CBAM

Morocco and CBAM: why the studies give different numbers

Different studies put Morocco’s CBAM exposure at different shares of exports. A guide to reading them, and to the sectors where the exposure really sits.

By Brahim Eloidii, Co-Founder, ESG & CSR Lead

Published 16 October 2026 · Sources last checked 16 October 2026

What the CESE opinion says

In an opinion published in December 2025, Morocco’s Economic, Social and Environmental Council (CESE) looked at the impact of the EU carbon border adjustment mechanism on Moroccan exports. It refers to an EU estimate of 3.7% of Moroccan exports being exposed, mainly fertilisers. The opinion discusses several estimates, in a range of roughly 1.6% to 3.7%.

Why the studies disagree

Three differences explain most of the gap between estimates:

• The year. Export structures and volumes change from one year to the next, and CBAM covers goods, not sectors.
• The product definition. CBAM applies to specific customs (CN) codes. A study that counts a whole sector gives a different share from one that counts only covered codes.
• The scenario. Each study makes its own assumptions, and the share changes with them.

The practical rule is to quote one study, with its year and its definition, and not to average or mix them.

Where the exposure sits

The direct CBAM exposure is concentrated in fertilisers, followed by exporters of steel, aluminium and cement. A wider exposure comes from customers’ supplier requirements, which hit the larger export sectors. Moroccan exports in 2025 were reported at MAD 159.2 billion for the automotive sector, MAD 99.7 billion for phosphates and derivatives, MAD 87.5 billion for agri-food and MAD 43.7 billion for textiles and leather.

Those figures are reported by the press from Office des Changes data, and the sectors are not all covered by CBAM. The phosphate and derivatives line includes the fertiliser trade, though not all of it falls under CBAM. Automotive, agri-food and textiles face supplier ESG requests from their customers, which are a separate matter from CBAM.

What an exporter should check

1. Map each product you ship to the EU to its CN code and find out whether CBAM covers it. Your exposure follows your codes, not the national percentage.
2. Ask each EU customer how they plan to declare your goods: on default values or on verified data.
3. Check whether your customer’s annual imports of covered goods are likely to pass the 50-tonne threshold.
4. If your goods are covered, start collecting installation-level data now, because the first declaration is due on 30 September 2027.

The free CBAM Compass Report shows your readiness and the estimated cost per tonne your buyers may face, for an installation in Morocco.