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

Last checked 2 November 2026

CBAM for Egyptian urea: the default figure, the cost per tonne, and what your EU buyer will ask for

Urea is Egypt's largest CBAM export by far: EUR 1.33bn and 3.29 million tonnes into the EU in 2025, 44% of all the urea the EU bought from outside its borders. This page takes the general rules from the CBAM hub for Egyptian exporters and applies them to urea only.

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At a glance

Status box (checked 2 November 2026)

What applies to urea now

Urea entering the EU since 1 January 2026 carries embedded emissions that the EU importer must cover with CBAM certificates. The first certificates for 2026 imports are surrendered by 30 September 2027.
Egypt has its own default figure for urea: 1.390 tCO2e per tonne for CN 3102 10 19, the line most solid urea falls under (Implementing Regulation (EU) 2025/2621, Annex I, as replaced by Implementing Regulation (EU) 2026/1740).
The mark-up on fertiliser defaults is 1% in 2026 and every year after. It does not rise to 20% or 30% as it does for steel, aluminium and cement.
Indirect emissions (from the electricity the plant uses) count for fertilisers. They do not for steel or aluminium.
Egypt is not exempt in law. An exemption to the end of 2027 was reported by EnterpriseAM on 12 January 2026. Reported, not law. The July 2026 correcting act lists Egypt with its own urea defaults, applying from 1 January 2026.

The next three dates

Date	What happens
1 January 2027	CBAM factor falls from 97.5% to 95%, so the deduction shrinks. Importers must 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.
30 September 2027	First annual declaration and surrender, covering 2026 imports.

What counts as urea under CBAM

Urea sits in heading 3102 of the Combined Nomenclature, which Annex I of Regulation (EU) 2023/956 lists in full as a fertiliser good. Since the 2025 Combined Nomenclature, urea has four eight-digit lines, and each carries a different default. Check yours with your customs broker before you use any figure below.

CN code	What it covers	Egypt default, total (tCO2e per tonne)	Direct / indirect	CBAM benchmark, Column B / Column A
3102 10 19	Urea over 45% nitrogen on the dry product, other than the solutions below (most granular and prilled urea)	1.390	1.320 / 0.080	0.902 / 0.053
3102 10 15	Urea in aqueous solution, over 33.2% and up to 55% urea	0.750	0.720 / 0.020	0.503 / 0.029
3102 10 12	Urea in aqueous solution, 31.8% to 33.2% urea	0.460	0.440 / 0.020	0.304 / 0.018
3102 10 90	Urea with 45% nitrogen or less	1.360	1.290 / 0.070	0.882 / 0.051

Sources: defaults, Implementing Regulation (EU) 2025/2621, Annex I, Egypt table, 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, read from the Commission's Excel of 6 February 2026. Direct and indirect splits are given for information and may not add to the total because of rounding; the certificate count uses the total.

Three points to keep in view:

The Egyptian default is low by EU standards. For 3102 10 19 the figure for countries without their own entry is 2.720, almost double Egypt's 1.390. Egyptian urea starts from a better default than most suppliers.
The two benchmark columns do different jobs. Column B (0.902) is used when the importer declares on the default. Column A (0.053) is the urea process alone, used with actual data, to which the benchmark of the ammonia you consumed is added (1.522 per tonne of ammonia).
Mixtures are separate lines. Urea and ammonium nitrate solution (UAN, 3102 80 00) has its own default of 1.510 and is not covered by this page.

EU imports of urea from Egypt

Year	EUR million	Tonnes	Egypt's share of extra-EU urea, by tonnes
2023	907.7	2,216,300	34.7%
2024	893.8	2,557,273	42.8%
2025	1,325.9	3,286,150	44.3%

By CN line in 2025: 3102 10 19 EUR 1,126.0m and 2,816,805 tonnes; 3102 10 15 EUR 130.3m and 298,781 tonnes; 3102 10 90 EUR 67.3m and 165,029 tonnes; 3102 10 12 EUR 2.3m and 5,534 tonnes.

Source: Eurostat Comext, dataset DS-045409, reporter EU, partner Egypt and partner extra-EU, imports, CN 3102 10 and its eight-digit lines, annual, dataset version of 16 October 2026, queried 2 November 2026. Shares are my division of the Egypt tonnes by the extra-EU tonnes (7,412,286 in 2025). The eight-digit split exists only from 2025, when the lines were created.

