Guides. Omar Hamdy, on the lender's side, in Cairo. Written in a personal capacity.

Last checked 2 November 2026

CBAM for Egyptian cement and clinker: the defaults, the clinker ratio, and why tonnes matter more than euros

Cement is Egypt's smallest CBAM group by worth, EUR 90.2m in 2025, but the second largest by weight: 1.65 million tonnes, most of it clinker. Because cement is cheap per tonne and carbon-heavy, the CBAM cost per euro of sales is higher than for any other Egyptian line. This page applies the CBAM hub for Egyptian exporters to clinker and cement.

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At a glance

Status box (checked 2 November 2026)

What applies to cement now

Cement and clinker entering the EU since 1 January 2026 carry embedded emissions that the EU importer must cover with CBAM certificates; the first surrender, for 2026 imports, is due by 30 September 2027.
Egypt's default for grey clinker is 1.270 tCO2e per tonne and for grey Portland cement 1.290 (Implementing Regulation (EU) 2025/2621, Annex I, as replaced by Implementing Regulation (EU) 2026/1740).
The mark-up on cement defaults is 10% in 2026, 20% in 2027 and 30% from 2028.
Indirect emissions (from the electricity the plant uses, mostly for grinding) count for cement.
Egypt is not exempt in law. A reported exemption to the end of 2027 (EnterpriseAM, 12 January 2026) is reported, not law.

The next three dates

Date	What happens
1 January 2027	Mark-up rises to 20%; CBAM factor falls to 95%; importers hold certificates for at least 50% of embedded emissions at the end of each quarter.
1 February 2027	Certificate sales open on the common central platform.
1 January 2028	Mark-up rises to 30%, its final level; CBAM factor 90%.

What counts as cement under CBAM

Annex I of Regulation (EU) 2023/956 covers heading 2523 (cement and clinker) and calcined kaolinic clay (2507 00 80). The default and the benchmark depend on whether the product is grey or white, and whether it is clinker or finished cement.

CN or TARIC code	What it covers	Egypt default, total (tCO2e per tonne)	Direct / indirect	CBAM benchmark, Column B / Column A	Default for countries without their own entry
2523 10 00 90	Grey clinker and other clinker	1.270	1.240 / 0.030	0.666 / 0.666	1.410
2523 10 00 10	White clinker	1.330	1.290 / 0.040	0.859 / 0.859	1.370
2523 29 00	Grey Portland cement	1.290	1.240 / 0.050	0.666 / 0 plus clinker	1.440
2523 21 00	White Portland cement	1.390	1.250 / 0.130	0.859 / 0 plus white clinker	1.450
2523 90 00 90	Other hydraulic cements, grey	1.240	1.180 / 0.060	0.666 / 0 plus clinker	1.370

Sources: defaults, Implementing Regulation (EU) 2025/2621, Annex I, tables "Egypt" and "Other countries and territories", as replaced by (EU) 2026/1740, read from the Commission's Excel transcription of 6 August 2026 (the regulation is the binding text). Benchmarks, Implementing Regulation (EU) 2025/2620, Annex, Commission Excel of 6 February 2026. Direct and indirect figures may not add to the total because of rounding.

Column A is zero for finished cement. On actual data, the deduction for cement comes only from the clinker in it: the clinker benchmark times your clinker ratio. On the default, the full 0.666 applies. This is why the clinker ratio is the single most important number in an Egyptian cement exporter's CBAM file.

Where the country of production of clinker used in cement cannot be identified, Annex IV of 2025/2621 (as replaced) applies 1.440 tCO2e per tonne of grey clinker.

EU imports of cement and clinker from Egypt

Year	All of 2523, EUR m	All of 2523, tonnes	Clinker (2523 10), tonnes	White Portland (2523 21), tonnes	Grey Portland (2523 29), tonnes
2023	38.1	461,120	307,871	152,221	1,028
2024	72.0	1,222,806	1,040,645	163,634	18,521
2025	90.2	1,646,843	1,350,005	155,662	141,148

In 2025, Egypt supplied 18.9% of the clinker, 21.5% of the white Portland cement and 2.4% of the grey Portland cement the EU imported from outside the EU, by tonnes.

