Libya exports hot-briquetted iron, fertilisers and hydrogen to the EU — with a critical CBAM gap: no country-specific default exists for Libyan iron and steel, so EU importers fall back to the "Other countries and territories" table unless producers supply verified data.
Libya is one of North Africa's primary exporters of direct reduced iron (DRI) and hot-briquetted iron (HBI), produced via the Midrex natural gas process. Key EU destinations include Italy, France, Spain and Germany. Libya also exports nitrogenous fertilisers and is developing hydrogen production capacity. All three categories fall within CBAM scope.
Source: IR (EU) 2026/1740 Annex I, which replaced the Annex I of IR (EU) 2025/2621 from 1 January 2026 · Default = the published total-emissions value · Net cost adds the Annex I mark-up once — 10% in 2026 and 30% from 2028 for cement, iron and steel, aluminium and hydrogen, 1% for fertilisers · Used when verified actual data is not provided
| Product | Sector | Default tCO₂e/t | Net cost 2026 €/t | Net cost 2030 €/t |
|---|---|---|---|---|
Grey Portland cement CN 25232900 | Cement | 0.9100 | €73.47 | €45.86 |
Anhydrous ammonia CN 28141000 | Fertilisers | 2.1700 | €160.87 | €84.97 |
Urea (solid) CN 31021019 | Fertilisers | 1.5000 | €111.20 | €58.74 |
Ammonium nitrate CN 31023090 | Fertilisers | 1.8600 | €137.89 | €72.83 |
Hydrogen CN 28041000 | Hydrogen | 10.8200 | €873.58 | €545.33 |
Net cost = default tCO₂e/t × €75.28 (Q2 2026, official price of CBAM certificates) × CBAM phase-in factor (2.5% in 2026, 48.5% in 2030). Actual liability depends on verified embedded emissions and SEFA benchmark deduction. Values shown are for illustrative default scenario only.
No Country-Specific Default Published — Iron & Steel
The EU has not published a country-specific default emission value for Libyan iron and steel exports. EU importers fall back to the “other countries and territories” row of IR (EU) 2026/1740 Annex I for the good in question — 1.325 tCO₂e/t for DRI/HBI under CN 7203, 1.46 once the 2026 mark-up is applied, and 3.996 (4.40 marked up) for semi-finished steel under CN 7207 11 11 — unless the Libyan producer supplies verified actual emissions data. It is a fallback, not a penalty bracket: which row applies follows the goods. The table above shows Libya's published defaults for fertilisers and hydrogen only. Verified emissions data is especially valuable for Libyan steel exporters.
Carbon pricing in Libya: Libya does not operate a domestic carbon pricing mechanism, emissions trading scheme, or carbon tax applicable to CBAM-covered goods.
No carbon price is paid in Libya on CBAM-covered production, so there is nothing to deduct under Article 9. The full certificate cost applies to embedded emissions above the benchmark.
Our reading of Libya's own published measures as at September 2026, not an EU-published value — third-country carbon policy changes without warning. Confirm the current position with advisers in the country of production before pricing anything on it.
Libya publishes no country-specific default for iron and steel, so EU importers fall back to the "Other countries and territories" table. For the goods Libya actually ships — direct reduced iron and hot-briquetted iron, CN 7203 — that fallback is 1.325 tCO₂e/t, or 1.458 with the 2026 mark-up. Semi-finished steel under CN 7207 11 11 falls back to a much higher 3.996, or 4.396 marked up, so which CN code you ship under changes the bill by a factor of three. A Midrex plant on natural gas can sit below the DRI fallback, and the only way to be paid for that is verified actual data: without it your EU customer surrenders certificates against the fallback whatever your plant achieves. Libya does publish country-specific defaults for fertilisers and hydrogen — only iron and steel falls back.
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Book a demoDefault values sourced from IR (EU) 2026/1740 Annex I (European Commission). Net costs are illustrative — actual liability depends on verified embedded emissions, SEFA benchmark deduction, and the applicable CBAM phase-in factor. Not legal or compliance advice.
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