Libya exports hot-briquetted iron, fertilisers and hydrogen to the EU — with a critical CBAM gap: no country-specific default exists for Libyan steel, so EU importers must use the global worst-case fallback 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 2025/2621 Annex I (as replaced by IR 2026/1740) · 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 are required to use the global worst-case fallback — the highest penalty bracket — unless the Libyan producer supplies verified actual emissions data. 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 has been paid in Libya on the production of CBAM-covered goods. Libyan exporters pay the full CBAM certificate cost on embedded emissions above the sector benchmark. No qualifying scheme exists as of 2026.
Libyan iron and steel exporters face an urgent CBAM planning challenge. The EU has not published a country-specific default emission value for Libyan steel — Libya falls under the global worst-case fallback, the highest penalty bracket in the regulation, at approximately 4.4 tCO₂e/t with mark-up. This is roughly three times higher than the actual emissions from a typical direct reduction plant using natural gas. EU importers of Libyan steel are forced to use this fallback unless the Libyan producer provides verified actual emissions data. Producers who establish a monitoring plan and obtain verified data gain a direct commercial advantage: their EU customers pay significantly fewer certificates, making Libyan steel more price-competitive. Libya does have published country-specific defaults for fertilisers and hydrogen — only iron and steel falls under the global fallback.
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Book a demoDefault values sourced from IR 2025/2621 (EU 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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