Green Industrialisation In Tunisia Under The EU Carbon Border Adjustment Mechanism: Aligning European Climate Policy With Tunisia’s Industrial Transformation And Fiscal Sustainability
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by Sameh Abidi
Abstract
The introduction of theCarbon Border Adjustment Mechanism (CBAM) by the European Union represents a structural transformation at the intersection of climate policy and international trade. Designed to prevent carbon leakage and ensure a level playing field between European producers subject to the EU Emissions Trading System (ETS) and foreign exporters, the mechanism applies a carbon price to selected imported goods such as cement, fertilizers, aluminium, and electricity. While CBAM reinforces the credibility of European climate ambition under the Paris Agreement, it also generates significant economic challenges for neighbouring economies closely integrated into European value chains.
This paper examines the implications of CBAM for Tunisia, where approximately 70% of exports are directed toward the European market and where industrial production remains both carbon-intensive and highly dependent on fossil fuels. By focusing on the sectors most exposed to the mechanism—cement, fertilizers, aluminium, and electricity—the study provides a quantitative-informed assessment of potential impacts. Preliminary estimates suggest that carbon pricing levels ranging between €70 and €95 per ton of CO₂ (https://sl1nk.com/vcOIq) could substantially increase export costs in energy-intensive sectors, potentially reducing profit margins and undermining international competitiveness. At the macroeconomic level, these effects may translate into indirect fiscal pressures through declining export revenues, lower industrial output, and increased demands for public investment in energy transition.
In this context, CBAM operates as an implicit carbon tax on Tunisia’s energy system, revealing structural vulnerabilities in the country’s industrial model. However, beyond these immediate risks, the mechanism may also act as a catalyst for structural transformation. The transition toward green industrialisation is no longer solely an environmental objective but an economic necessity for maintaining access to European markets. The development of renewable energy, particularly solar and wind power, combined with improvements in industrial energy efficiency and thedecarbonisation of energy-intensive sectors, could enable Tunisia to reposition itself within emerging Euro–Mediterranean green value chains.
The paper further examines the fiscal and financial implications of this transition. Tunisia faces constrained public finances and rising debt levels, limiting its capacity to finance large-scale decarbonisation investments. European financial instruments, including the Global Gateway initiative and financing from the European Investment Bank (EIB) and the European Bank for Reconstruction and Development (EBRD), are analysed as potential sources of support. However, their predominantly loan-based structure and associated conditionalities raise concerns regarding debt sustainability and long-term fiscal stability, particularly in the absence of sufficient grant-based financing.
In addition, the study integrates the social dimension of the transition by highlighting potential risks related to employment in carbon-intensive sectors, regional inequalities, and unequal access to green investment opportunities. Without adequate mitigation measures, the decarbonisation process could exacerbate existing socio-economic disparities.
Against this backdrop, the article raises a central question: Can the European Union impose a carbon cost on imports without providing proportional financial and technological support to its trading partners? Addressing this issue requires incorporating principles of climate justice, including differentiated responsibilities and equitable burden sharing in the global energy transition. Without such considerations, CBAM risks reinforcing existing asymmetries in international trade and development.
To transform CBAM into a lever for co-development rather than a punitive trade instrument, the paper proposes a set of operational and sector-specific policy recommendations. These include allocating a share of CBAM revenues to partner countries, increasing the use of grants in European climate finance, promoting targeted industrial decarbonisation strategies, and strengthening technological cooperation between European and Tunisian industries. At the national level, priorities include securing domestic energy supply, ensuring local industrial participation in green investments, safeguarding fiscal sustainability, and enhancing transparency in international partnerships.
Finally, the paper emphasises the importance of inclusive governance mechanisms that integrate civil society participation and parliamentary oversight in the design and implementation of climate-related economic policies. A transition financed primarily through external debt risks undermining the very development objectives it seeks to achieve. Ultimately, the success of Tunisia’s transition will depend not only on financial and technological resources but also on institutional capacity, fiscal governance, and the ability to ensure a socially just and economically sustainable transformation.
