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Ammonia Europe

Ammonia Europe is the voice of the European Ammonia industry.

Lobbying Activity

Response to EU’s next long-term budget (MFF) – EU funding for competitiveness

12 Nov 2025

Ammonia Europe welcomes the Commissions proposed restructuring of the Multiannual Financial Framework and the establishment of the European Competitiveness Fund (ECF). The renewed focus on industrial resilience, innovation, and strategic autonomy is essential at this pivotal moment for Europes economy. In particular, ammonia should be recognised within this framework for its role as a critical chemical underpinning competitiveness across energy, industry, transport, and defence. In an era of weaponised interdependence, ammonia can also contribute directly to strategic autonomy by enabling a more diversified fuel supply while providing the foundation for a more resilient and strategically autonomous Europe. To ensure this potential is realised, the following elements could be considered: (1) Inclusion of ammonia within the ECF clean transition and resilience windows: Ammonia is a storable, tradable molecule produced within existing EU industrial clusters for chemicals and fertilisers production. Clean ammonia further enables the decarbonisation of shipping, heavy industry, and power generation while reinforcing Europes energy security. Given that ammonia infrastructure - from production to ports - can support both civilian logistics and strategic supply chains, ammonia should be included in the ECFs Clean Transition and Resilience & Defence Industry windows. (2) Closing the investment gap: High capital and energy costs combined with regulatory complexity remain the main barrier to scaling clean ammonia. ETS revenues should be redirected to the ammonia sector and the ECF should deploy targeted CAPEX and OPEX support, to de-risk early projects. Simplified access and cumulative funding (between EU funds and state aid) could also accelerate investment in strategic technologies such as carbon capture and storage (CCS) and autothermal reformer (ATR) technology for producing low-carbon ammonia, as well as for developing low-carbon ammonia cracking systems and cutting-edge ammonia fuelled engines for ships. (3) Supporting critical infrastructure: Modern, resilient infrastructure is essential for Europes industrial base and strategic autonomy. Investments in electrical connections, as well as in ammonia cracking and ammonia distribution systems - including pipelines, rail connections, and safe storage facilities - should be prioritised under the Connecting Europe Facility (CEF) and related funding instruments. Such investments would strengthen internal market integration, improve supply security, and enable the wider deployment of clean fuels across industrial clusters and shipping corridors. At the same time, an updated EU Infrastructure Atlas mapping clean-fuel capacity, connectivity, and logistical gaps could help guide strategic funding to the regions most in need. (3) Industrial leadership and skills: Europes ammonia sector provides a strong foundation for the clean energy transition, operating 32 plants (10% of global production) and 30+ terminals, transport vessels, and rail networks, while accounting for up to 30% of hydrogen use in Europe. Building on this base, Europe can lead in greening the chemicals industry, advancing clean maritime fuels, and developing ammonia as both a hydrogen carrier and energy source. Targeted investment through the Innovation Fund, ECF, and Horizon Europe should support innovation, retrofitting, and safety training and standards across the value chain to help secure high-value jobs and keep Europe competitive in the global clean ammonia transition.
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Response to Revision of the EU’s energy security framework

