Which carbon tax are we talking about: Morocco’s or the EU CBAM?
This article is about a national carbon tax that the Moroccan State would levy on greenhouse gas emissions. It is not the EU Carbon Border Adjustment Mechanism (CBAM), which applies to goods imported into the EU and which the Moroccan press often calls a “carbon tax”.
The two get mixed up because they are linked: the EU regulation takes account of a carbon price paid in the country of production. If you buy cement, fertiliser, steel or aluminium from Morocco, or export them, you will meet three different mechanisms.
Moroccan carbon tax | EU CBAM | UK CBAM | |
|---|---|---|---|
Legal basis | Article 7 of framework law No. 69-19 (principle only) | Regulation (EU) 2023/956, amended by Regulation (EU) 2025/2083 | SI 2026/995 and Finance Act 2026 |
Status on 11 November 2026 | Not created | Definitive period since 1 January 2026 | Applies from 1 January 2027 |
Who pays | No one so far | The authorised CBAM declarant in the EU | The UK importer |
What the Moroccan producer supplies | Nothing so far | Verified embedded emissions of its goods | Emissions verified under UK rules |
For the EU mechanism, see our page on CBAM for exporters and our article on the CBAM definitive period; for the UK, our article on UK CBAM 2027.
Is a carbon tax in force in Morocco?
No. As of 11 November 2026, no published text creates a carbon tax in Morocco: not the 2025 or 2026 finance laws, and not the circulars of the Customs and Indirect Taxes Administration (ADII), Morocco’s customs and excise authority.
We read these official texts on 11 November 2026:
- Finance Law No. 50-25 for the 2026 budget year, enacted by dahir (royal decree) No. 1-25-67 of 10 December 2025 and published in Official Bulletin No. 7465 bis of 16 December 2025: none of its tax or customs provisions creates a carbon tax, and the word “carbone” does not appear in it.
- Finance Law No. 60-24 for the 2025 budget year: same finding.
- ADII circular No. 6702/210 of 26 December 2025, which sets out the customs provisions of the 2026 finance law: no carbon tax. In the ADII circulars database, a search for “carbone” returns only one circular on tobacco, which refers to the carbon monoxide content of cigarettes.
For a Moroccan company, there is therefore no return, payment or record to prepare for a national carbon tax today. For a foreign buyer, there is no Moroccan carbon cost built into the price.
Which official texts underpin the carbon tax project?
Three documents announce the tax without creating it: a 2021 framework law, Morocco’s nationally determined contribution (NDC) under the Paris Agreement, and the explanatory note to the 2026 budget.
Date | Official text | What it says about a carbon tax |
|---|---|---|
26 July 2021 (Official Bulletin No. 7010 of 5 August 2021, French translation) | Framework law No. 69-19 on tax reform, article 7 | Tax measures will be adopted to protect the environment, notably through the introduction of a carbon tax |
30 September 2025 (submitted to the UNFCCC) | Morocco NDC 3.0, 2026-2035 | National carbon tax under consideration, with a gradual approach that takes account of the sectors affected by the CBAM |
20 October 2025 | Explanatory note to the 2026 finance bill | Among the customs projects planned for 2026: completing the work to create a carbon tax |
16 December 2025 | Finance Law No. 50-25 for 2026 | No provision |
23 October 2026 | Finance Bill No. 60-26 for 2027 | No provision |
The framework law sets no deadline for this measure. Its article 19 sets a five-year deadline for the measures in its articles 4, 9 and 13, and leaves the others, including the carbon tax, to be implemented gradually. The tax is still to be created: no published text sets its base, rate or taxpayers.
The 2026 explanatory note placed the project with the ADII, to align customs taxation and regulation with climate issues. The finance law adopted two months later did not take it up.
What does the 2027 finance bill provide?
No carbon tax. Finance Bill No. 60-26 for the 2027 budget year, published by the Ministry of Economy and Finance on 23 October 2026, does not contain one. Its explanatory note mentions it neither among the ADII’s 2026 achievements nor among its 2027 priorities, which cover tobacco, alcoholic drinks and modernised controls, among other things.
The same note handles climate through other instruments: implementing the NDC 3.0, which targets a 53% cut in greenhouse gas emissions by 2035, climate tagging of the budget (Head of Government circular No. 06/2026), a green financial taxonomy, and putting into operation the bilateral carbon market agreements signed with Norway, Switzerland, Singapore and South Korea. It also cites industrial decarbonisation in light of the requirements of the CBAM. Carbon market agreements fall under article 6 of the Paris Agreement: see our guide to carbon credits in Morocco.
Parliament can amend a finance bill; the enacted 2027 finance law will have the final word. As of 11 November 2026, Finance Bill No. 60-26 of 23 October 2026 contains no carbon tax, and its departmental budgets are under review in the committees of the House of Representatives. The 2027 finance law is expected in the Official Bulletin in late December 2026.
Why does the absence of a national tax matter to buyers?
Because a carbon price paid in Morocco could reduce what EU and UK importers pay; with no national tax, there is nothing to claim on that basis.
- EU CBAM. Article 9 of Regulation (EU) 2023/956, in the consolidated version read on EUR-Lex on 11 November 2026, lets the authorised CBAM declarant claim a reduction in the number of certificates to surrender for a carbon price effectively paid in a third country, where embedded emissions are based on actual emissions. The regulation defines that price as an amount paid in the form of a tax, levy or fee, or of emission allowances. The evidence is certified by a person independent of both the declarant and the third-country authorities, and any rebate or compensation is deducted. From 2027, the Commission may publish annual default carbon prices for third countries with carbon pricing rules in force; with default values, that is the only route.
- UK CBAM. HMRC’s provisional list of schemes that qualify for carbon price relief, published on 27 August 2026 on the basis of information available on 19 June 2026, has sixteen schemes, including South Africa’s carbon tax; none is Moroccan. HMRC states that the list is not exhaustive and will be updated.
In 2027, then, a Moroccan cement maker, fertiliser producer or steelmaker will have no national carbon price to put forward to its customers. The only way to cut their CBAM bill is to reduce and document the actual emissions of its installations: that is the purpose of an industrial decarbonisation plan.
If a tax is created one day, its value for exports will depend on its design: a price effectively paid, rebates deducted, and evidence that can be certified.
What should buyers and suppliers do in the meantime?
Prepare the data that is needed in any case: what the EU and UK CBAM require today, and what a national tax would require tomorrow.