In conclusion, the Carbon Border Adjustment Mechanism represents a pivotal moment in the evolving relationship between climate governance, trade policy, and industrial development. For Tunisia, it may either deepen structural vulnerabilities or serve as a catalyst for a new model of sustainable industrialisation. The outcome will depend on the extent of alignment between European climate ambitions, Tunisian industrial strategies, and broader reforms toward a more equitable and inclusive global energy transition.
Keywords: Carbon Border Adjustment Mechanism (CBAM), Green Industrialisation, Tunisia, Energy Transition, Euro-Mediterranean Green Value Chains
Introduction
Climate policies are increasingly shaping global trade and industrial development. In recent years, climate governance has expanded beyond environmental regulation to become a central element of international economic policy. One of the most significant developments in this area is the European Union’s Carbon Border Adjustment Mechanism (CBAM), introduced as part of the European Green Deal and the broader Fit for 55 legislative package, which aims to reduce greenhouse gas emissions by at least 55 percent by 2030 compared to 1990 levels (European Commission, 2023).(https://l1nq.com/m99Rl)
The CBAM represents a structural shift in global climate governance. For the first time, a major economic bloc is integrating carbon pricing into international trade policy by applying a carbon cost to imported goods. This mechanism aims to prevent carbon leakage, a phenomenon in which industries relocate production to countries with weaker environmental regulations in order to avoid carbon pricing constraints (Zachmann, Roth & Tamara, 2020).
While CBAM primarily seeks to protect the environmental integrity of European climate policies, its economic implications extend far beyond the EU. Countries exporting carbon-intensive products to the European market will increasingly face regulatory requirements related to emissions reporting and carbon pricing. For developing economies that rely heavily on industrial exports to the EU, these changes may significantly affect trade competitiveness (World Bank, 2023).
Tunisia is particularly exposed to these developments due to its strong economic integration with European markets. The European Union represents Tunisia’s largest trading partner, accounting for approximately 70 percent of its exports (European Commission, 2023).
Several Tunisian industrial sectors that export to Europe, including cement, fertilizers, and metal products, are energy-intensive and rely largely on fossil fuels, especially natural gas.
As a result, the introduction of CBAM may increase export costs for Tunisian industries and potentially weaken their competitiveness in European markets. At the same time, the mechanism may act as a catalyst for industrial modernisation and energy transition.
This article examines how Tunisia can transform the constraints imposed by CBAM into an opportunity for green industrialisation while maintaining fiscal sustainability and economic competitiveness. It argues that while CBAM functions as an indirect carbon tax on Tunisia’s industrial structure, it may also accelerate structural reforms toward a low-carbon industrial economy if accompanied by appropriate financial support, technology transfer, and policy coordination between Tunisia and the European Union.
1. CBAM: A New Industrial Challenge for Tunisia
1.1. Understanding the Carbon Border Adjustment Mechanism
The Carbon Border Adjustment Mechanism (CBAM) is one of the flagship
instruments of the European Green Deal. It was introduced to address a central challenge in global climate policy: ensuring that products imported into the European Union bear a carbon cost comparable to that faced by European producers. By doing so, the mechanism aims to preserve fair competition in the European market while supporting the EU’s broader climate objectives.
CBAM was designed to complement the European Union’s Emissions Trading System (EU ETS), which represents the EU’s main policy tool for reducing greenhouse gas emissions (European Commission, 2023). Under the ETS framework, companies operating in certain sectors must purchase emission allowances corresponding to the amount of carbon dioxide emitted through their activities. These allowances create a market-based carbon price that incentivises industries to invest in cleaner technologies and reduce their emissions over time.
However, differences in climate regulations across countries can create significant competitive distortions. European industries that are subject to carbon pricing may face higher production costs compared to foreign competitors operating in jurisdictions with weaker environmental regulations or without carbon pricing mechanisms. This situation may encourage companies to relocate production to countries where climate policies are less stringent, a phenomenon commonly referred to as carbon leakage. Such relocation risks undermining the EU’s climate efforts by shifting emissions abroad rather than reducing them globally.
