Decarbonisation Strategy in Morocco: Plan, Levers and Pathway

What is a decarbonisation strategy, and how does it differ from a carbon footprint?

A decarbonisation strategy is the plan that brings your greenhouse gas emissions down: which levers, in which order, towards which target, with which owners and which monitoring. The carbon footprint is its baseline: the footprint measures, the strategy decides.

A corporate footprint is calculated under ISO 14064-1:2018 — Greenhouse gases — Part 1: Specification with guidance at the organization level for quantification and reporting of greenhouse gas emissions and removals, or under the GHG Protocol Corporate Standard (Revised Edition, 2004), with the Scope 2 Guidance (2015) and the Corporate Value Chain (Scope 3) Standard (2011). Both are under revision: iso.org showed working draft ISO/WD 14064-1.2 at stage 20.60 on 11 November 2026, and the GHG Protocol and ISO are preparing a consolidated standard with publication estimated for the fourth quarter of 2028. The current editions remain the reference; see our carbon footprint ISO 14064 page.

• Scope 1: direct emissions from sources you own or control (boilers, kilns, vehicles, refrigerants, processes).
• Scope 2: emissions from the electricity, steam, heat or cooling you purchase.
• Scope 3: all other emissions in your value chain, upstream (purchased goods, transport) and downstream (transport, use and end of life of products).

A credible strategy rests on four elements: a baseline that can be recalculated, levers quantified in tonnes of CO2e avoided, a target linked to those levers, and annual monitoring of planned versus actual.

Why should a Moroccan manufacturer decarbonise now?

Because three of its counterparts already ask for it: European buyers, CBAM importers and financiers. None of them stops at the footprint; all of them ask what the company is doing to reduce it.

European buyers. Your scope 1 and 2 emissions are part of your customers’ scope 3. Customers with reduction targets ask their suppliers for data, then targets, then evidence of action, usually through ESG questionnaires: see CSRD, VSME and ESG questionnaires.

The CBAM. Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083, has applied in its definitive regime since 1 January 2026 to imports of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. The EU importer declares the embedded emissions of the goods and surrenders certificates; certificate sales on the common central platform start on 1 February 2027; an importer whose cumulative net mass of imports does not exceed 50 tonnes per calendar year is exempt. When the importer declares the installation’s actual values rather than the Commission’s default values, every tonne the Moroccan plant avoids reduces the emissions its customer declares: decarbonisation becomes a sales argument. See CBAM for exporters.

Lenders and banks. ESR 3 of the EBRD’s 2024 Environmental and Social Policy covers resource efficiency and pollution prevention and control: see EBRD and IFC ESG requirements and our guide to the EBRD performance requirements. Banks also assess their borrowers’ climate risk: see climate risk and ISSB.

There is a simpler reason too: on an industrial site, energy is both a major source of emissions and a cost that weighs on margins. The first decarbonisation levers are also competitiveness levers.

Which abatement levers apply, scope by scope?

Levers are classified by scope and by site. The table shows, for each one, which data you need and who usually owns the action.

The table deliberately gives no emission factor and no quantified saving: both depend on your site, and every figure in your plan must be traceable to its source.

Energy efficiency and ISO 50001

It is usually the first lever studied: it cuts both emissions and the energy bill, and the meters measure it. ISO 50001:2018 — Energy management systems — Requirements with guidance for use (which replaced ISO 50001:2011, amended by ISO 50001:2018/Amd 1:2024) structures the approach: energy review, significant uses, indicators, baseline, action plans, measurement and verification. Energy audits follow ISO 50002-1:2025 (formerly ISO 50002:2014), with ISO 50002-3:2025 for processes.

In Morocco, Law 47-09 on energy efficiency, promulgated by Dahir 1-11-161 of 29 September 2011, provides for a mandatory energy audit. Its implementing Decree 2-17-746 of 10 April 2019 makes it mandatory for industry above a total final energy consumption of 1,500 tonnes of oil equivalent per year, with a new audit within five years, carried out by an approved energy audit body, and annual reporting of energy data to AMEE, the Moroccan Agency for Energy Efficiency. Under its Article 3, activities covered by an energy management system certified to the Moroccan standards in force are exempt from the mandatory audit while the certification is valid. Details on our ISO 50001 and energy audit page.

