Are organic, phosphate-only and potash-only fertilisers covered by the United Kingdom (UK) Carbon Border Adjustment Mechanism (CBAM)?
Not by heading. HM Revenue and Customs (HMRC) names 3102 and 3105, plus nitric acid, ammonia and potassium nitrate. Headings 3101, 3103 and 3104 are not named. But 3105 also takes packs of 10 kilograms (kg) or less, and HMRC's own example does not match its list.
What HMRC's fertiliser list names
- 2808 00 00: nitric acid and sulphonitric acids.
- 2814: ammonia, anhydrous or in aqueous solution.
- 2834 21 00: nitrates of potassium.
- 3102: mineral or chemical fertilisers, nitrogenous.
- 3105: fertilisers with 2 or 3 of nitrogen, phosphorus and potassium, "other fertilisers", and goods of the chapter "in tablets or similar forms or in packages of a gross weight not exceeding 10 kg".
- Except 3105 60 00: fertilisers with the 2 elements phosphorus and potassium.
Headings not named
3101 is animal or vegetable fertilisers, 3103 is phosphatic and 3104 is potassic. The names are from the UK Trade Tariff, not HMRC's CBAM pages. HMRC's list does not name them, and its rule is that goods in scope are the listed heading and the sub-headings under it. This is the UK list, not the European Union one.
Pack size can change the answer
HMRC's description of 3105 includes goods of the chapter in tablets or in packages of a gross weight not exceeding 10 kg. Our reading, not HMRC's: a phosphatic or potassic product sold in packs of 10 kg or less may classify under 3105, not 3103 or 3104, and so may be named, except 3105 60, which HMRC excludes. The same product in a bulk bag may not be. Confirm the classification with your buyer's customs broker.
HMRC's own example does not match its list
HMRC's fertiliser scope page says: "3101 0000 00 is not listed but is in scope for CBAM, as it falls under 3102." The list on the same page names 3102 and 3105, not 3101, and the page itself explains 3101 as a four-digit heading on its own.
We cannot tell whether HMRC meant 3101 or 3102. Do not rely on the example. HMRC's policy summary gives cbamenquiries@hmrc.gov.uk for operational enquiries, so ask it which code was meant.
What to do
- Get the 8-digit code your buyer will declare, in writing.
- Note the pack size on the invoice, as it can decide the heading.
- For product that is named, look up the default values on our linked pages.
What Senseible does here
Senseible reads fuel invoices and electricity bills into dated, fingerprinted records. It does not set commodity codes or tell you whether a product is in the UK CBAM. Your buyer's customs broker, or HMRC, settles that.
- Fertiliser default values
- Cement and fertiliser: how the figure is expressed
- Gases counted for fertilisers
- Which listed code covers my code
- UK CBAM for Indian exporters
Sources: HMRC, Carbon Border Adjustment Mechanism (CBAM): Policy summary (updated 2 November 2026), HMRC, Check which goods are in scope of CBAM (sector pages, updated 16 July 2026), HMRC, Send HMRC questions about CBAM, UK Integrated Online Tariff, heading names for 3101, 3103 and 3104
Last reviewed 2026-11-07. List checked against the policy summary annex (updated 2 November 2026) and HMRC's fertiliser scope page (updated 16 July 2026). Re-read the fertiliser page to see whether HMRC corrects the example. Pack size reading is ours. Heading names for 3101, 3103 and 3104 are from the UK Integrated Online Tariff.