The CBAM seeks to address this challenge by extending the principle of carbon pricing to imports. Under this mechanism, importers of certain goods into the European Union are required to purchase CBAM certificates corresponding to the carbon emissions embedded in those products. The price of these certificates is linked to the weekly average price of emission allowances under the EU ETS, ensuring consistency between the carbon costs borne by European producers and those applied to imported products (World Bank, 2023). Through this approach, the EU aims to establish a level playing field between domestic and foreign producers.
The implementation of the CBAM is taking place in phases. The transitional period (2023–2025) requires companies exporting to the EU to report the carbon emissions embedded in their products without yet paying a financial adjustment. This phase is intended to allow both exporting countries and EU authorities to develop robust monitoring, reporting, and verification systems. Starting in 2026, the financial component of the CBAM will become fully operational, requiring importers to purchase carbon certificates corresponding to the emissions embedded in imported goods (European Commission, 2023).
Currently, the mechanism applies to several sectors that are both highly carbon-intensive and significantly exposed to international trade. These include cement, iron and steel, aluminium, fertilizers, electricity, and hydrogen (OECD, 2023). These industries were selected because they represent a large share of industrial emissions and are particularly vulnerable to carbon leakage.
Beyond its regulatory dimension, the CBAM represents a strategic instrument for the global transition toward a low-carbon economy. For European companies, it protects the value of investments made in decarbonisation by preventing carbon-intensive imports from undermining their competitiveness. For exporters outside the EU, the mechanism presents both a challenge and an opportunity. Firms that anticipate these changes and adapt their production processes can transform compliance into a competitive advantage, improve their environmental reputation, and secure long-term access to one of the world’s most demanding markets in terms of sustainability.
Ultimately, the CBAM goes beyond a simple trade or fiscal measure. It constitutes a key tool of climate governance that seeks to align international trade with climate objectives while encouraging a broader transformation toward low-carbon industrial production.
Main Objectives and Operational Mechanisms of CBAM
Main Objective | Description / Operational Mechanism |
1. Limiting Carbon Leakage | Companies may relocate production to countries with weaker environmental regulations, undermining EU climate policies. The Carbon Border Adjustment Mechanism (CBAM) addresses this by ensuring that the carbon emissions embedded in imported goods are reflected in their price, thereby discouraging the relocation of production to jurisdictions with lower environmental standards. |
2. Creating a Carbon Price Signal for Imports | CBAM converts embedded emissions into an economic cost for imported goods. This creates an incentive for non-EU producers to reduce their greenhouse gas emissions in order to remain competitive in the EU market, thereby encouraging decarbonisation beyond the EU's borders. |
3. Supporting the EU's 2050 Carbon Neutrality Goal | CBAM supports the EU's long-term objective of achieving climate neutrality by 2050. It prevents imported goods from undermining the effectiveness of EU climate policies and complements other European Green Deal initiatives, including the EU Emissions Trading System (EU ETS), the European Climate Pact, and circular economy policies. |
4. Emissions Reporting | Importers are required to identify, quantify, and report the direct emissions (generated during production) and, where applicable, indirect emissions (associated with energy consumption) embedded in imported products. These reports must be accurate and supported by credible evidence, such as supplier declarations, verified emissions reports, or independent third-party audits. |
5. Purchase of CBAM Certificates | Importers must purchase CBAM certificates corresponding to the embedded CO₂ emissions of imported goods. The price of these certificates is linked to the prevailing EU ETS carbon price, ensuring that imported and domestically produced goods face equivalent carbon costs and creating a level playing field within the EU market. |
1.2. Tunisian Industrial Sectors Exposed to CBAM
Several Tunisian industries are directly or indirectly exposed to CBAM due to their energy intensity and export orientation.
The cement sector is one of the most energy-intensive industries in Tunisia. Cement production requires high-temperature kilns fuelled by fossil fuels and involves chemical processes that release large quantities of carbon dioxide (IEA, 2023). If Tunisian cement producers export to European markets, they will face additional carbon costs under CBAM.