13 Oct 2025

Ammonia Europe welcomes the European Commissions initiative to revise the EU energy security framework. The events of 202123 have demonstrated the vulnerability of Europes energy system to external shocks, underlining the need for a diversified, resilient, and decarbonised energy mix. Clean ammonia can therefore play a pivotal role in strengthening EU energy security while supporting climate and competitiveness objectives but it can only play this role with the right support: (1) Recognise clean ammonia as a strategic energy carrier: The revised framework should explicitly classify ammonia as a strategic energy vector alongside hydrogen. This could mean revising the Gas and Hydrogen Package and TEN-E Regulation to fully incorporate ammonia infrastructure including transport and storage as key priorities. Ammonias role as an energy carrier should be further embedded in the Industrial Accelerator Act (IAA) and the wider Clean Industrial Deal implementation, ensuring ammonia-based projects can access streamlined permitting, PCI/PMI status, and targeted de-risking. (2) Support ammonias direct use as an energy source: The Commission should update the Renewable Energy Directive (RED III) and the Energy Taxation Directive (ETD) to provide recognition and incentives for direct ammonia use in power generation, combined heat and power, and seasonal storage. EU R&I funding (e.g. Horizon Europe and the Innovation Fund) should support the development of EU demonstration plants to validate ammonia-to-power systems as is already being done in a variety of countries including Japan, Korea and Singapore. These demonstration plants should be eligible under the Strategic Technologies for Europe Platform (STEP), enabling ammonia to complement renewable electrification in delivering grid stability. (3) Safeguard Europes industrial base through technology-neutral rules: The EU must align methodologies under ETS, CBAM, and RED III delegated acts to consistently recognise all clean ammonia production pathways. Approval of the delegated act on low-carbon hydrogen and derived fuels is essential to ensure technology neutrality. In parallel, ETS Innovation Fund revenues and the European Hydrogen Bank should explicitly support ammonia offtake contracts, covering both renewable and low-carbon routes, to bridge the green premium and prevent further industrial closures in Europe. (4) Harness ammonias transport and storage advantages to build resilience: Ammonia is one of the most efficient chemicals for large-scale energy storage all while leveraging existing infrastructure. Stockpiling clean ammonia in port terminals and storage facilities would allow the EU to build strategic reserves for a range of purposes, enhancing resilience against supply shocks in key sectors ranging from energy and defence to chemicals and shipping. The revised framework should therefore recognise ammonia storage assets as part of Europes energy security architecture and ensure they are eligible for accelerated permitting and financing under TEN-E, AFIR and CEF/AFIF mechanisms. (5) Promote international cooperation and interoperable standards: The Commission should champion EU-wide certification standards (building on Ammonia Europes certification scheme) and ensure mutual recognition with trading partners.
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Response to Carbon price paid in a third country under the carbon border adjustment mechanism (CBAM)

24 Sept 2025

The European ammonia industry welcomes the opportunity to provide feedback on the implementation of CBAM, but we are concerned by the limited timeframe for application of these implementing acts given that no draft methodology is currently available and CBAMs full implementation is due to start in 2026. Ammonia is a critical building block of Europes chemical and agri-food value chains, yet the sector is highly exposed to international competition from regions without comparable carbon constraints. While CBAM aims to minimise unfair competition on imports there is currently no solution for European exports, which are subject to high carbon costs. The principle must remain that EU producers and third-country producers face an equivalent carbon cost burden. Exemptions or reductions for imports should only apply when the third-country scheme is genuinely comparable to the EU ETS in terms of scope, design, monitoring, and price level. Partial schemes, rebates, or non-transparent systems should not qualify, as they would create structural asymmetries and risks undermining CBAMs credibility, distorting competition, and incentivising shifting production to higher-emission regions. We therefore recommend that: The rules for converting a carbon price into CBAM certificates ensure full transparency, taking into account any rebates, offsets, or compensation that reduce the effective price paid. The conversion methodology for foreign currencies is standardised to avoid discrepancies that could be exploited. Eligibility rules for third-party certifiers ensure independence, competence, and accountability. Evidence requirements are aligned with international monitoring and reporting standards, minimising administrative burden while guaranteeing integrity. A preference for real verified values and where necessary default values at least at country level
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Response to Adjustment of the obligation to surrender CBAM certificates to take account of ETS free allowances phase-out

24 Sept 2025

The European ammonia industry welcomes the opportunity to provide feedback on the implementation of the CBAM, but we are concerned by the limited timeframe for application of these implementing acts given that no draft methodology is currently available and CBAMs full implementation is due to start in 2026. Ammonia is a critical building block of Europes chemical and agri-food value chains, yet the sector is highly exposed to international competition from regions without comparable carbon constraints. While CBAM aims to minimise unfair competition on imports there is currently no solution for European exports, which are subject to high carbon costs. Free allocation under the EU ETS has so far provided sufficient protection against carbon leakage. As free allocation is progressively phased out between 2026 and 2034, it is essential that CBAM delivers equally robust protection. The mechanism must be designed and proven in a way that ensures EU producers are not placed at a structural disadvantage compared to imports from third countries. Any weakening of protection risks shifting production and the associated greenhouse gas emissions outside the EU, undermining both climate goals and Europes strategic autonomy with ammonia being a critical input in the chemical and fertiliser sector and in future markets as a hydrogen carrier and marine fuel. We therefore recommend that: The methodology for calculating the adjustment for free allocation remains closely aligned with EU ETS benchmarks, reflecting actual production processes with accuracy while keeping administrative complexity low. The derivation of CBAM benchmarks from EU ETS benchmarks ensures consistency and comparability and avoids circumvention that could disadvantage EU producers relative to imports. Adjustments must be simple to implement but must not erode the level of protection previously ensured through free allocation.
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Response to Carbon border adjustment mechanism (CBAM) methodology for the definitive period

