not “over 50 tonnes,” but all other applicability conditions must still be checked. Electricity and hydrogen are not included in this 50-tonne aggregation because special rules apply there.

Example: 30 tonnes of covered fertilizer + 25 tonnes of covered aluminium under the same EORI and during the same calendar year = 55 tonnes. This exceeds the threshold even if the fertilizer import alone is only 30 tonnes. The actual legal status and the possibility of further imports must then be investigated. The Swedish Environmental Protection Agency warns of import bans for imports exceeding the threshold without the necessary authorization.

First Annual Declaration and CBAM Certificates 2027

The first annual declaration for the import year 2026 must be submitted no later than 30 September 2027 by the party obliged to declare. The sale of CBAM certificates begins during 2027; the surrender of the relevant number of certificates for 2026 imports must also take place no later than 30 September 2027. The certificate requirement cannot be accurately calculated using a single general price or emissions factor because, among other things, the production method, verification, applicable standard values, EU ETS benchmarks, free allocation, and any carbon price already paid in a third country may have an impact. The Swedish Environmental Protection Agency on CBAM certificates.

File by File

The Excel Workbook: Nine Tabs

Overview, Import Flow, CN Code Check, Suppliers, Emissions Evidence, Authorization, Non-Compliance, Annual Report, and Read Me & Sources. The import flow administratively aggregates the net mass of affected goods under the same EORI and year. The import of electricity or a code classified outside the scope is not included in the mass-based threshold. The control field shows ”MAX 50 TONNES – CHECK EXEMPTIONS”, ”OVER 50 TONNES – MANUAL CHECK”, or a ban/completion flag. No flags mean that a legal declaration, verification, or authorization check has already been performed.

Functionally tested: 30 + 25 tonnes in two sectors gives 55 tonnes; 50,000 tonnes does not exceed the threshold; 50,001 tonnes exceeds the threshold; CN 3105 60 00 can be marked as exempt; and separate electricity imports are not included in the four-sector aggregation. The customer file is without fictitious test imports.

Who Should Use the Package?

Suitable for: Swedish importers/wholesalers of nitrogen fertilizer, ammonia, or other CBAM-covered fertilizer products; procurement and regulatory compliance officers; customs and logistics officers, and companies with both fertilizer imports and other mass-based CBAM goods. Not suitable as: a binding classification decision from Swedish Customs, certified emissions calculation, complete solution for electricity/hydrogen, import authorization, official form, or actual electronic CBAM declaration. For all industries, Mallbutiken offers its broader CBAM Compliance Package; for aluminium profiles, see CBAM Aluminium Profiles.

How to Use the Material

1. Establish the actual legal importer and correct EORI, or alternatively, the responsible indirect customs agent.
2. Check the correct CN/TARIC, actual origin, and whether the goods actually enter free circulation for each product.
3. Check the scope of the goods against Annex I and use the CN code check, especially for 3102, relevant 3105, and exempt 3105 60 00.
4. Record the actual net masses per calendar year and EORI across all four sectors; perform a separate check before planned further imports.
5. If there is a risk of exceeding 50 tonnes, check the actual status as an approved CBAM declarant and import authorization before the goods enter.
6. Send the supplier letter with concrete requirements for the facility, process, CO₂/N₂O, method, and evidence. Document what has not yet been verified.
7. Collect annual data and perform a final legal review; submit the actual declaration and manage certificates in the EU's official register when applicable.

Frequently Asked Questions

Is the 50-tonne threshold per supplier?

No. It is assessed per importer and calendar year and covers the combined affected imports in four sectors. A single fertilizer purchase can therefore not be isolated from the company's other CBAM imports.

Does exactly 50,000 tonnes count as exceeding the limit?

No, not according to the legal limit “exceeds 50 tonnes.” All other CBAM conditions, commodity codes, origin, and importer roles must still be checked.

Are all fertilizer products with CN 3105 covered?

No. Among others, 3105 60 00 is exempt. Always classify the actual product range before calculating and submitting data.

Can I use Excel to purchase CBAM certificates?

No. Excel calculates administrative net weight flags, not a legally correct certificate quantity, certificate price, or purchase in the CBAM register.

Do we need to report 2026 imports during 2026?

The first annual declaration regarding 2026 must be submitted no later than 30 September 2027 according to the current amendment of the CBAM rules, if the importer is covered.

Can we use the supplier's own emissions data?

Data and required verification must follow the applicable methods of the CBAM rules. The letter in the template helps request documentation, but a supplier's signature is not automatically sufficient verification.

Are the PDF files fillable, and are there English documents?

The PDFs are searchable and printable but not interactively fillable. The five working templates and Excel are in Swedish; a separate English User Guide describes how the Swedish documents are used.

Official Sources and Limitations

Regulation (EU) 2023/956 – CBAM and amending Regulation (EU) 2025/2083; The Swedish Environmental Protection Agency on CBAM goods and CN codes; status as an approved CBAM declarant; certificates; The European Commission's sectoral guidance, fertilizer.

The product is an internal documentation and planning package, not an officially approved CBAM form. No file transmits data, performs emissions verification, or provides import authorization. AI-assisted legal source check performed on 10 November 2026. No external independent legal review has been performed. For actual imports, current EU rules, Swedish official requirements, and actual customs data must be checked.