The fertilizer industry represents another important sector. Tunisia is one of the world’s major producers of phosphate-based fertilizers. However, fertilizer production relies heavily on energy-intensive processes and fossil fuel inputs, increasing the carbon intensity of these products.
The aluminium and metal-processing sectors may also face indirect exposure. Even if certain products are not directly covered, the carbon intensity of electricity used in production will affect overall competitiveness.
Electricity exports could also become relevant in the future if Tunisia expands energy interconnections with European markets. In such a case, the carbon intensity of Tunisia’s electricity generation would determine its ability to compete with low-carbon European electricity.
1.3. Potential Economic Impacts
The economic implications of CBAM for Tunisia are likely to be multifaceted.
First, exporters will face increased compliance costs related to monitoring and reporting emissions. Establishing Monitoring, Reporting, and Verification (MRV) systems requires institutional capacity, technical expertise, and investment in data management infrastructure (World Bank, 2023).
Second, carbon pricing may increase the cost of Tunisian exports entering the European market. According to IMF estimates, EU carbon prices could reach 70 to 95 euros per ton of CO₂ by 2030, significantly affecting the competitiveness of carbon-intensive industries (IMF, 2024a). (https://sl1nk.com/kJnOX)
Third, CBAM may influence investment decisions within Tunisia’s industrial sector. Companies integrated into European supply chains may face increasing pressure to adopt low-carbon production technologies in order to maintain market access (OECD, 2023).
In this sense, CBAM acts as an indirect carbon tax on Tunisia’s energy system and industrial structure.
2. Green Industrialisation as an Economic Necessity
2.1. Structural Weaknesses of Tunisia’s Industrial Model
Tunisia’s industrial structure exhibits several characteristics that increase its vulnerability to carbon pricing mechanisms.
Industrial production remains highly dependent on fossil fuels, particularly natural gas. Despite the country’s renewable energy potential, renewable sources still represent a relatively small share of total electricity generation (IEA, 2023).
Many Tunisian manufacturing facilities also operate with aging infrastructure and limited technological modernisation. Energy efficiency levels remain lower than international benchmarks in several sectors.
Furthermore, Tunisia’s industrial specialisation often focuses on medium-value-added manufacturing rather than high-technology sectors. This limits the capacity of firms to absorb additional environmental or regulatory costs (World Bank, 2024).
These structural weaknesses increase exposure to CBAM-related risks.
2.2 Energy Transition as Industrial Strategy
Although decarbonisation is often framed as an environmental objective, it increasingly represents an economic strategy.
Tunisia possesses considerable solar and wind resources that could support a large-scale expansion of renewable energy production. Increasing renewable energy capacity would reduce the carbon intensity of electricity generation and strengthen the competitiveness of Tunisian industrial exports.
Industrial energy efficiency improvements could also generate significant economic benefits. Investments in efficient equipment and production processes often reduce operational costs while lowering emissions (IEA, 2023).
In addition, emerging sectors such as green hydrogen, renewable energy technologies, and low-carbon manufacturing could create new opportunities for industrial diversification (IRENA, 2023).
2.3 Integration into Euro-Mediterranean Green Value Chains
The global transition toward low-carbon economies is creating new industrial value chains centred around renewable energy technologies, electric mobility, and sustainable materials.
Tunisia’s geographic proximity to Europe and its established industrial base provide opportunities to participate in emerging Euro–Mediterranean green supply chains.
By investing in renewable energy infrastructure and industrial innovation, Tunisia could attract foreign investment and strengthen its role in regional production networks (OECD, 2023).
3 Global Gateway and European Financial Instruments
3.1 The Global Gateway Strategy
The European Union’s Global Gateway initiative aims to mobilise up to €300 billion in investments in sustainable infrastructure worldwide (European Commission, 2022). (https://sl1nk.com/tb0uO) The initiative focuses on strategic sectors including renewable energy, digital connectivity, transportation infrastructure, and climate resilience.
Global Gateway combines public funding with private investment through mechanisms such as blended finance, guarantees, and development bank loans.
