Is technical-grade urea or diesel exhaust fluid covered by CBAM?
Urea is covered under CN 3102 10 whether or not in aqueous solution, so fertiliser, technical and automotive grades are in when declared there. Diesel exhaust fluid is often classified elsewhere, so check its code. Fertilisers count direct and indirect emissions. CO2 bound in urea is not subtracted.
Is it covered?
Annex I covers all of heading 3102, which includes urea under 3102 10, whether or not in aqueous solution. Grade or end use does not change that. Diesel exhaust fluid is a urea solution that customs may classify under 3102 10 or under a chemical preparation code; the code on the EU declaration decides coverage.
Precursors to report
- Ammonia (2814), with its maker's embedded emissions, or your own figure if you make it.
- Carbon dioxide used in the urea reactor is not a CBAM good.
Default value
The Commission sets default values by CN code and country of origin in the annex to Implementing Regulation (EU) 2025/2621, with a mark-up that rises over the first years. We do not quote the figure here. Open the annex, find your code and India, and treat it as the number your buyer pays on if you send nothing usable.
What to send your EU importer
- Direct embedded emissions per tonne of urea, from fuel, feedstock and process.
- Electricity used per tonne and its source, because fertiliser goods count indirect emissions too.
- Each precursor's embedded emissions per tonne and its supplier if bought in.
- Whether a verifier accredited for CBAM has checked the figure.
The common mistake
Subtracting the CO2 captured into the urea molecule. The CO2 bound in urea is released when the urea is used, so it is not deducted from the producer's direct emissions. Report the ammonia plant's process CO2 in full.
What Senseible does here
Senseible reads fuel, electricity and purchase invoices into dated, fingerprinted installation records, the starting point for the actual emissions an EU importer asks for. It does not file CBAM declarations or verify emissions.
- Check if a CN code is covered
- Urea and DAP under CBAM
- A urea plant's CBAM figure
- Where official default values sit
Sources: Regulation (EU) 2023/956, Annex I (consolidated), Implementing Regulation (EU) 2023/1773, methods and precursors, Implementing Regulation (EU) 2025/2621, default values, European Commission, CBAM definitive regime
Last reviewed 2026-10-23.