European Fertiliser Blenders Association

CBAM Position Statement

EFBA calls on the European Commission for an immediate postponement of the Carbon Border Adjustment Mechanism (CBAM) on fertilisers to ensure continuity of product supply to EU farmers for spring 2026 and beyond.

EFBA: Who We Are

European Fertilizer Blenders Association (EFBA) represents national associations whose members are engaged in the importation, production and distribution of fertilisers in France, Germany, Italy, Ireland, Belgium and The Netherlands, and the UK and Switzerland.

Fertiliser Import and Blending Model

Fertiliser importers and blenders operate within long, complex supply chains with raw material procurement often contracted several months in advance of the sale of final product to distributors and farmers. It is imperative to have absolute clarity on costs for the fertiliser sector to function and ensure continuity of supply, particularly given EU reliance on fertiliser imports.

CBAM is unworkable in its current format

Less than three months from implementation, CBAM is a direct threat to continuity of fertiliser supply to farmers from 1st January 2026 onwards due to the following fundamental issues:

CBAM Benchmark and Default Values

The reference values, which are integral to calculating the costs of CBAM, are not yet published. Without these benchmarks the cost of fertiliser at both the point of purchase and the point of sale cannot be determined. This is commercially unworkable.

Certificate Pricing

The European Commission plans to set certificate prices retrospectively in 2027 for 2026 based on a quarterly average of the ETS carbon price. This means that operators will not know the costs of CBAM until after the purchase and sale of products. This is commercially and administratively unworkable and unacceptable.

CBAM creates a high administrative burden and liability of the accuracy of CO2 balance data for fertiliser importers. Difficulties are also emerging in accurate carbon verification by official bodies.

EFBA’s Position on CBAM

EFBA is not engaging in the politics of CBAM. Rather, our call for immediate postponement is based solely on the administrative and economic implications of an unworkable scheme that threatens continuity of fertiliser supply. This threat is real, imminent and already being manifested in very low levels of market activity reported for Q1 2026.

The EU Call for Evidence on three key Implementing Acts for CBAM closed on 25th September 2025. The need for this Call for Evidence and its timing should make it self-evident to the European Commission that they are not ready for CBAM to start on 1st January 2026. To apply CBAM to fertiliser imports from 1st January 2026 threatens market disruption to fertiliser supply and EU food security and therefore implementation must be postponed.