Frontier Agriculture is calling for a collaborative and considered approach to new fertilisers regulations in the UK, highlighting the importance of keeping fertiliser supplies reliable and affordable for growers at a time of increasing pressure on UK food production.

Following Frontier’s response earlier this year to the Government’s proposal for new UK Fertilising Product Regulations (UK FPR), the company’s experts are also calling for a review of proposed tariff reforms, and of the Carbon Border Adjustment Mechanism (CBAM) coming in January 2027.

UK FPR welcomed but it must be proportionate

In its response, Frontier recognised that a renewed fertiliser regulatory framework is due and welcomed the move to replace outdated legislation with a single UK-wide framework. However, the business stipulated that its support was conditional; stressing that any reform must not compromise product availability or affordability, cause trade barriers, or result in overly complex compliance rules in what is already a volatile market, as this would ultimately increase costs and reduce choice for growers, with implications for the resilience of UK food production.

Drawing on its day-to-day work with growers, manufacturers, suppliers and the wider food supply chain, Frontier highlighted several areas that will be critical if the new regulations are to work in practice:

• Protect supply and availability: New rules or regulatory gaps through the transition period must not remove existing products or disrupt supply and mustn’t create trade barriers (e.g. through certification delays or rigid UK-specific requirements), given the UK’s reliance on imported fertiliser product.

• Maintain a level playing field: Regulations should support fair competition and an open and efficient market for the UK. There should be no bias between different product groups; with alignment to the EU FPR where possible to avoid duplication.

• Keep rules proportionate: Overly prescriptive or rigid regulations will cause problems across the supply chain, including for growers.

• Avoid added cost and complexity: Reforms must not create additional administrative burdens. For example, conformity assessments should be simple and affordable, with concerns around extra testing, laboratory accreditation and delays to market addressed first.

• Provide long-term certainty: Regulations should support innovation and the introduction of new products (e.g. low carbon fertiliser) with clear, science-based definitions and approval pathways.

• Limit nutrient restrictions: Introducing fixed minimum or maximum levels could distort formulations or encourage unnecessary nutrient additions in order to comply.

• Ensure practical labelling: Labelling rules must be flexible, proportionate and workable. EU-labelled products should be recognised to avoid an automatic re-labelling requirement with zero benefit. Labelling must not restrict availability or be disproportionate in cost for different products too – especially for bespoke blends where there will be many variations.

• Apply proportionate enforcement – new regulations should be fair, consistent, not revenue-driven, and informed by existing, established industry expertise such as the Agricultural Industries Confederation (AIC).

Careful consideration needed for temporary tariff suspensions on agricultural and food products

Frontier’s experts have also shared views on the Government’s proposal to temporarily suspend tariffs on selected agricultural and food products in a bid to combat rising costs.

The Government has stipulated that a shorter, more targeted suspension is being considered for fertilisers in recognition of their strategic role in food production, but urea ammonium nitrate (UAN) is currently excluded from this list.

Frontier is supportive of the Government’s attempts to address rising costs, recognising that price reductions would help growers at a time when the cost of production is incredibly high.

However, the company has also highlighted that the majority of imported fertiliser to the UK comes from countries where such tariffs are not currently applied. Where they are, Frontier has warned that any temporary suspension must be consistent across products; a move that the AIC is also lobbying for in relation to the decision for UAN.

Beyond fertiliser specifically, Frontier’s response also recognises that suspended tariffs on food products could unintentionally undermine domestic food production and therefore long-term food-security – a concern also shared by the National Farmers’ Union (NFU).

As it stands, the Government is still gathering feedback from industry stakeholders, including fertiliser suppliers and distributors. Overall outcomes will be shaped by the perceived market impact, supply chain needs and broader economic and trade considerations.

CBAM uncertainties

As well as the proposals above, in the here-and-now many conversations on-farm around fertiliser and crop nutrition include the upcoming Carbon Border Adjustment Mechanism (CBAM), sometimes described as a ‘fertiliser tax’.

Set to take effect in the UK from 1st January 2027, CBAM is designed to address the impacts of the emissions trading schemes (EU ETS and UK ETS), which increase costs for high-emission industries in the UK and EU.

By applying a carbon cost to imports based on their emissions, CBAM aims to create a level playing field between domestic and imported products while encouraging decarbonisation globally. It also applies more widely beyond fertilisers, covering sectors such as iron and steel, cement, aluminium and hydrogen.

However, because the UK no longer produces ammonia domestically, the costs associated with CBAM will ultimately be felt across imported nitrogen fertiliser. While the policy is well intentioned, Frontier, alongside many other industry organisations, is concerned this could increase costs and uncertainty for farm businesses, placing further pressure on UK food production and raising the risk of cheaper imports from countries that do not face equivalent carbon costs.

The calculation

 There are three factors that make up the CBAM sum:

• Carbon cost – fixed quarterly based on the average price of the UK ETS for the previous quarter.

• Embedded emissions of the product – either independently verified or a default figure if unknown.

• Free allowance – in essence a discount that will likely start high to reduce to 0% in nine years’ time.

The challenges

Frontier recognises the challenges associated with the CBAM implementation, recommending the Government revisits and reviews the regulation; specifically the removal of fertiliser given the UK’s production infrastructure.

The company notes that:

• The UK has limited domestic fertiliser manufacturing: meaning every tonne of nitrogen fertiliser in the UK will have CBAM applied to it after 1st January 2027. This creates additional financial strain for growers, raising the cost of production which will ultimately affect food prices.

• Costs remain unclear: Although the Government suggests CBAM rates may be lower than anticipated; actual costs won’t be clear until October 2026 and could  rise significantly every 12 months until the free allowances disappear. That’s if the rate of decarbonisation of fertiliser doesn’t match these reductions, which presents real uncertainty for food production costs.

• A difficult transition: the early years of CBAM will be difficult, with impacts felt across the entire food supply chain.

• Need for grower support: The Government should consider EU-style compensation schemes for growers when fertiliser prices rise to a certain threshold, but should take into account the breakeven-ratio to ensure fertiliser costs and the market value of a crop are taken into consideration.

Helping growers navigate the change

Based on the information currently known to the industry, Frontier’s experts are advising growers to make cautious decisions aligned to their business needs.

Ed Downing explains: “Decisions should not be based solely on CBAM but, given the direction from the Government so far, it has to be factored into plans as a whole.

“Fundamentally, if buying fertiliser now is the right decision based on the market then it will also avoid any CBAM cost, helping to further reduce some risk in the short-term. But it really comes down to the individual farm.

“Although the Government has implied that initial values will be modest, uncertainty around longer-term cost increases remain. Growers are making decisions today that will affect crops, investment and business performance months or even years down the line. Greater certainty is essential if they are to plan with confidence.”

A need for resilience and fairness in the UK fertiliser market

Given the ongoing challenges faced by the agricultural industry, specifically relating to fertiliser supply, Frontier joins other organisations such as the AIC and NFU in calling for further action from the Government.

Securing a resilient, accessible and affordable fertiliser supply is critical to a productive and sustainable UK food system. Achieving this requires Government, industry and the wider food supply chain to work together. Growers need confidence to invest in their businesses, suppliers need a stable operating environment, and consumers depend on a reliable supply of affordable, high-quality food.

Solutions must be practical and proportionate, carefully balancing environmental ambitions with economic viability, and they must work fairly across all parts of the food supply chain.

By taking a collaborative, evidence-based approach, the long-term viability of domestic food production can be better protected, supporting UK growers and ensuring a stable supply of high-quality produce for consumers.