24 Sept 2025

The European ammonia industry welcomes the opportunity to provide feedback on the implementation of CBAM, but we are concerned by the limited timeframe for application of these implementing acts given that no draft methodology is currently available and CBAMs full implementation is due to start in 2026. Ammonia is a critical building block of Europes chemical and agri-food value chains, yet the sector is highly exposed to international competition from regions without comparable carbon constraints. While CBAM aims to minimise unfair competition on imports there is currently no solution for European exports, which are subject to high carbon costs. The implementing act on emissions calculation methodology is central to ensuring that CBAM achieves its objectives. Accurate, transparent, and enforceable methodologies are required to capture the emissions embedded in imported goods. For European ammonia production, indirect CO cost compensation is essential to address rising electricity costs, however, it should not come at the expense of removing indirect emissions from the CBAM for the ammonia/fertiliser sector. This is critical for avoiding carbon leakage, particularly against ammonia produced using carbon-intensive electricity outside the EU. One of the main pathways to decarbonise the European ammonia industry is via electrifying the production process eg: hydrogen generation via electrolysis, on top of other demand for electricity for systems like air separation and syngas compression. This transition will sharply increase electricity demand, making indirect emissions central to the sectors competitiveness. If indirect emissions are excluded from CBAM, EU producers would face high electricity costs (even if partially offset by indirect cost compensation), while imports of ammonia produced with carbon-intensive electricity, such as coal-based grids outside the EU, would only be charged for direct emissions. This asymmetry would undermine the integrity of CBAM and could incentivise production in higher-emission regions. Additionally, there should be a provision to update and include new innovative/non-integrated production routes into the CBAM methodology. For example, ammonia production where hydrogen is sourced from a pipeline network. Currently, there are no traceability/mass balance rules recognised under the CBAM methodology to demonstrate the origin of such precursors. A credible third party verified mass balance scheme would need to be recognised under CBAM for this purpose. We therefore recommend that: The methodology should explicitly cover both direct and indirect emissions for CBAM goods. Rules for calculating indirect emissions are harmonised with EU ETS methodologies and based on transparent emission factors. Default values remain conservative to prevent underestimation of third-country emissions and be set at least at country level, while operators should be encouraged to use actual values where monitoring and verification are ensured. Administrative complexity is minimised for EU producers, who already bear significant compliance costs under the EU ETS. Address inconsistencies between CBAM and ETS policies to guard against carbon leakage by compensating all downstream ammonia value chains. Inclusion of across sectors indirect emissions from electricity and refineries, which constitute a large portion of CO costs. Include provision for third party verification of for precursors procured from non-typically means to facilitate the take up of potential new production pathways
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Response to European Climate Law amendment

