What is the tonnage threshold for REACH on diammonium phosphate?

Registration required for any importer or manufacturer placing >1 t/year on the EU market

CAS 7783-28-0 · REACH · European Union

Diammonium phosphate under REACH

(NH4)2HPO4 · 磷酸二铵

Status: Registered. Diammonium phosphate 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. **DAP is in CBAM Phase 1 scope (fertilisers)** effective full from 2026, after the 2023-2025 transitional reporting period. EU Fertiliser Regulation (EU) 2019/1009 caps cadmium content at 60 mg/kg P2O5 (full application 16 July 2022, verified against https://eur-lex.europa.eu/eli/reg/2019/1009; some Member States have lower national caps under Article 3 derogation); this is the dominant trade-policy concern for Chinese-origin DAP.

DAP 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 DAP into EU is twofold: (1) **CBAM certificate purchase** equivalent to embedded carbon emissions with verifier-attested data (coal-fed Chinese ammonia carries ~1.5-2.5 tCO2e per tonne DAP, materially higher than Russian gas-fed alternatives), and (2) **EU Fertiliser Regulation 2019/1009 cadmium cap** at 60 mg/kg P2O5 binding from 16 July 2022, with Chinese sedimentary phosphate-rock-derived DAP (Yunnan, Guizhou, Hubei) carrying higher Cd than Russian / Moroccan igneous-derived alternatives. Russia and US DAP / MAP AD case context (verify current case status, regulation number, and provisional / definitive duty rates against https://eur-lex.europa.eu and https://trade.ec.europa.eu/access-to-markets/en/ before invoicing) shifts EU import volume toward Moroccan and Chinese supply; CBAM cost differential will likely reshape the EU lane economics from 2026 onward.

Listing and threshold

Substance	Diammonium phosphate (CAS 7783-28-0), (NH4)2HPO4
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 DAP product (downstream eutrophication is a separate water-policy concern)
NOT scheduled under EU Drug Precursors Regulation
NOT scheduled under EU Explosives Precursors Regulation (note: ammonium nitrate IS, but DAP 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): DAP IS in CBAM Phase 1 scope** (fertilisers, alongside urea and other ammonium-based fertilisers); definitive regime in force from 1 January 2026 after transitional reporting 2023-2025. Importers must purchase CBAM certificates equivalent to embedded emissions
EU Fertiliser Regulation (EU) 2019/1009 (effective full from 16 July 2022): cadmium content limit 60 mg/kg P2O5 in EC-fertiliser-marked product; further reductions to 40 mg/kg P2O5 may be considered post-2026 review
Nitrates Directive 91/676/EEC: Member State action programmes restrict DAP application in vulnerable zones
Water Framework Directive 2000/60/EC: phosphorus 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 DAP specifically the practitioner-facing complexity is **CBAM Phase 1 compliance** (effective full from 2026): importers must purchase CBAM certificates equivalent to the embedded emissions of imported DAP, with verifier-attested embedded-emissions data flowing through the supply chain. EU Fertiliser Regulation 2019/1009 cadmium cap (60 mg/kg P2O5) is the second dominant compliance layer; Chinese sedimentary phosphate-rock-derived DAP (Yunnan, Guizhou, Hubei sedimentary deposits) carries higher cadmium than Russian / Moroccan igneous-derived DAP. EU is structurally net-importer of DAP; Russia, Morocco, and China are the dominant supply origins.

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)
EU Fertiliser Regulation 2019/1009 conformity declaration with cadmium content certification (≤60 mg/kg P2O5)
Customs entry with HS code 31053000 (DAP) or 31055100 (NPK 20-20-0 with DAP base)
P2O5 minimum 46% specification certificate, N minimum 18% 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 from 1 January 2026** is the dominant compliance and cost layer for Chinese-origin DAP into EU. CBAM certificate cost equivalent to embedded carbon emissions (~1.5-2.5 tCO2e per tonne DAP for coal-fed Chinese ammonia plant) plus EU ETS carbon price (~70-90 EUR/tCO2 in 2025) is structural cost addition
EU Fertiliser Regulation 2019/1009 cadmium cap (60 mg/kg P2O5) applies to EC-fertiliser-marked product. Chinese sedimentary phosphate-rock-derived DAP (Yunnan, Guizhou, Hubei) carries higher Cd than Russian / Moroccan igneous-derived DAP; verify Cd content before invoicing EU lane
NO active EU AD/CVD case on Chinese-origin DAP currently. Russian DAP carries EU AD investigation context (provisional duties imposed under Reg 2024/1267 from 12 May 2024 on Russian and US DAP / MAP); Chinese DAP not subject to current EU AD case
EU is structurally net-importer of DAP; Russia, Morocco, and China are dominant supply origins. Russia AD case will likely shift volume toward Moroccan and Chinese DAP
Coal-fed Chinese ammonia (input to DAP via ammonia + phosphoric acid synthesis) carries higher embedded CO2 vs Russian gas-fed; CBAM cost differential will likely reshape the EU lane materially from 2026
Cd content potentially tightening to 40 mg/kg P2O5 post-2026 EU review; long-term watch-item that would further restrict Chinese sedimentary-rock-derived DAP
EU PFAS Restriction Roadmap: phosphate fertilisers may be reviewed for PFAS contaminants in coming years (separate concern from cadmium)

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for diammonium phosphate, see the CAS 7783-28-0 sourcing reference.

For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the diammonium phosphate 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.

Cross-jurisdiction profile and sourcing references

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