CBAM Impact on Morocco: Phosphates, Fertilisers, and the OCP Group

Morocco is the world's largest phosphate exporter. While phosphate rock is not covered by CBAM Phase 1, downstream fertilisers may be. This guide explains Morocco's CBAM exposure and what OCP and other Moroccan exporters need to know.

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

Morocco and CBAM: The Phosphate Giant Navigates the Carbon Gate

Morocco occupies a unique position in the global CBAM landscape. As the world's largest phosphate exporter and a major fertiliser producer, Morocco has significant potential CBAM exposure — but also significant renewable energy assets that could provide a carbon advantage.

The OCP Group: Morocco's CBAM Anchor

OCP Group controls approximately 70% of global phosphate reserves and processes phosphate rock into fertilisers at its Jorf Lasfar and Safi industrial complexes. OCP has announced a major green transition programme including renewable energy investment and green ammonia production.

Phosphate Rock vs Downstream Fertilisers

Phosphate rock (CN 2510): NOT covered by CBAM Phase 1.

Downstream fertilisers: Some phosphate-based fertilisers may be covered depending on CN codes. Moroccan exporters should check each product against Annex I of the CBAM Regulation.

Ammonia (CN 2814): Covered by CBAM. If exported directly to the EU, it is subject to CBAM.

Morocco's Renewable Energy Advantage

Morocco's Noor solar complex and Tarfaya wind farm give its industrial exporters a potential carbon advantage. Moroccan exporters who can demonstrate they use renewable electricity can use a lower emission factor for Scope 2 calculations, reducing CBAM liability.

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Frequently Asked Questions

Is Moroccan phosphate rock covered by CBAM?

No. Phosphate rock (CN code 2510) is not listed in Annex I of the CBAM Regulation and is not covered by CBAM Phase 1. However, downstream phosphate-based fertilisers — including DAP, MAP, and TSP — may be covered depending on their specific CN codes.

What is OCP Group's CBAM exposure?

OCP Group processes phosphate rock into fertilisers (DAP, MAP, TSP, urea) and exports to EU markets. The CBAM exposure depends on which specific fertiliser products OCP exports and their CN codes. OCP has invested significantly in renewable energy and green ammonia production, which could reduce its CBAM liability.

Does Morocco have a carbon tax?

As of 2026, Morocco does not have a national carbon tax or emissions trading system. Morocco has been a leader in renewable energy development in Africa but no operational carbon pricing mechanism exists, meaning Moroccan exporters cannot claim a carbon price credit.

How does Morocco's renewable energy investment affect CBAM?

Morocco has invested heavily in renewable energy, targeting 52% renewable electricity by 2030. Moroccan industrial exporters who use renewable electricity have lower Scope 2 emissions and therefore lower CBAM liability. OCP has announced plans to power its fertiliser production with renewable energy.

What should Moroccan exporters do to prepare for CBAM?

Moroccan exporters should: (1) check whether their specific products are covered by CBAM using the CN code list; (2) calculate actual embedded carbon; (3) engage an accredited third-party verifier; (4) register at the DPP Registry; and (5) provide verified data to EU buyers.

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