11 Sept 2025

The European Climate Laws proposed 90% net emissions reduction by 2040 is an important step, but under current conditions, it risks accelerating deindustrialisation, raising costs, and weakening Europes competitiveness. Europes energy-intensive industries are already under pressure from high energy costs, global subsidies, and structural overcapacity abroad. In chemicals and ammonia production, closures are mounting, and capacity is shifting overseas. Unless safeguards are in place, higher ambition will undermine the ammonia sectors ability to supply strategic value chains from fertilisers to energy, defence and clean fuels and will increase reliance on imports. As a result, the following should be considered: (1) Balancing net zero climate ambition with competitiveness: The 2040 target must be embedded in Europes updated industrial strategy. That means aligning with the Draghi Report, the Antwerp Declaration, the EUs Clean Industrial Deal, and the European Chemicals Industry Action Plan, ensuring that critical sites and clusters are safeguarded. Decarbonisation should be stepwise beginning with efficiency and partial abatement, then scaling up as infrastructure and markets mature, and ultimately reaching zero-carbon production. (2) Technology neutrality and its legal recognition: Higher ambition is only achievable if Europe keeps all viable solutions on the table. This means not prescribing a single route, but recognising that clean ammonia whether blue ammonia produced via SMR/ATR with carbon capture, or green ammonia produced via electrolysis powered by wind, solar, nuclear, or grid mix has a role to play. The principle of technology neutrality must therefore be embedded in legislation. Under RED III, only renewable fuels of non-biological origin (RFNBOs) count towards the decarbonisation of ammonia production, while other low-carbon hydrogen and ammonia pathways remain unrecognised. On the other hand, in the maritime sector, both FuelEU Maritime and maritime ETS do provide limited recognition of low-carbon fuels a recognition that should be expanded, not only in shipping, but across the wider Climate Law framework. (3) Stimulating demand for low-carbon products: Achieving higher ambition requires that there is a market for clean products. As a result, demand-pull measures are needed. Initiatives under the Industrial Decarbonisation Accelerator Act (IDAA), as well as low-carbon product labels, private procurement initiatives, and fiscal measures such as VAT reductions on clean fuels could all play a key role. Many low-carbon products and related projects such as CCS involve very high upfront capital costs and long payback periods, underscoring the need for strong and sustained demand signals. (4) Funding and targeted investments: The investment challenge is substantial. ETS revenues, the European Hydrogen Bank, and national state aid should all be mobilised in a cumulative and coordinated way to support both supply and demand for clean products. Mechanisms must fully cover the green premium the cost gap compared to fossil equivalents in order to de-risk projects, reward early movers, and create sustainable markets in chemicals, fuels, and other energy-intensive value chains. (5) ETS, CBAM and international credits: Free allowances must be phased out gradually and in line with CBAM implementation. Otherwise, EU producers risk double exposure: losing allowances while competing with imports that benefit from subsidies or weaker climate rules. The current CBAM design creates inconsistencies in the treatment of hydrogen-derived fuels, leading to uneven competition among alternative options. To ensure fair market conditions, CBAM and ETS policies must address sectoral inconsistencies and adopt harmonised, technology-neutral methodologies that create a true level playing field.
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Response to Technical updates of the Emissions Trading Scheme (ETS) State aid guidelines

4 Sept 2025

We welcome the opportunity to provide input on the revision of the EU ETS State Aid Guidelines for indirect cost compensation. Ammonia production is vital to Europes chemical and agri-food value chains and is increasingly exposed to indirect CO costs from electricity. Please see attached supporting document.
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Response to Sustainable transport investment plan

