Our urea plant gets its carbon dioxide from a separate ammonia plant. Which of us counts it for the Carbon Border Adjustment Mechanism (CBAM)?

The Commission's guide says carbon dioxide (CO2) a urea plant receives from another installation counts as an emission unless the plant that made it already counted it, and CO2 from ammonia that ends up in urea is not a deduction. Our reading: it is counted once, at the ammonia plant, and the urea plant adds nothing again.

The shared bill

Think of an electricity bill split between two flatmates. It counts once, whoever pays it. CBAM is the European Union's (EU) charge on the carbon built into imported goods. For CO2 passed from an ammonia plant to a urea plant, the question is the same: make sure it is counted, and counted once.

What the sources say

• Urea boundary: where CO2 is received from another installation as a process input, the CO2 received shall be considered an emission, if not already counted as emission of the installation where the CO2 was produced.
• Questions and Answers 6.3: no discount for CO2 bound in urea; it counts under the ammonia production.
• Fertiliser guide: CO2 consumed in the production of urea has to be considered as being emitted at the installation, because it does not meet the requirements for permanently chemically bound CO2.

Three cases

1. Ammonia and urea on one site as one installation: the CO2 never leaves the installation, so nothing is deducted and nothing is added twice. This is our reading, like case 2.
2. Two separate installations, the ammonia plant counts the CO2 it sends: the urea plant adds nothing for it. This is our reading of the Questions and Answers and the boundary text together.
3. The CO2 comes from an installation that did not count it: the urea plant counts it, as the boundary text says.

What to keep

• Meter readings of the CO2 sent and received, from both ends.
• A written note from the ammonia plant that it counted the CO2 sent.
• Both plants' monitoring plans, so a verifier can see where it was counted.

Counted once, not deducted (example)

• Ammonia plant direct CO2 for the year: 1,800,000 tonnes, of which 500,000 tonnes go by pipe to the urea plant
• Ammonia made: 700,000 tonnes. Counted correctly: 1,800,000 / 700,000 = 2.571 tonnes of CO2 per tonne of ammonia
• Wrongly deducting the urea share: (1,800,000 minus 500,000) / 700,000 = 1.857, which is 0.714 too low
• The urea plant adds none of the 500,000 tonnes again

Example numbers for direct CO2 only, ignoring hydrogen sources and electricity. The guide leaves the handshake between two plants to the monitoring plan.

What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. Reading CO2 transfer meters between plants is custom, on request. Senseible builds the verifier-ready file and checks every figure in-house; an accredited verifier Senseible partners with signs it off, or the client sends it to their own.

• Build your fertiliser CBAM file
• Captured CO2 and the CBAM deduction
• Urea plant gas as feedstock or fuel
• Verifier checks at a fertiliser plant

Sources: European Commission, CBAM Guidance No. 5c, fertilisers (14 August 2026), European Commission, CBAM Questions and Answers

Last reviewed 2026-11-07. Check the fertiliser boundaries in Annex I, points 3.7 to 3.10 and the CO2 transfer rules in Annex II, section B.8 of Implementing Regulation (EU) 2025/2547 with your verifier. The guide says it is not legally binding.