CAS 7783-20-2 · REACH · European Union

Ammonium sulfate under REACH

(NH4)2SO4 · 硫酸铵

Status: Registered. Ammonium sulfate is fully registered under REACH at the highest tonnage band. The substance carries a light occupational hazard profile (typically not classified as hazardous, dust irritation only) and is NOT subject to authorisation, SVHC, or precursor scheduling. **AS IS in CBAM Phase 1 scope (fertilisers)** effective full from 2026, after the 2023-2025 transitional reporting period. The CBAM compliance pattern for AS is distinctive: ~80% of global AS production is **by-product** (caprolactam by-product accounting for ~4 tonnes AS per tonne caprolactam; coke-oven by-product secondary), so embedded-emissions allocation under CBAM Implementing Regulation (EU) 2023/1773 uses by-product allocation methods (system-expansion or economic-value allocation) rather than direct attribution.

AS is fully REACH-registered with light occupational hazard profile but is in CBAM Phase 1 scope (fertilisers, effective full from 1 January 2026 after 2023-2025 transitional reporting). The dominant practitioner-facing compliance complexity for Chinese-origin AS into EU is **CBAM Phase 1 by-product allocation** under Implementing Reg 2023/1773: ~80% of global AS production is caprolactam by-product or coke-oven by-product, so embedded-emissions allocation uses system-expansion or economic-value allocation methods rather than direct attribution. Caprolactam-coupled AS (Sinopec Yueyang, Hengyi Petrochemical, Tianlong) carries different embedded-emissions than coke-oven by-product AS (Shougang, Baowu, Sinosteel) or direct-production AS. EU is structurally net-importer of AS; Chinese caprolactam-coupled supply competes with Russian / Belarusian (under broader nitrogen-fertiliser sanctions concern) and Egyptian / Saudi direct-production capacity. NO active EU AD on Chinese AS currently.

Listing and threshold

Substance Ammonium sulfate (CAS 7783-20-2), (NH4)2SO4
Regime EU Regulation (EC) No 1907/2006: Registration, Evaluation, Authorisation and Restriction of Chemicals
Jurisdiction European Union (EU-27 plus EEA: Iceland, Liechtenstein, Norway)
Status Registered
Tonnage threshold Registration required for any importer or manufacturer placing >1 t/year on the EU market

Classifications under this regime

  • Harmonised CLP classification: typically NOT classified as hazardous (dust irritation only)
  • Some self-classifications: Eye Irrit. 2 (H319) for dust exposure
  • Signal word: WARNING (where dust classification applies)
  • GHS pictograms: GHS07 (where dust classification applies)
  • NOT classified as carcinogen, mutagen, or reproductive toxicant
  • NOT classified as hazardous to the aquatic environment as AS product
  • NOT scheduled under EU Drug Precursors Regulation
  • NOT scheduled under EU Explosives Precursors Regulation (note: ammonium nitrate IS, but ammonium sulfate is not)

Restrictions and conditions of use

  • NOT on REACH Annex XIV (Authorisation list)
  • NOT classified as SVHC
  • NOT subject to any Annex XVII restriction
  • **Carbon Border Adjustment Mechanism (CBAM): AS IS in CBAM Phase 1 scope** (fertilisers, alongside urea and DAP); definitive regime in force from 1 January 2026 after transitional reporting 2023-2025. By-product allocation method (CBAM Implementing Reg 2023/1773) determines embedded emissions calculation
  • EU Fertiliser Regulation (EU) 2019/1009 conformity required for EC-fertiliser-marked AS product
  • Nitrates Directive 91/676/EEC: Member State action programmes restrict nitrogen fertiliser application in vulnerable zones
  • Water Framework Directive 2000/60/EC: nitrate discharge into waterbodies regulated at Member State level

Importer obligations

A non-EU producer cannot register directly under REACH. The EU importer of record must hold a registration or rely on an Only Representative (OR). For AS specifically the practitioner-facing complexity is **CBAM Phase 1 compliance with by-product allocation** (effective full from 1 January 2026): importers must purchase CBAM certificates equivalent to embedded emissions, with the embedded emissions determined by by-product allocation rules (CBAM Implementing Reg 2023/1773) given that ~80% of AS production is caprolactam by-product or coke-oven by-product. Caprolactam-coupled AS carries lower attributed embedded emissions than direct-production AS because caprolactam is the primary product (carrying most embedded emissions) and AS is the by-product. EU is structurally net-importer of AS; major supply origins are China, Russia, Belarus, and Egypt (BASF Antwerp + Saudi Arabia / Egypt direct-production capacity).

Required documents

  • REACH registration number on the EU side (registrant or OR-appointed)
  • Safety Data Sheet (SDS) compliant with REACH Annex II in destination Member State language(s)
  • **CBAM declaration with verifier-attested embedded-emissions data** for imports from 1 January 2026 (transitional reporting was 2023-2025); **by-product allocation method declaration** specifying caprolactam-coupled / coke-oven-coupled / direct-production origin
  • EU Fertiliser Regulation 2019/1009 conformity declaration
  • Customs entry with HS code 31022100 (ammonium sulfate)
  • N minimum 21% specification certificate

Common compliance traps

The pitfalls that have bitten importers on this lane in the past. None of these is theoretical.

  • **CBAM Phase 1 by-product allocation** is the dominant compliance complexity for AS: ~80% of global AS is caprolactam by-product or coke-oven by-product; embedded-emissions allocation under CBAM Implementing Reg 2023/1773 uses system-expansion or economic-value allocation. Caprolactam-coupled AS (Sinopec Yueyang, Hengyi Petrochemical, Tianlong, Lujian Caprolactam) carries different embedded-emissions than coke-oven by-product AS (Shougang, Baowu, Sinosteel) or direct-production AS (Capro Corporation, Asia Pacific Resources)
  • NO active EU AD/CVD case on Chinese-origin AS currently. EU AD investigations on Russian and Belarusian AS have happened periodically (related to broader nitrogen-fertiliser sanctions); Chinese AS not currently AD-targeted in EU
  • EU is structurally net-importer of AS; major supply origins are China, Russia, Belarus, Egypt, and intra-EU sources (BASF Antwerp caprolactam by-product)
  • Coal-fed Chinese ammonia upstream (input to caprolactam → AS by-product chain or direct AS production) carries higher embedded CO2 vs gas-fed; CBAM cost differential is structural even after by-product allocation
  • EU Fertiliser Regulation 2019/1009 cadmium / heavy-metal limits: AS does not carry the same Cd concern as DAP (no phosphate-rock geology dependency); coke-oven by-product AS may carry trace heavy-metal concern from upstream coal feed
  • Granular vs crystalline AS specification: granular (typically caprolactam-coupled) commands premium for direct-application; crystalline (typically coke-oven by-product) requires NPK-blender intermediate processing
  • EU Single-Use Plastics directive does not apply to AS; phosphate-fertiliser PFAS roadmap concerns do not apply to AS (sulfate, not phosphate, not generally PFAS-contaminated)

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for ammonium sulfate, see the CAS 7783-20-2 sourcing reference.

For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the ammonium sulfate cornerstone hub covers the full sourcing chain.

For the structure and history of REACH, see the REACH glossary entry.

Need cross-jurisdiction compliance support on this substance? Run it through the REACH / TSCA / IECSC / AICIS / K-REACH checker, or send us the substance and the destination and we will quote FOB China and CIF / DDP landed including the regulatory work on the destination side.

Read next

Cross-jurisdiction profile and sourcing references

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