3.2 Financial Instruments Available to Tunisia
Several European financial institutions support development projects in Tunisia, including the European Investment Bank (EIB) and the European Bank for Reconstruction and Development (EBRD).
These institutions provide financing for renewable energy projects, industrial modernisation, and infrastructure development.
Blended finance mechanisms combine grants and loans to reduce investment risks and mobilise private capital (OECD, 2023).
3.3 Current Limitations
Despite the availability of financial instruments, several limitations remain.
A significant share of climate-related financing is delivered through loans rather than grants, increasing the risk of climate-driven debt accumulation (IMF, 2023a).
Furthermore, there is currently no explicit mechanism linking CBAM revenues to financial support for partner countries affected by the policy.
This raises an important policy question: Can the EU impose carbon costs on imports without financing the decarbonisation of its trading partners?
4 From Carbon Tax to Development Opportunity
Transforming CBAM into a development opportunity requires stronger alignment between European climate policy and development financing.
From a climate justice perspective, developing economies emphasise the principle of common but differentiated responsibilities, which recognises differences in historical emissions and economic capacities (UNFCCC, 2015).
In this context, international climate cooperation should include financial support, technology transfer, and capacity-building programmes.
For Tunisia, several strategic priorities should guide negotiations with European partners:
a. Ensuring national energy security before prioritising energy exports.
b. Promoting local industrial participation in green infrastructure projects.
c. Protecting fiscal sustainability and avoiding excessive debt.
d. Strengthening transparency in climate-related investments.
5 Fiscal Implications and Budgetary Considerations
5.1 Fiscal Assessment of CBAM Impacts
Beyond sectoral competitiveness, the Carbon Border Adjustment Mechanism (CBAM) is likely to generate significant indirect fiscal pressures for Tunisia.
Tunisia’s vulnerability is closely linked to its energy structure. The country’s electricity system remains highly carbon-intensive, with approximately 85-90% of electricity generated from fossil fuels, primarily natural gas, and an estimated carbon intensity of 0.45–0.50 tCO₂/MWh (IEA, 2023; World Bank, 2023). (https://l1nq.com/VPJg4)
Renewable energy represents less than 5% of electricity production, reflecting a significant gap compared to European decarbonisation levels (IEA, 2023).(https://sl1nk.com/0tZSZ)
This carbon-intensive energy mix directly translates into higher embedded emissions in exported goods, which will be priced under CBAM (European Commission, 2023).
CBAM is expected to affect Tunisia’s public finances through three main channels:
Decline in export revenues: Carbon pricing between €70 and €95 per ton of CO₂ could increase production costs in exposed sectors by up to 20-30%, potentially reducing export competitiveness (OECD, 2023; IMF, 2024b). (https://sl1nk.com/zibya)
Increased public investment needs: Tunisia aims to reach 30% renewable energy by 2030, requiring substantial investments in infrastructure and industrial decarbonisation (ANME, 2022).
Energy-related fiscal pressures: Tunisia faces a structural energy deficit and high dependence on imported natural gas, which contributes to fiscal vulnerability and exposure to external shocks (World Bank, 2024).
Cement Sector
The cement sector is one of the most carbon-intensive industries, with emissions ranging between 0.6 and 0.9 tCO₂ per ton of cement (IEA, 2023). Tunisia’s reliance on petcoke and fossil fuels places it at the higher end of this range.
Under a carbon price of €80/tCO₂, the additional cost could reach €50-70 per ton, significantly affecting export competitiveness (OECD, 2023).
Fertilizer Sector
Tunisia is a major producer of phosphate-based fertilizers, a sector characterised by emissions of 1.5 to 3 tCO₂ per ton of output, depending on production processes (World Bank, 2023).(https://l1nq.com/6HtgS)
The sector’s dependence on natural gas and energy-intensive chemical transformations makes it particularly vulnerable to CBAM (IEA, 2023).
Electricity Sector
Electricity plays a central role in determining the carbon footprint of industrial production. Tunisia’s electricity mix is dominated by natural gas, resulting in carbon intensity levels significantly higher than the EU average (IEA, 2023; OECD, 2023).