By worth, Egypt supplied 45.7% of the urea the EU imported from outside the EU in 2025 (EUR 1,325.9m of EUR 2,902.0m). For an EU fertiliser distributor, Egyptian data quality is a supply question, not a side issue.

The default and the mark-up, year by year

For fertilisers the mark-up is 1% for 2026 and every later year (Implementing Regulation (EU) 2025/2621, Annex I, opening paragraphs, as replaced by (EU) 2026/1740). What changes each year is the CBAM factor, which shrinks the deduction.

Import year	Default used, 3102 10 19 (1.390 x 1.01)	CBAM factor	Deduction on the default (0.902 x factor)	Certificates per tonne on the default
2026	1.4039	97.5%	0.8795	0.5245
2027	1.4039	95%	0.8569	0.5470
2028	1.4039	90%	0.8118	0.5921
2030	1.4039	51.5%	0.4645	0.9394
2034	1.4039	none	0	1.4039

The cross-sectoral correction factor is taken as 1, its maximum; a lower factor shrinks the deduction and raises every line. Egypt has no carbon price, so nothing is deducted for carbon paid at home.

What that means for the whole flow, as an illustration. If the 2,816,805 tonnes of 3102 10 19 that entered the EU in 2025 entered again in 2026, all on the Egyptian default, the importers would owe about 1.48 million certificates. Every EUR 1 of certificate price would then be about EUR 1.48m across the trade. By 2030 the same tonnes would need about 2.65 million certificates, and from 2034 about 3.95 million. This is my arithmetic on the figures above, not a forecast: volumes, the benchmark and the correction factor will all move.

Worked example and calculator

The example uses a fictional plant. The "actual" figure is an assumption chosen to show the arithmetic, not a benchmark for any real Egyptian plant. P is the certificate price in euros per tonne of CO2e, which you take from the Commission's "Price of CBAM certificates" page.

Inputs (illustrative): 10,000 tonnes of urea, CN 3102 10 19, produced and imported in 2026. Verified actual emissions 1.100 tCO2e per tonne (assumed). Ammonia consumed 0.567 tonnes per tonne of urea, the chemical ratio (two molecules of ammonia, 34.06, per molecule of urea, 60.06).

Embedded emissions. Default: 10,000 x 1.4039 = 14,039 tCO2e. Actual: 10,000 x 1.100 = 11,000 tCO2e.
Deduction. Default: 10,000 x 0.902 x 0.975 = 8,794.5 tCO2e. Actual: 10,000 x (0.053 + 0.567 x 1.522) x 0.975 = 8,930.7 tCO2e.
Certificates. Default: 14,039 minus 8,794.5 = 5,244.5. Actual: 11,000 minus 8,930.7 = 2,069.3.
Cost. Default: 5,244.5 x P. Actual: 2,069.3 x P. The gap is 3,175.2 x P: every EUR 1 of certificate price adds EUR 3,175 to the cost of staying on the default.

The break-even. With the chemical ratio of ammonia, a plant is cheaper on actual data only if its verified figure is below about 1.418 tCO2e per tonne in 2026 (1.4039 plus 0.0136 for the slightly larger actual-data deduction). Above that line the default is cheaper, before the cost of monitoring and verification. Because Egypt's default is already low, the case for actual data on urea rests on plants that are clearly below it, or on buyers who insist on verified data whatever the arithmetic.

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. It uses the same formula as the hub: certificates equal embedded emissions minus the benchmark times the CBAM factor, never below zero. For the two solution lines it shows the default only.

What your EU importer and the verifier will ask for

The content of the request is set by the CBAM Regulation and its implementing acts; the template is the importer's own.

The exact CN line, shipment by shipment, matched to the customs declaration. A solution declared under 3102 10 19 instead of 3102 10 15 nearly doubles the default.
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).
Specific embedded emissions per tonne of urea, direct and indirect, for the reporting period, calculated under Implementing Regulation (EU) 2025/2547.
The ammonia precursor: tonnes of ammonia consumed per tonne of urea, where it was made, and its own embedded emissions. Most Egyptian urea plants make their own ammonia on site; if yours buys it in and cannot show the country of origin, a much higher default applies to that ammonia (4.360 tCO2e per tonne, Annex IV of 2025/2621 as replaced).
Electricity: the power used per tonne and the emission factor applied, because indirect emissions count for fertilisers. Default factors for indirect emissions are in Annex II of Implementing Regulation (EU) 2025/2621.
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, because the declaration is annual.