Source: Eurostat Comext, dataset DS-045409, reporter EU, partners Egypt and extra-EU, imports, CN 2523 and its eight-digit lines, annual, dataset version of 16 October 2026, queried 2 November 2026. Shares are my division of Egypt's tonnes by extra-EU tonnes (7,147,931 for clinker, 724,021 for white and 5,765,759 for grey Portland cement in 2025). Comext reports clinker at eight digits, so white and grey clinker cannot be separated in this data.

Clinker sales to the EU more than quadrupled between 2023 and 2025. In euros it is a small trade, EUR 58.4m in 2025, about EUR 43 a tonne on my division. The CBAM cost on a tonne of clinker can be a large share of that price, which is why cement is the line where CBAM weighs most on price.

The default and the mark-up, year by year

Import year	Mark-up	CBAM factor	Grey clinker: default used	Grey clinker: certificates per tonne	Grey cement: default used	Grey cement: certificates per tonne
2026	10%	97.5%	1.397	0.748	1.419	0.770
2027	20%	95%	1.524	0.891	1.548	0.915
2028	30%	90%	1.651	1.052	1.677	1.078
2030	30%	51.5%	1.651	1.308	1.677	1.334
2034	30%	none	1.651	1.651	1.677	1.677

Sources: mark-ups, Implementing Regulation (EU) 2025/2621, Annex I, opening paragraphs, as replaced by (EU) 2026/1740; CBAM factor, Directive 2003/87/EC, Article 10a(1a); benchmark 0.666 (Column B) from 2025/2620. The cross-sectoral correction factor is taken as 1, its maximum. Egypt has no carbon price, so nothing is deducted for carbon paid at home.

For the whole flow, as an illustration. If the 1,350,005 tonnes of clinker of 2025 entered again, all on the Egyptian grey clinker default, importers would owe about 1.01 million certificates in 2026, 1.42 million in 2028 and 2.23 million from 2034: about two thirds of what the whole urea trade needs in 2026, on a trade worth about a twentieth as much. This is my arithmetic, taking all the clinker as grey, not a forecast.

Worked example and calculator

The plant is fictional and the "actual" figures are assumptions chosen to show the arithmetic, not a benchmark for any real Egyptian plant. P is the certificate price in euros per tonne of CO2e, from the Commission's "Price of CBAM certificates" page.

Inputs (illustrative): 10,000 tonnes of grey Portland cement, CN 2523 29 00, produced and imported in 2027. Verified embedded emissions, direct plus indirect and including the clinker, 0.800 tCO2e per tonne of cement (assumed). Clinker ratio 0.85 tonnes of clinker per tonne of cement (assumed).

Embedded emissions. Default: 10,000 x 1.290 x 1.20 = 15,480 tCO2e. Actual: 10,000 x 0.800 = 8,000 tCO2e.
Deduction. Default: 10,000 x 0.666 x 0.95 = 6,327 tCO2e. Actual: 10,000 x (0 + 0.85 x 0.666) x 0.95 = 5,378 tCO2e.
Certificates. Default: 9,153. Actual: 2,622.
Cost. Default: 9,153 x P. Actual: 2,622 x P. The gap is 6,531 x P: every EUR 1 of certificate price adds about EUR 0.65 per tonne of cement to the cost of staying on the default.

The break-even. With a clinker ratio of 0.85, actual data is cheaper for grey cement when the verified figure is below about 1.322 tCO2e per tonne in 2026, 1.453 in 2027 and 1.587 in 2028. For grey clinker the deduction is the same on both bases, so the line is simply the default with its mark-up: 1.397, 1.524 and 1.651. A lower clinker ratio lowers the actual figure but also the actual deduction; the calculator shows the net effect.

Work it out: certificates and cost

CN line

Import year

Tonnes imported into the EU

Certificate price P, EUR per tonne of CO2eType the current figure from the Commission's page. This site states no price.

Your verified emissions, tCO2e per tonne (optional)Direct plus indirect where they count. Leave empty to see the default only.

Illustrative arithmetic on public figures, not advice for a shipment. Cross-sectoral correction factor taken as 1, its maximum; a lower factor shrinks the deduction. No carbon price paid in Egypt is deducted.

Defaults: Implementing Regulation (EU) 2025/2621 as replaced by 2026/1740. Benchmarks: 2025/2620. CBAM factor: Directive 2003/87/EC, Article 10a(1a).

The calculator runs in your browser and sends nothing. For finished cement, type your clinker ratio to see the actual-data result. Certificates equal embedded emissions minus the benchmark times the CBAM factor, never below zero.