Renewable self-generation: what Moroccan Law 82-21 allows

Law 82-21 on self-generation of electricity, promulgated by Dahir 1-23-21 of 10 February 2023 (Arabic text in Official Bulletin No. 7173 of 27 February 2023), allows a company to generate electricity exclusively for its own consumption, whatever the source. It sets three regimes:

• declaration: installations not connected to the grid, or connected at low voltage below a capacity threshold set by regulation;
• grid-connection agreement from the grid operator: from that threshold up to 5 megawatts, at low or medium voltage;
• authorisation from the administration: from 5 megawatts, at medium, high or very high voltage, with a right of access to the grid to carry power from a generation site to a consumption site, under conditions.

The self-generator may sell to the grid operator a surplus capped at 20% of its annual output, at a tariff set by the National Electricity Regulatory Authority; when connected, it also pays a contribution for system and distribution services. The law also provides for storage and for a certificate of origin for the renewable electricity produced, useful evidence for scope 2. Provisions that require implementing texts only enter into force when those texts are published. The implementing decree has been published: Decree 2-25-100 of 15 Ramadan 1447 (5 March 2026) setting the conditions and procedures for building and operating self-generation installations, Arabic text in Official Bulletin No. 7489 of 9 March 2026 (general edition). It makes installations below 11 kilowatts subject to declaration, those from 11 kilowatts to 5 megawatts subject to a grid-connection agreement, and those of 5 megawatts and above subject to authorisation; it enters into force three months after its publication in the Official Bulletin (Article 29). The certificate of origin is governed by Decree 2-24-761 of 22 October 2024, adopted under Article 6 bis of Law 13-09 and Article 16 of Law 82-21 (Arabic text in Official Bulletin No. 7352 of 14 November 2024, official French translation in No. 7506 of 7 May 2026): applications are filed on the “National Register of Certificates of Origin”, and the decree enters into force twelve months after its publication (Article 12). As of 11 November 2026, no text on raising the 20% cap or on storage has been published in the Official Bulletin (general editions checked up to No. 7559 of 9 November 2026).

The other route is buying renewable electricity from a private producer connected to the grid, under Law 13-09 on renewable energy, promulgated by Dahir 1-10-16 of 11 February 2010, as amended and supplemented. It was amended by Law 58-15 (Dahir 1-16-3 of 12 January 2016, Official Bulletin No. 6433 of 25 January 2016) and Law 40-19 (Dahir 1-23-20 of 10 February 2023, Official Bulletin No. 7173 of 27 February 2023). In its version consolidated on 27 February 2023, published on the Ministry of Justice legal portal, the law allows a renewable installation to connect to the grid at low, medium, high or very high voltage, within the grid’s hosting capacity (Article 5), and gives the producer a right of access to these four voltage levels under an agreement with the grid operator (Article 24). A producer may supply a consumer or a group of consumers connected to the national grid, under a contract in which they undertake to take and consume the electricity exclusively for their own use (Article 26). At low and medium voltage, applying the law, including grid access, depends on conditions set by regulation (Article 5).

Logistics, suppliers and circularity: scope 3

For an exporter, scope 3 can outweigh the plant itself. Three levers address it:

• Transport, quantified under ISO 14083:2023 (formerly IWA 16:2015) — Greenhouse gases — Quantification and reporting of greenhouse gas emissions arising from transport chain operations.
• Suppliers: ask the largest ones for primary data first, then targets, then plans, the same logic your customers apply to you. See also supply chain due diligence.
• Circularity: ISO 59004:2024 (vocabulary, principles and guidance), ISO 59010:2024 (transition of business models and value networks) and ISO 59020:2024 (measuring and assessing circularity performance). All three are under revision, at stage 20.60 on iso.org on 11 November 2026. For packaging, see PPWR packaging and our PPWR guide for non-EU exporters.

When a customer asks for the footprint of a specific product rather than the company, move to a product carbon footprint under ISO 14067.

How do you prioritise the actions in a decarbonisation plan?

By ranking each lever on the tonnes of CO2e it avoids, its cost per tonne avoided calculated with your own data, its lead time and its feasibility. Profitable, quick actions come first; heavy investments follow the equipment replacement cycle.

The standard tool is the marginal abatement cost curve: each action is a bar whose width is the tonnes avoided per year and whose height is the net cost per tonne, energy savings included. On the left sit actions with a negative net cost: the “no-regret” actions. We build it from your quotes and invoices, never from generic values. Four criteria complete it:

1. Lead time: an action that needs a line shutdown waits for the planned shutdown.
2. Lock-in risk: replacing a boiler with a new one burning the same fuel can rule out electrification for the equipment’s whole life.
3. Dependencies: self-generation is sized after energy savings, not before.
4. Commercial value: a reduction on a CBAM installation or on a product a key customer asks about may come before a more profitable action the market never sees.

