CBAM Country Intelligence Tunisia 2026: The Asymmetric Transformation Node, from Phosphate Endowment and Ammonia Dependence to Upstream Carbon Attribution

Executive Summary

Tunisia enters the definitive period of the European Union's Carbon Border Adjustment Mechanism (CBAM) with four EU-facing industrial chains whose embedded emissions are formed in different places. Cement, phosphate fertilisers, aluminium products and processed flat steel all reach the European market from Tunisian installations. In fertilisers, aluminium and steel, the Tunisian plant performs the chemical or physical transformation that creates the traded product, while a carbon-intensive precursor was produced in another installation and usually in another country. In integrated cement production, clinker burning and most of the associated carbon formation remain domestic. The configuration is described here as an asymmetric transformation node: an industrial economy in which transformation location, carbon formation, trade identity and control over verifiable emissions evidence do not coincide. [1][2]

The 2024 trade record shows that each chain is material. Tunisia reported 889,829 tonnes of exports of other Portland cement under HS 252329 and 148,976 tonnes of clinker exports under HS 252310, while also importing 304,321 tonnes of clinker; EU importer records show 704,743 tonnes of the cement and 60,794 tonnes of the clinker arriving from Tunisia. [3][4] Tunisia exported 223,571 tonnes of diammonium phosphate (DAP), of which EU importers recorded 99,265 tonnes, and it imported 111,181 tonnes of anhydrous ammonia, about 80,112 tonnes from Egypt and 31,066 tonnes from Algeria. [5][6] Galvanised flat steel under HS 721049 reached 99,693 tonnes of exports, with EU importers recording 96,827 tonnes, and Tunisia imported about 17,158 tonnes of unwrought aluminium while exporting 3,509 tonnes of alloy profiles. [7][8]

Tunisia has its own entry in the default-value tables of Commission Implementing Regulation (EU) 2026/1740, covering cement, fertilisers, aluminium and hydrogen. The entry contains no iron and steel section. Grey Portland cement carries a total default of 0.910 tCO2e per tonne, DAP 0.520, and aluminium alloy profiles 1.000 on the secondary-aluminium route, whereas galvanised flat steel under CN 7210 49 00 inherits the "Other countries and territories" value of 4.101 on the blast-furnace route, or 4.511 after the 2026 mark-up, provided the Bizerte output holds Tunisian non-preferential origin. [9][1] Applied to 2024 EU import volumes at the first-quarter 2026 certificate price of €75.36 and the cross-sectoral correction factor of 100 per cent fixed for 2026 to 2030, the default pathway yields an indicative obligation of about €44 million a year across the five principal flows. Galvanised steel accounts for about €22.3 million and cement for about €18.7 million, even though EU-bound cement tonnage is more than seven times larger. [10][11][12]

The most Tunisia-specific configuration is phosphate endowment and ammonia dependence. Groupe Chimique Tunisien (GCT) transforms more than 80 per cent of national phosphate production into acid and fertilisers, and its Gabès complex produces DAP from phosphoric acid and imported ammonia; the national hydrogen strategy states that Tunisia has no domestic ammonia production. [13][14] Under the precursor rules, the documented origin of that ammonia carries a measurable value. A tonne of standard DAP contains about 0.219 tonnes of ammonia, so replacing the highest-default value for unidentified ammonia with the Egyptian or Algerian country default lowers embedded emissions by roughly 0.5 tCO2e per tonne of DAP, about €38 at the first-quarter price. [9][2]

Flat steel is the clearest downstream-transformation case. SM Tunis Acier, a joint venture of Marcegaglia Carbon Steel and Sideralba, pickles, cold-rolls and galvanises coil in Bizerte, and Italy and Spain absorbed more than 92 per cent of Tunisia's HS 721049 exports in 2024. [15][7] Tunisia's hot-rolled flat-steel imports came predominantly from China by value. [16] The origin of the galvanised output decides which default table applies: Tunisian origin leads to the fallback of 4.101, while Chinese origin would lead to China's value of 3.205. From 1 July 2026 the same flow also falls under the tariff-quota regime of Regulation (EU) 2026/1384, which requires importers to identify the country where the steel was melted and poured, the same upstream information that CBAM precursor attribution demands. [9][17]

Aluminium combines imported primary metal, mainly from Bahrain and the United Arab Emirates, with a domestic secondary loop operated by Alufond, a 99.83 per cent subsidiary of Tunisie Profilés Aluminium (TPR). [8][18] Tunisia's default entry assigns the secondary route to its aluminium goods, while an actual-value declaration for a profile made from Bahraini primary billet would carry a higher gross value and a much larger free-allocation adjustment. With the correction factor at 100 per cent, the actual pathway gives a net value of about 0.61 tCO2e per tonne against 0.95 on defaults, at one tonne of billet per tonne of profile and before Tunisian process emissions. [9][10]

Cement defines the boundary of the concept. Carthage Cement produced 1,615,628 tonnes of clinker and 1,859,578 tonnes of cement in 2024, keeping the main carbon-forming stage inside Tunisia. [19][20] Les Ciments de Bizerte (SCB) produced no clinker in 2024, after it could not finance petroleum coke for its kiln, and ground purchased clinker into 129,293 tonnes of cement; in January 2026 it bought 30,000 tonnes of clinker from Carthage Cement. [21][22] The installation kept its corporate label while its physical role in the chain changed, a pattern described here as industrial identity drift.

Tunisia's CBAM position between 2026 and 2030 depends on physical decarbonisation and on upstream carbon attribution: identifying the installation, production route, reporting period and verifiable emissions of each precursor that entered a Tunisian production process. Commission Implementing Regulation (EU) 2025/2547 applies weighted averaging to precursors received from multiple installations unless evidence supports installation-specific attribution, and it allows actual process emissions to be combined with default precursor values. [2] Tunisia has no carbon price that could be deducted under Article 9. [23] The national green-ammonia pilot at Gabès is sized at about 630 tonnes a year, and the ELMED interconnector, a 600 MW bidirectional link to Sicily whose procurement was completed in June 2026, will add a future electricity exposure once power flows from Tunisia into Italy. [14][24] For cement the main lever is kiln and clinker performance; for DAP, ammonia sourcing and its documentation; for aluminium, the secondary share and route evidence; and for flat steel, substrate procurement and mill-level data.