What your EU importer and the verifier will ask for

The CN or TARIC line, shipment by shipment, matched to the customs declaration: grey or white, clinker or cement.
Installation identity: operator, address, coordinates and main activity, the fields used to register an installation in the EU CBAM registry (Article 10 of Regulation (EU) 2023/956). A grinding plant that buys clinker is a separate installation from the kiln that made it.
Direct emissions per tonne of clinker, for the reporting period, calculated under Implementing Regulation (EU) 2025/2547: process emissions from calcining limestone and combustion emissions from kiln fuels, with the share of alternative fuels and biomass.
Indirect emissions: the power used per tonne of clinker and of cement and the emission factor applied. Default factors for indirect emissions are in Annex II of Implementing Regulation (EU) 2025/2621.
The clinker ratio of each cement type, with production records behind it, and where the clinker was made.
A verification report from an accredited verifier, if the importer is to declare on actual data (Article 8 and Annex VI).
A named contact and a date for next year's update.

The lender's view

Cement has the steepest CBAM cost per euro of sales. At about EUR 43 a tonne of clinker on the 2025 trade figures and about 0.75 certificates a tonne on the default in 2026, the certificate cost can be a large share of the selling price. A lender to an exporting cement plant should read EU sales as the most exposed part of the book and test them at several certificate prices.

What a lender wants to see before counting a CBAM benefit in a decarbonisation loan:

A verified baseline per tonne of clinker and of each cement type, direct and indirect. A cut in emissions at a plant that stays on defaults changes nothing on the bill.
The lever, measured. Most of a cement plant's emissions come from limestone and kiln fuel. Alternative fuels and waste-derived fuels, kiln and cooler efficiency, and a lower clinker ratio through supplementary materials move the figure. Waste heat recovery and renewable power reduce indirect emissions, which count for cement.
The clinker ratio effect calculated both ways. A lower ratio reduces embedded emissions and the actual-data deduction together. The calculator shows the net.
Who captures the saving. The importer buys the certificates. On a low-priced product a pricing clause that shares the saving may decide whether the trade survives.
The result at several certificate prices and for 2026 to 2028, as the mark-up rises to 30%.

Next steps

Confirm the CN or TARIC line of every product you ship to the EU: grey or white, clinker or cement.
Run the calculator for 2026, 2027 and 2028 at three prices from the Commission's page, using your own clinker ratio.
Ask each EU buyer which basis they will declare on and when they need your data.
If your kiln and grinding data are already metered, scope verification before 2028.
Read the CBAM hub for Egyptian exporters for the rules common to every product.

Frequently asked questions

What is Egypt's CBAM default for cement and clinker?

1.270 tCO2e per tonne for grey clinker, 1.290 for grey Portland cement, 1.330 for white clinker and 1.390 for white Portland cement, before the mark-up.

What mark-up applies to cement defaults?

10% in 2026, 20% in 2027 and 30% from 2028 onwards.

Why does the clinker ratio matter so much under CBAM?

On actual data, the deduction for finished cement comes only from the clinker in it, at 0.666 tCO2e per tonne of clinker for grey cement. A tonne of cement with less clinker has lower emissions and a smaller deduction; the net decides the bill.

Do indirect emissions count for cement?

Yes. Electricity used, mostly for grinding, counts for cement, so renewable power and waste heat recovery can lower the CBAM figure.

How many CBAM certificates does a tonne of Egyptian clinker need?

On the grey clinker default, about 0.75 in 2026, 0.89 in 2027, 1.05 in 2028 and 1.65 from 2034, taking the correction factor at 1.

Send me what you received

If your EU buyer, a verifier or your lender has sent you a CBAM request about cement or clinker, send it to me in five short lines: what you received, from whom, the deadline, your sector, and what you want to know. I'll reply by email.

Send me what you received How engagements run

Guides, checks, toolkit and newsletter are free. Advisory is paid work in a personal capacity: scope agreed in writing, fee quoted after a free first call.

I don't arrange finance, introduce lenders or work on files for my employer's credit decisions. Every enquiry gets a conflicts check before any work.

Sources

All views are my own, written in a personal capacity. They do not represent my employer or any other institution. This page explains public rules; it is not legal or tax advice for a specific shipment.

Cite this guide

Hamdy, O. (2026) "CBAM for Egyptian cement and clinker: defaults, costs". omarhamdy.com, 2 November 2026. https://omarhamdy.com/guides/cbam-egypt-exporters/cement/