3 Sept 2025

Ammonia Europe welcomes the STIP initiative. Maritime transport is the EUs 3rd highest transport emitter, responsible for 1314 % of transport CO emissions, behind only road and aviation. Unlike those sectors, shipping can be decarbonised more rapidly because fuelling is concentrated at few ports. Ammonia-specific fuel mandates and incentives (e.g. a multiplier for low-carbon ammonia) can further enable cost-effective deployment of alternative fuels. This makes maritime a low-hanging fruit for early, high-impact emissions reductions. Clean ammonia encompassing zero-carbon green and low-carbon blue ammonia can play a decisive role in delivering on the EUs climate and competitiveness objectives. It is one of the few scalable, storable, and globally tradable fuels capable of fully decarbonising deep-sea shipping. It benefits from existing global production and logistics networks, with over 30 EU ports already handling ammonia, and modelling by UMAS and UCL suggests it will be the most cost-competitive zero-emission maritime fuel by the mid-2030s. Maritime uptake can also lower costs for other sectors, enhance security of supply, and reinforce EU strategic autonomy. With that in mind, we recommend that the STIP address the following: (1) Prioritise ammonia infrastructure: Include ammonia bunkering, storage, and safety systems in STIPs maritime priorities and the 2026 AFIR review. Target key TEN-T ports where maritime bunkering shares infrastructure with industrial uses, and grant PCI/PMI status to enable Connecting Europe Facility (CEF) and AFIF support. Integrate hinterland connectivity to ensure stable, efficient, cost-effective supply from import terminals to industrial clusters. (2) De-risk first movers: Use ETS Innovation Fund revenues, State Aid flexibility, and pooled national/EU funding to co-finance vessel retrofits and new builds, plus shipyard capacity expansion, safe fuel storage integration, and crew training. This accelerates deployment in a sector where more concentrated infrastructure enables quicker scaling. (3) Link vessel and port readiness: Fund vessels and port infrastructure together to ensure simultaneous deployment, while also boosting collaboration with non-EU countries and international organisations. This should include promoting global adoption of renewable and low-carbon fuel standards to incentivise production and use at scale. Use Green Shipping Corridors to validate ammonia supply chains on strategic intra-EU and extra-EU routes (e.g., SpainRotterdam, SingaporeRotterdam), demonstrating interoperability, international compliance, and rapid scalability through centralised bunkering hubs. (4) Leverage EU Hydrogen Bank: Provide targeted offtake support via the Hydrogen Bank for clean ammonia as a maritime fuel across all eligible production pathways, bridging the green premium and enabling long-term supply contracts. Recent cancellations of four projects that had previously won Hydrogen Bank auctions highlight the need to strengthen the design of future rounds to ensure delivery and investor confidence. Addressing these shortcomings, while also expanding on the 200 million already earmarked for maritime fuels, will be critical to scaling clean ammonia deployment in shipping. (5) Harmonise regulation and standards: Strive for harmonisation of EU-wide rules for ammonia bunkering, crew training, safety, and renewable/low-carbon fuel certification, aligned with IMO standards. This will reduce investment risk, facilitate global trade, and ensure EU leadership in shaping international rules for alternative maritime fuels. (6) Set a clear roadmap for ammonia in shipping: Establish interim milestones for infrastructure and fleet deployment to meet FuelEU Maritime targets; integrate ammonia into the EUs hydrogen import and industrial strategies; and align STIP measures with evolving EU and IMO fuel policies to maximise emissions reductions, cost efficiency, and industrial competitiveness.
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Response to EU Ports Strategy

28 Jul 2025

The EU Ports Strategy is an excellent first step toward building a more competitive and decarbonised EU ports sector. The transition to clean maritime fuels like ammonia hinges not only on advances in ammonia production and ship propulsion, but also on port readiness. As such, the following areas should be addressed: (1) Port Infrastructure: While more than 30 EU ports currently handle ammonia, this is largely limited to industrial cargo handling operations. A meaningful shift requires moving from handling to dedicated bunkering infrastructure. At present, most ammonia handling occurs near production sites rather than within ports, creating a logistical disconnect that restricts fuel availability and slows compliance with regulations such as FuelEU Maritime. To overcome this, EU ports must be better integrated into ammonia supply chains through improved hinterland connectivity - via rail, pipeline, or other means - to ensure a stable and cost-effective supply. This will lay the foundation for enabling broader adoption of ammonia-fuelled vessels. Once ammonia reaches port, dedicated bunkering systems must be in place. These include purpose-built storage tanks, bunkering vessels, and robust safety infrastructure adapted to ammonias properties. Ammonia could also support broader port decarbonisation by serving as a clean fuel for onshore power supply, reducing emissions from berthed ships. To advance in these areas, the STIP should prioritise support for ammonia infrastructure in key TEN-T maritime ports, especially where demand can be aggregated across multiple sectors. In addition, AFIR should be updated to include provisions on the deployment of storage and bunkering infrastructure for ammonia and specifically call for Members States to included it in their strategies in the next review to be undertaken by December 2026. Finally, the adoption of harmonised technical standards for bunkering, and operator safety - both onshore and onboard - are also needed to facilitate the proper functioning of port infrastructure. (2) Funding: Given the high CAPEX of building new ammonia infrastructure, targeted subsidies and financial instruments will be essential to de-risk investments and mobilise private capital. Funding mechanisms such as AFIF should specifically support ammonia-related projects. (3) Permitting and Technical standards: Further support is needed through streamlined permitting for ammonia port infrastructure. This is essential to avoid delays and ensure that EU decarbonisation targets are reached in time. As a result. ports should be prioritised as strategic EU acceleration areas, granting key clusters access to fast-track permitting through IPCEI status. (4) Energy Security: Port infrastructure must also serve Europes broader energy and dual-use security objectives. Given Ammonias key role across a range of sectors, from agriculture to energy and defence, ports must be ready to effectively ensure European strategic autonomy. For example, with the EU aiming to import 10 million tonnes of green hydrogen by 2030, ammonia can play a central role as an energy carrier. Meeting this ambition will require a coordinated strategy on fuel importation, infrastructure development, and port readiness. (5) Support Coordination: To ensure a harmonised and evidence-based approach, the European Commission should establish a comprehensive EU Ports Atlas which maps current and planned infrastructure for alternative fuels, hinterland connectivity, and shipping lanes. It could build on existing tools like TENtec and the European Alternative Fuels Observatory (EAFO), but with a stronger focus on ammonia, and with more data on infrastructure gaps, industrial readiness, and supply chains. This data would support policy development, investment planning, and cross-border coordination - ensuring that ports become drivers, not bottlenecks, in EU maritime decarbonisation.
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Response to EU industrial maritime strategy

