CAS 57-13-6 · REACH · European Union

Urea under REACH

CH4N2O · 尿素

Status: Registered. Urea is fully registered under REACH at the highest tonnage band (>1,000,000 tonnes/year). Multiple lead registrants from the European fertiliser industry consortium (Yara, OCI Nitrogen, Borealis, Grupa Azoty). Urea is unique among heavy industrial chemicals because at standard purity it carries NO GHS hazard classification under REACH; the substance is treated as non-hazardous for transport, storage, and labelling.

Urea is the inversion of the precursor-overlay pattern: REACH-trivial (no hazard, no precursor scheduling) but trade-policy-significant. EU CBAM Phase 1 from January 2026 makes the China-EU urea lane increasingly economically pressured because Chinese urea is structurally coal-routed (higher embedded emissions), while Russian, Trinidad, and Egyptian alternatives are gas-routed (lower emissions, less CBAM cost). For non-fertiliser urea applications (urea-formaldehyde, melamine, AdBlue / DEF), CBAM still applies. Russia EU-export disruption since 2022 has temporarily favoured Chinese supply, but the long-term carbon-cost trajectory is structurally adverse.

Listing and threshold

Substance Urea (CAS 57-13-6), CH4N2O
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

  • NOT classified as hazardous under CLP at standard purity (no Skin Corrosion, no Acute Toxicity, no STOT, no Carcinogen / Mutagen / Reprotox)
  • NOT on the harmonised CLP Annex VI list
  • Standard precautionary handling for dust (mechanical hazard, not chemical)
  • GHS pictograms: NONE required
  • Signal word: NONE required
  • Technical-grade urea may contain trace ammonia / biuret residues that trigger separate handling rules; verify spec

Restrictions and conditions of use

  • NOT on REACH Annex XIV (Authorisation list)
  • NOT on REACH Annex XVII (Restriction list)
  • NOT classified as SVHC
  • NOT scheduled under EU Drug Precursors Regulation
  • NOT a regulated explosives precursor under Regulation 2019/1148 (note: ammonium nitrate IS, urea is NOT)
  • **EU CBAM (Carbon Border Adjustment Mechanism) applies from 2026 Phase 1**: urea is in scope as a fertiliser product. Importers must report embedded greenhouse-gas emissions and (from 2026 onwards) purchase CBAM certificates for emissions above the EU-ETS-equivalent baseline.

Importer obligations

A non-EU producer cannot register directly under REACH. The EU importer of record must hold a registration in their own name or rely on an Only Representative (OR) appointment. Urea is REACH-trivial from a hazard standpoint but is the most operator-relevant CBAM-scope chemical: from 1 January 2026, every fertiliser importer must report embedded emissions per shipment, file CBAM declarations quarterly, and (from full Phase 2 in 2034) purchase CBAM certificates priced at the EU ETS market rate. Chinese-coal-route urea has higher embedded emissions than Russian, Trinidad, or Middle East gas-route alternatives, materially affecting landed cost.

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); urea SDS is brief but required
  • CBAM declaration data (manufacturer-level embedded emissions per tonne, verified by accredited verifier from 2026)
  • CBAM certificates purchased to cover net-of-baseline embedded emissions (from 2026 onwards)
  • Customs entry with HS code 31021000 (urea, fertiliser-grade in bulk or packaged)

Common compliance traps

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

  • CBAM is the binding constraint for Chinese urea exports to EU from 2026; embedded-emissions data must come from the manufacturer, not estimated by importer
  • Coal-route Chinese urea has structurally higher embedded emissions than gas-route Russian or Middle East supply, materially affecting CBAM cost
  • Technical-grade urea (urea-formaldehyde resin, AdBlue / DEF feedstock, melamine precursor) has the same REACH treatment as fertiliser-grade
  • Some Member States require additional fertiliser-quality registration (CE Mark for fertiliser, Reg (EC) 2003/2003 baseline rules, replaced by Reg (EU) 2019/1009 with full application from 16 July 2022; verified against https://eur-lex.europa.eu/eli/reg/2019/1009)
  • EU and Member State MAP / DAP / urea anti-dumping investigations are an active 2024-2026 trade-policy lever

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for urea, see the CAS 57-13-6 sourcing reference.

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

Free download

Free PDF: the same MSDS verification template the Sourzi team uses to cross-reference factory documents against TSCA, REACH, AICIS, and CDR before booking.