In practice a verifier works from the monitoring plan, gas and power invoices, meter records, production records and the calculation workbook. Assemble them before you appoint one. Ask your buyer early which verifiers they will accept and the date they need your figures for the 30 September declaration.

The lender's view

A bank or development finance institution financing a urea producer reads CBAM as a margin question on EU sales. For urea the arithmetic gives a specific answer.

The gap is small; the bill is not. With a low Egyptian default and a 1% mark-up, the difference between default and actual data stays almost flat over time (3,175 x P in 2026, 3,039 x P in 2034 in the example above). What grows is the bill itself, as the CBAM factor falls: certificates on the default rise from 0.52 to 1.40 per tonne between 2026 and 2034. So for urea, measurement settles the gap and decarbonisation settles the bill.

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

A verified baseline per tonne, direct and indirect, for each CN line sold into the EU. A project that lowers emissions on a plant that stays on defaults changes nothing on the CBAM bill.
The project's effect in tCO2e per tonne of urea, with the method. Most of a urea plant's emissions come from natural gas used in making ammonia, so reformer efficiency, waste heat recovery and steam system work move the number most.
Renewable power counted properly. Because indirect emissions count for fertilisers, a solar plant or a renewable supply contract lowers the CBAM figure for urea, which it would not for aluminium. The effect is small: indirect emissions are 0.080 of Egypt's 1.390 default.
The EU share of sales and who captures the saving. The importer buys the certificates. A pricing clause or a buyer's letter that passes some of the saving back is worth more to the credit file than an estimate.
The result at several certificate prices. The price moves weekly from 2027. A model at one price is a forecast; a table at three prices is a credit case. The calculator above gives the certificate count; multiply by your own range.

Next steps

Confirm the eight-digit CN line of every product you ship to the EU, especially solutions.
Run the calculator at three prices from the Commission's page, for 2026 and 2030, on the default and on your best current estimate.
Ask each EU buyer which basis they will declare on, and when they need your data.
If your estimate is clearly below the break-even, scope monitoring and verification; if not, keep the data file in order and plan decarbonisation against the growing bill.
Read the CBAM hub for Egyptian exporters for the rules common to every product, and the ammonia page if you also sell ammonia.

Frequently asked questions

What is Egypt's CBAM default for urea?

1.390 tCO2e per tonne for CN 3102 10 19, which covers most solid urea, before the 1% mark-up: 1.4039 in use. Urea with 45% nitrogen or less is 1.360; urea solutions are 0.750 and 0.460.

Does the CBAM mark-up for urea rise to 30%?

No. For fertilisers the mark-up is 1% for 2026 and every year after. The 10%, 20% and 30% steps apply to cement, iron and steel, aluminium and hydrogen.

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

On the default, about 0.52 in 2026, 0.55 in 2027, 0.94 in 2030 and 1.40 from 2034, taking the correction factor at 1. Multiply by the certificate price you take from the Commission's page.

Do indirect emissions count for urea under CBAM?

Yes. For fertilisers both direct and indirect emissions count, which is why Egypt's default for urea includes 0.080 tCO2e per tonne of indirect emissions.

Is Egyptian urea exempt from CBAM until 2027?

Not in law at 2 November 2026. An exemption was reported in January 2026, but no legal text contains it, and the EU's July 2026 act sets Egyptian urea defaults applying from 1 January 2026.

Is it worth paying for actual data on urea?

Only if your verified figure is clearly below the break-even, about 1.418 tCO2e per tonne in 2026 at the chemical ratio of ammonia, or if your buyer requires verified data. Run the calculator with your own figures first.

Send me what you received

If your EU buyer, a verifier or your lender has sent you a CBAM request about urea, 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 urea: defaults, costs, what to send". omarhamdy.com, 2 November 2026. https://omarhamdy.com/guides/cbam-egypt-exporters/urea/