28 Jul 2025

Ammonia Europe warmly welcomes the initiative for an EU Maritime Industrial Strategy and its stated aim of strengthening and decarbonising Europes waterborne industrial and technological base. In light of the upcoming IMO Net Zero Framework, this goal has become even more urgent. In this context, ammonia presents a zero-carbon fuel alternative with significant potential, offering the advantages of scalability and an established global trade network compared to other clean molecules. Recent total cost of ownership (TCO) modelling by UMAS and University College London (UCL), combined with over 30 stakeholder interviews conducted by the Getting to Zero Coalition, indicates that ammonia is likely to become the most competitive zero-emission fuel pathway for shipping from the mid-2030s onward. This finding suggests that ammonia dual-fuel vessels could already be a viable and strategic choice today. Consequently, more is needed from the European Union to ensure that the EU maritime industrial sector is well positioned to benefit from this transition. While the EU maritime sector already holds valuable expertise in dual-fuel ammonia engine technologies and onboard ammonia cracking systems, and while ammonia-ready ship designs are emerging, these activities are increasingly taking place outside Europe. The same applies to ship retrofitting, raising concerns that the EU may lose ground in this critical area of maritime innovation. To address this, the EU Maritime Industrial Strategy should include the following: (1) Funding for Ammonia-ready Propulsion: The EU should earmark targeted support measures for ammonia propulsion and related technologies. A key step would be to channel revenues from the EU Emissions Trading System (ETS) and similar maritime climate mechanisms into decarbonisation efforts. These funds should back pilot projects, retrofitting initiatives, and the development of new ammonia-ready vessels, enabling the sector to meet climate targets while maintaining technological leadership. (2) Research, Development, & Innovation (RDI): EU support for RDI must be reinforced. Horizon Europe and other relevant programmes should allocate specific and dedicated funding to support the advancement of next-generation maritime solutions, with a clear focus on ammonia-based propulsion systems and associated safety and performance technologies. (3) Implementation Support: Once new technologies have been developed, more support is needed to roll them out in real-world situations. Here, Green Shipping Corridors can play a key role in promoting ammonia uptake and accelerating maritime decarbonisation across the EU. By enabling the testing and deployment of new technologies, fuels, and business models along defined trade routes, these corridors can act as catalystsaddressing challenges such as fuel costs, infrastructure development, and regulatory coordination. By implementing these measures, the EU can secure its role as a global leader in maritime decarbonisation and ensure that its industrial base fully reaps the benefits of the emerging ammonia propulsion market.
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Meeting with Elisa Roller (Director Secretariat-General)

3 Jul 2025 · Low-carbon Delegated Act

Meeting with Fotini Ioannidou (Director Mobility and Transport)

15 Jan 2025 · Introducing the potential for EU policies of the ammonia.

Response to Greenhouse gas emissions savings methodology for low-carbon fuels

25 Oct 2024

Ammonia Europe welcomes the possibility to give feedback to the draft delegated act setting out the methodology to determine the GHG emission savings of low-carbon fuels. Low-carbon fuels (LCFs) will play a crucial role, especially for the decarbonisation of hard-to-abate industries, as such this DA will have a great importance in providing the certainty required for investments. See attached document for our full consultation response.
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