Which target: SBTi, net zero or carbon neutrality?

They are three different things: an SBTi target is a reduction target validated by a third party, net zero is a long-term end state, and carbon neutrality is a claim about a period or a product that allows offsetting. A decarbonisation strategy starts with reduction; the rest comes later, and only when it can be demonstrated.

For the SBTi, the effective date given in the V2.0 version history is 1 February 2027, and validation against V2.0 opens in the first quarter of 2027, so a company preparing a file now chooses its version knowingly. On the ISO side, ISO/DIS 14060 is only a draft: we announce neither its content nor its date, and a net zero framework today relies on IWA 42:2022 and the SBTi standard.

What makes a pathway credible?

A pathway is the year-by-year curve of planned emissions up to the target. It is credible when each step matches dated actions in the plan. A straight line between two points, with no action behind it, is only an intention.

How do you govern and monitor the plan over time?

With a named owner, a committee that arbitrates, indicators reviewed every year and an inventory recalculated with a stable method. Without monitoring, the plan becomes a communication document.

• One lead reporting to top management, with a relay on each site.
• An annual review built into the management review of your ISO 14001:2026 (formerly ISO 14001:2015) or ISO 50001:2018 system rather than one more committee: see ISO 14001 certification.
• Two families of indicators: outcome indicators (tonnes of CO2e by scope, intensity per tonne produced) and progress indicators (actions launched, investments committed, share of renewable electricity).
• A written recalculation policy for acquisitions, divestments, method changes or material errors.
• Traceable emission factors (source and year), so that year-on-year changes reflect your actions, not a new factor.

What can you say publicly about your climate targets?

What you can prove. Since 27 September 2026, EU rules on unfair commercial practices strictly govern climate claims made to EU consumers. A Moroccan exporter is concerned as soon as its claims appear on products or communications aimed at those consumers, directly or through its customer.

Directive (EU) 2024/825 of 28 February 2024, which amends Directives 2005/29/EC and 2011/83/EU to empower consumers for the green transition, had to be transposed by 27 March 2026 and applies from 27 September 2026. Two rules bear directly on a decarbonisation plan:

• Offsetting cannot support a product claim. Claiming, based on greenhouse gas offsetting, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions is banned in all circumstances.
• Future claims need a verified plan. A claim about future environmental performance is misleading unless it comes with clear, objective, publicly available and verifiable commitments, set out in a detailed and realistic implementation plan with measurable, time-bound targets, regularly verified by an independent third-party expert whose findings are made available to consumers.

A “net zero by 2040” statement on packaging sold to EU consumers therefore requires a detailed plan, milestones, resources and independent verification. Our position: reduction first, claims only once demonstrated.

How can a decarbonisation plan be financed?

Action by action, matching each one with the type of financing suited to its size and risk profile. We describe the options; the decision and the terms belong to the financier.

ACG promises no financing: whether a file is accepted depends on the financier and on your situation.

Is your decarbonisation plan credible?

Review these points with management, engineering, purchasing and finance.

• The baseline inventory is written and can be recalculated, with the source and year of each emission factor.
  
• Scopes 1, 2 and 3 are covered, and any excluded scope 3 categories are justified.
  
• Each lever is linked to a site, a scope, an owner and an estimate of tonnes avoided.
  
• Actions are prioritised with your own cost and savings data, not generic averages.
  
• The target names its framework and version (for example SBTi Corporate Net-Zero Standard V1.3.1 or V2.0).
  
• Each step of the pathway matches dated actions in the plan.
  
• Top management has approved the plan and allocated resources.
  
• The base-year recalculation policy is written.
  
• No neutrality or net zero claim is published without a verifiable plan, in line with Directive (EU) 2024/825.
  
• Applicable Moroccan texts (energy audit under Law 47-09, self-generation under Law 82-21) are part of your regulatory watch.
  

What ACG does in decarbonisation

ACG supports manufacturers and exporters in Morocco and Africa. The firm counts 502 projects, 10 in-house consultants and more than 100 qualified external experts, and has trained more than 120,000 people. We calculate, structure the plan and prepare the files; target validation belongs to the SBTi, verification to an accredited body.

We start from your existing systems. For your sector, see industry and energy and packaging; for the wider ESG picture, see ESG and CSR. Your teams can train with our training catalogue (GHG inventory, ISO 50001, energy audit). To discuss your plan, describe your project.