Over the past months, we have repeatedly warned institutions about the drastic impact
that the entry into force of the Carbon Border Adjustment Mechanism (CBAM) for fertilisers
on 1 January 2026 would have, given that many elements required for its calculation remain
unresolved. It appears that the Commission and Member States have heard these concerns
and are now attempting to provide quick fixes on some of these elements, such as
benchmarks and default values. Although we welcome the intention, the reality is that the
secondary legislation published today will not resolve the situation.
We welcome the work on the benchmarks and the setting of the default values, but one of
the key components of the CBAM calculation remain unaddressed: the CBAM carbon
certificate. As long as the platform for CBAM carbon certificates remains unfinished,
planned only for 2027, the CBAM tax will have to be based on the quarterly average CO₂
price following the placing of an order by fertiliser importers. Given that the CO₂ price can
fluctuate significantly over three months, this creates enormous financial uncertainty for
importers who are not in a position to take on such risk.
With only two out of three key factors needed for CBAM calculation clarified, financial
uncertainty for EU fertiliser blenders and importers remains total, preventing them from
placing further orders, while 50% of EU fertiliser supplies come from third countries.
Moreover, aside from the reduction in the mark-up for default values, which is appreciated,
no measures have been proposed to offset CBAM-related costs for farmers. At a time when
many EU arable farmers are facing very low or even negative margins, now for the third
consecutive year in some Member States, due to sharply rising production costs since 2020,
this is simply unacceptable. We call on the Commission, Member States and the European
Parliament to take action.
In this context, we once again jointly call on the European Commission and Member States
to postpone the implementation of CBAM for fertilisers until the following conditions are
met:

1. All technical elements determining CBAM costs are finalised in a way that ensures
full price predictability at the moment of importation and invoicing.
2. Effective measures are put in place to offset CBAM-related costs for farmers,
preventing further cost increases and safeguarding the competitiveness of EU
agriculture and food supply chains.
We cannot afford half measures at a time when the viability of EU agricultural production
is at risk and when the competitiveness and resilience of the wider food chain are being
called into question, with potential consequences for consumer prices.