A group of farmers, agri-cooperatives, food processors, traders and fertiliser blenders have said that the small tweaks to the CBAM tax calculation formula introduced “will not prevent the risk of fertiliser shortages or the prohibitive production costs threatening EU crop production”.

The group includes Copa Cogeca, an umbrella organisation representing European farmer organisations, the European Landowners' Organization (ELO), and the European Fertiliser Blenders Association (EFBA), among others.

The statement said: “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 January 1, 2026 would have, given that many elements required for its calculation remain unresolved.

“Although we welcome the intention, the reality is that the secondary legislation [published on December 10] will not resolve the situation.”

CBAM carbon certificate

The group says that it welcomes the work on the benchmarks and the setting of the default values, but adds that “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 (carbon dioxide) CO₂ price following the placing of an order by fertiliser importers," the statement said.

“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.”

‘Uncertainty’

The statement warned of "financial uncertainty", saying: “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."

The statement said, at a time when "many EU arable farmers are facing very low or even negative margins, due to sharply rising production costs since 2020, this is simply unacceptable".

The group jointly called on the European Commission and member states to postpone the implementation of CBAM for fertilisers until the following conditions are met:

All technical elements determining CBAM costs are finalised in a way that ensures full price predictability at the moment of importation and invoicing;
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," the statement said.

Other members of the group include: the European Association of Industrial Bakers; European Association of Sugar Manufacturers; European Confederation of Maize Production; International Confederation of European Beet Growers; Coceral; European Flour Millers; European Oilseed Alliance; and Primary Food Processors.