CBAM Country Intelligence Mauritania 2026: Pre-Agglomeration Invisibility, a Carbon Price Without a Deduction Path, and Entry into Scope from 2031

Executive Summary

Scope. This volume applies the goods list in Annex I to Regulation (EU) 2023/956 to the Islamic Republic of Mauritania, entry by entry. Annex I contains forty two positive entries across six sectors, together with twelve exceptions carved out of Chapter 72, and it lists those entries at mixed granularity: whole chapters, four digit headings, and eight digit Combined Nomenclature codes [1]. Against that list, Mauritania presents two relevant industries and no others. The country grinds imported clinker into cement at four stations, and it mines and beneficiates iron ore. It operates no integrated cement kiln, no blast furnace, no basic oxygen or electric arc steelmaking, no primary aluminium smelter, no ammonia or nitric acid plant, and no industrial scale hydrogen facility. It shares no electricity interconnection with the European Union.

Principal finding. Mauritanian iron ore enters the European Union under CN 2601 11 00, non-agglomerated iron ores and concentrates. That code does not appear in Annex I. Its neighbour, CN 2601 12 00, covering agglomerated ores and concentrates, does appear. The distinction between them rests on a process that Mauritania does not perform. Under Annex II to Commission Implementing Regulation (EU) 2025/2547, a precursor is defined as an input material that is itself on the Annex I list [2]. Non-agglomerated ore therefore cannot function as a precursor to any covered good, which means that the emissions attached to Mauritanian mining and beneficiation remain outside the accounting boundary along two distinct routes: direct shipment to the Union, and shipment to a third country whose steel subsequently enters the Union.

Quantified results. The Société Nationale Industrielle et Minière (SNIM), the state owned iron ore producer, reported 540,731 tonnes of carbon dioxide equivalent for 2024 against production of 14,226,000 tonnes of ore, an intensity of 38.0 kilograms per tonne [3]. The figure is self declared under Requirement 3.4 of the EITI Standard, carries no third party assurance, and passes three independent engineering checks set out in Part 2 of this volume. Mauritania holds exactly one country specific default value in the European Union's default value tables, and it belongs to the cement sector: 1.190 tonnes of carbon dioxide per tonne of grey Portland cement [4].

Governing variable. Mauritania's position under the Carbon Border Adjustment Mechanism turns on the resolution at which the instrument observes, and hardly at all on the carbon intensity of its industry. Coverage is fixed by an eight digit customs code, default parameters are modelled from national product statistics, and recognition of a foreign carbon price turns on the identity of the taxpayer. Each of those three observation windows is internally consistent. Taken together, they produce a picture of a mining and beneficiation economy that does not coincide with its physical reality.

Trade context. Iron ore destinations in 2024, measured by value: China 61.75 per cent, Algeria 13.05 per cent, Italy 8.65 per cent, Germany 6.16 per cent [3]. Trade statistics reported by Mauritania to the United Nations give closely matching shares [5]. European Union member states together took roughly 16.7 per cent. Europe once absorbed about three quarters of SNIM's shipments; that share has been falling since the financial crisis of 2008, for reasons that have nothing to do with carbon regulation [6].

Timeline. A climate contribution levied on imported hydrocarbons entered force in January 2025 at 400 ouguiya per tonne of carbon dioxide, rose to 800 ouguiya in 2026, and is scheduled by statute to reach 2,000 ouguiya by 2030 [7][8]. Separately, the Atomai pellet project is planned for commissioning in the fourth quarter of 2031, at which point Mauritanian output would fall under CN 2601 12 00 and enter the regulated perimeter for the first time.

Qualifications. The Groupe Industriel des Ciments d'Algérie, which supplied 73 per cent of Mauritanian clinker imports in 2023, publishes no figure for carbon dioxide per tonne of clinker. SNIM's emissions disclosure carries no external assurance. Mauritania publishes no official national grid emission factor. Exhaustive retrieval of binding tariff information rulings and Court of Justice case law was not possible through the public interfaces of those databases. Three sources give three different production figures for 2024 (14.226, 14.7 and 15 million tonnes); all three are reported here without reconciliation.