Mass-balance chain-of-custody not accepted after blending
The European Commission has clarified that blending liquid fertiliser batches from different installations prevents importers from maintaining separate CBAM emissions claims through mass-balance accounting. The clarification applies when batches are combined in the same tank, removing the basis for separate claims tied to different origins.
Liquid fertiliser producers and traders cannot rely on a mass-balance chain-of-custody model to preserve distinct carbon claims once the material is blended. The Commission’s position is set out in its latest clarification on how emissions claims should be handled after mixing.
Weighted-average reporting for mixed batches
When batches of the same liquid fertiliser under the same Combined Nomenclature (CN) code are mixed, embedded emissions must be reported as a weighted average. The applicable functional unit is based on kilograms of nitrogen contained in the goods, rather than only tonnes of product.
The Commission also states that mass balance cannot be used as proof of traceability for this purpose. As a result, emissions reporting reflects the blended outcome rather than separate inputs.
Physical mixing changes what customers can claim
The clarification affects terminals, distributors and producers handling fertilisers from multiple origins. Once batches with different emissions intensities are physically blended, a book-and-claim approach cannot preserve the lower emissions value for a selected customer.
Instead, the CBAM calculation reflects the weighted physical mix relevant to the functional unit. Separate storage can therefore become commercially valuable where suppliers seek to market lower-carbon fertilisers in the EU.
Storage controls and verification requirements
The Commission’s clarification points to operational measures such as dedicated tanks, detailed batch records and installation-specific verification. These steps are described as ways to preserve an emissions distinction that would otherwise be lost through blending.
The requirements also have financing implications for terminals seeking to market differentiated carbon grades. Additional storage capacity and stronger inventory controls may be needed to keep batches separate and preserve their distinct emissions characteristics.
Fertiliser trade context and procurement checks
The clarification arrives as European fertiliser trade continues to face political and commercial pressures. Fertilizers Europe withdrew its anti-dumping complaint concerning Russian urea on 14 October, shifting attention back towards differences in energy, carbon and sanctions-related costs rather than that specific trade-remedy procedure.
For EU importers, procurement checks may need to go beyond the emissions figure stated on a supplier’s certificate. How a product was stored, handled and blended can affect whether its claimed emissions value remains supportable under CBAM rules.
Logistics integrated into carbon accounting
The Commission links carbon accounting for blended liquid fertilisers to physical logistics. Where batches are mixed, the resulting physical composition can determine the emissions value used for CBAM purposes.
The investment case for tank segregation can increasingly be assessed against CBAM-related costs potentially avoided by retaining access to lower actual-emissions values. This connects infrastructure decisions with how blended materials are treated for reporting purposes.