CBAM Impact on Kenya: Steel, Cement, and East Africa's Trade Gateway

Kenya is East Africa's largest economy and a growing exporter of steel and cement to the EU. This guide explains Kenya's CBAM exposure, its geothermal energy advantage, and what Kenyan exporters must do to comply with CBAM from 2027.

Published April 2026·Last updated April 2026·carbonborderadjustment.co.za

Kenya and CBAM: East Africa's Green Grid Advantage

Kenya is East Africa's largest economy and a growing industrial exporter. Its CBAM exposure is concentrated in steel and cement — two sectors where Kenya's exceptionally low-carbon electricity grid provides a significant structural advantage.

Kenya's Energy Mix: A CBAM Asset

Kenya's national grid is one of Africa's greenest, with a carbon intensity of approximately 180 gCO₂/kWh. The electricity mix includes geothermal (approximately 45%), hydropower (approximately 25%), wind (approximately 15%), and thermal peakers (approximately 15%). For CBAM purposes, this means Kenyan electric arc furnace (EAF) steel producers have actual Scope 2 embedded emissions far below the EU default emission factor.

Kenya's Steel Sector

Kenya's steel sector is anchored by electric arc furnace (EAF) producers in Nairobi and Mombasa. Key producers include Devki Steel Mills, Apex Steel, and Steel and Tubes of Kenya. These facilities use scrap steel and electricity — making them significantly less carbon-intensive than coal-fired blast furnace steel. Kenyan steel is exported to EU markets primarily as wire rod (CN code 7213), reinforcing bar (CN code 7214), and hollow sections (CN code 7306).

Kenya's Cement Sector

Kenya is a significant cement producer, with East Africa Portland Cement, Bamburi Cement (a Holcim subsidiary), and ARM Cement operating large kilns. Cement clinker (CN code 2523) is within CBAM scope. Kenya's cement sector uses a mix of coal and waste fuels, and the carbon intensity of Kenyan cement is broadly comparable to global averages.

The Verification Opportunity

For Kenyan EAF steel producers, actual emissions verification is the single most important CBAM action. The gap between EU default emission factors and Kenya's actual embedded emissions (due to the low-carbon grid) is likely to be very significant — potentially reducing CBAM costs by 40–60% for steel.

Compliance Pathway for Kenyan Exporters

▸Identify all CBAM-scope goods in your EU export portfolio
▸Calculate actual embedded emissions using the EU CBAM methodology
▸Engage an accredited third-party verifier
▸Appoint an Authorised CBAM Declarant registered in the EU CBAM Registry
▸Register at the Digital Product Passport Registry
▸Submit your first CBAM declaration by 31 May 2027 Kenya's green grid is a competitive asset in the CBAM era. Exporters who document and verify their actual emissions will pay significantly less than competitors from coal-dependent grids — and will be able to market their lower-carbon products at a premium to EU buyers.

Frequently Asked Questions

Which Kenyan exports are subject to CBAM?

Kenya's primary CBAM-covered exports are steel products (CN codes 7213–7217, 7304–7306) from Kenya's growing electric arc furnace sector, and cement clinker (CN code 2523) from East Africa Portland Cement and Bamburi Cement. Kenya also exports small volumes of aluminium semi-fabricated products.

What is Kenya's grid carbon intensity?

Kenya has one of Africa's lowest grid carbon intensities at approximately 180 gCO₂/kWh. Kenya's electricity mix is dominated by geothermal (approximately 45%), hydropower (approximately 25%), and wind (approximately 15%). This gives Kenyan industries a significant structural carbon advantage for CBAM purposes.

Does Kenya have a carbon tax?

Kenya does not have a national carbon tax or ETS as of 2026. Kenya's Climate Change Act 2016 provides a framework for carbon pricing, but no qualifying mechanism has been implemented. Kenyan exporters cannot claim a carbon price credit against their CBAM liability, but their low-carbon grid means actual CBAM costs are likely well below EU defaults.

What is Kenya's estimated CBAM liability for steel?

Using EU default emission factors, Kenya's steel exports face a CBAM cost of approximately EUR 130/tonne (1.985 tCO₂/t × EUR 65.42/tCO₂). However, Kenya's EAF steel producers using the national grid have actual embedded emissions significantly below this default. Verified actual emissions could reduce CBAM costs by 40–60%.

What should Kenyan exporters do to prepare for CBAM?

Kenyan exporters should: (1) identify CBAM-scope goods in their EU export portfolio; (2) calculate actual embedded emissions (which are likely well below EU defaults due to Kenya's low-carbon grid); (3) appoint an EU Authorised CBAM Declarant; (4) register at the Digital Product Passport Registry; and (5) submit their first CBAM declaration by 31 May 2027.

Gate 3 — Complete Registration

✓ Gate 1 KYC · ✓ Gate 2 CBAM · Gate 3 DPP →

Digital Product Passport Registry

Complete all three compliance gates — Gate 1 KYC identity verification, Gate 2 CBAM financial authorisation, and Gate 3 Digital Product Passport registration — in one place at the DPP Registry.

Start Three Gates Registration →