Omar Hamdy.

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

Data retrieved

CN 3105 40 00: Monoammonium phosphate (MAP)

An EU importer that declares this line on default figures uses 0.330 tCO2e per tonne for goods from Egypt, plus a mark-up. In 2025 the EU imported 5,560 tonnes of it from Egypt, worth EUR 3,733,221.

The default that applies to Egypt

The table gives direct emissions of 0.290, indirect emissions of 0.040 and a total of 0.330 tCO2e per tonne. The direct and indirect figures are for information; the certificate count uses the total (2026/1740, recital 10).

For comparison, the table for other countries and territories gives 0.510 for the same line.

No route is indicated: the CBAM benchmark for this line does not depend on the production route.

The mark-up schedule

YearMark-upDefault with mark-up, tCO2e per tonne
20261%0.3333
20271%0.3333
2028 onwards1%0.3333

For fertilisers the mark-up is 1% in every year from 2026. It applies to the total. The figures with the mark-up are my arithmetic; the binding figure is calculated in the CBAM Registry (2026/1740, recital 10).

Trade with the EU in 2025

Year
2025
Tonnes
5,560
Amount, EUR
3,733,221
Comext code and label
31054000Ammonium dihydrogenorthophosphate "monoammonium phosphate", whether or not mixed with diammonium hydrogenorthophosphate "diammonium phosphate" (excl. that in tablets or similar forms, or in packages with a gross weight of <= 10 kg)(1998-2500);Ammonium dihydrogenorthophosphate 'monoammonium phosphate', whether or not mixed with diammonium hydrogenorthophosphate 'diammonium phosphate' (excl. that in pellet or similar forms, or in packages with a gross weight of =< 10 kg)(1988-1990)
Source
Eurostat Comext DS-045409, EU imports from Egypt, 2025; dataset updated 16 October 2026. Tonnes are Comext's quantity in 100 kg divided by 10, rounded.

What this means in plain words

On default figures, each tonne shipped in 2026 is declared with 0.3333 tCO2e: the default of 0.330 times one plus the 1% mark-up. At the 2025 volume of 5,560 tonnes, that is about 1,853 tCO2e of embedded emissions on defaults (my arithmetic).

The mark-up stays at 1% in later years.

The importer does not buy a certificate for every one of those tonnes: it deducts a benchmark amount that shrinks each year until 2034. The calculator on the CBAM for Egyptian ammonia page does that step; this line is not among its lines, so use the default above in the same way.

Verified actual data from the plant replaces the default, and no mark-up is added to it.

Where to go next

Sources

  1. Commission Implementing Regulation (EU) 2026/1740 of 20 July 2026 correcting Implementing Regulation (EU) 2025/2621 as regards Annexes I and IV thereto: default figures, mark-ups and route indicators eur-lex.europa.eu
  2. European Commission, 'Default values definitive period (Excel format)', file 'DV correcting act_final update_06.08.xlsx' (version 2 of 6 August 2026, listed on the page as 10 August 2026; for information only, not legally binding): cross-check only; the regulation is binding taxation-customs.ec.europa.eu
  3. Commission Implementing Regulation (EU) 2025/2547 on the methods for calculating embedded emissions, Annex I, point 2, Table 1 'Mapping of CN codes to aggregated goods categories': aggregated goods categories eur-lex.europa.eu
  4. Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism, Annex I (goods in scope), as amended by Regulation (EU) 2025/2083: goods in scope eur-lex.europa.eu
  5. Eurostat Comext, dataset DS-045409 'EU trade since 1988 by HS2-4-6 and CN8', reporter EU, partner Egypt (EG), flow imports, indicators VALUE_IN_EUROS and QUANTITY_IN_100KG, annual 2025: 2025 trade, dataset updated 16 October 2026 ec.europa.eu
  6. European Commission, CBAM legislation and guidance (section 'Default values and benchmarks'): the Commission's page on default figures and benchmarks taxation-customs.ec.europa.eu

Dataset retrieved 2 November 2026.

Download the data, CSVDownload the data, JSON

Compilation by Omar Hamdy, licensed CC BY 4.0: reuse it with credit to Omar Hamdy, omarhamdy.com. The figures come from EU legal texts and the Commission's Excel file of defaults (© European Union, reuse authorised under Commission Decision 2011/833/EU) and from Eurostat Comext (© European Union, reuse with acknowledgement of the source under Eurostat's copyright notice). The electricity line is left out: its figures are IEA data under a non-commercial licence.

In a personal capacity. An explanation of published rules and data, not legal or tax advice for a specific shipment.