This creates a structural disadvantage, as electricity-related emissions are embedded in exported goods and increasingly accounted for under CBAM reporting requirements (European Commission, 2023).
5.2 Social Dimension and Just Transition
The transition toward low-carbon industrialisation raises important social challenges.
Employment risks are particularly concentrated in carbon-intensive sectors. According to international evidence, industrial decarbonisation can lead to short-term job displacement if not accompanied by reskilling policies (World Bank, 2023).
In Tunisia, these risks are compounded by:
regional inequalities,
labour market rigidity,
and limited access to green jobs.
A just transition approach is therefore essential, including:
vocational training programmes,
targeted social protection,
and inclusive policy design (UNFCCC, 2015).
5.3 Governance and Institutional Framework
Effective CBAM adaptation requires strong governance frameworks. Current challenges in Tunisia include:
limited coordination between industrial, energy, and fiscal policies,
weak data systems for emissions tracking,
and insufficient transparency in climate-related investments.
Strengthening Monitoring, Reporting, and Verification (MRV) systems aligned with EU standards is essential (European Commission, 2023; World Bank, 2023).
Moreover, integrating climate transition into medium-term fiscal frameworks is necessary to ensure sustainability (IMF, 2023b).
6 Strategic Policy Recommendations for Tunisia
6.1 Develop a Data-Driven National Industrial Decarbonisation Strategy
Tunisia should prioritise CBAM-exposed sectors (cement, steel, fertilizers) based on quantified emissions and trade exposure. This strategy should include sector-specific targets, investment needs, and timelines, supported by scenario modelling to assess competitiveness impacts under different carbon price assumptions.
6.2 Integrate Climate Transition into Fiscal Policy and Budget Planning
The government should incorporate climate transition costs into medium-term budget frameworks. This includes:
reallocating inefficient fossil fuel subsidies,
introducing green fiscal instruments,
and mobilising international climate finance.
A clear fiscal strategy is essential to balance industrial support, debt constraints, and social spending.
6.3 Accelerate Renewable Energy Deployment with Industrial Integration
Beyond expanding renewable capacity, Tunisia should prioritise direct electrification of industry and long-term power purchase agreements (PPAs) to reduce carbon intensity in export-orientated sectors.
6.4 Strengthen MRV Systems with Sectoral Differentiation
Tunisia should develop robust, sector-specific MRV frameworks aligned with EU standards. This requires institutional coordination, digital infrastructure, and capacity building, particularly for SMEs.
6.5 Promote a Just Transition Framework
To mitigate social risks, Tunisia should implement:
targeted reskilling programmes,
regional development policies for affected industrial zones,
and social protection measures for vulnerable workers. This will ensure that decarbonisation does not exacerbate inequalities.
6.6 Negotiate a Redistributive and Cooperative CBAM Framework with the EU
Tunisia should advocate for:
partial redistribution of CBAM revenues,
increased grant-based climate finance,
and facilitated access to low-carbon technologies.
This cooperation should explicitly address fiscal asymmetries and development constraints.
6.7 Support Industrial Innovation and Green Value Chains
Public policies should incentivise low-carbon innovation through tax incentives, green public procurement, and support for startups. Tunisia can position itself in emerging green value chains (e.g., green hydrogen, low-carbon materials).
7 Conclusion
The Carbon Border Adjustment Mechanism represents a pivotal shift at the intersection of climate policy, international trade, and industrial transformation. For Tunisia, its implications are both constraining and potentially transformative.
On the one hand, CBAM reveals and amplifies structural vulnerabilities within the country’s industrial model, notably its high carbon intensity and dependence on fossil fuels. It is likely to increase export costs, weaken the competitiveness of energy-intensive sectors, and generate additional fiscal and social pressures. On the other hand, the mechanism creates a powerful incentive to accelerate the transition toward a low-carbon and more resilient economic model, fostering industrial modernisation and integration into emerging green value chains.
However, this transformation is contingent upon addressing three critical dimensions. First, financial sustainability remains a major constraint, given Tunisia’s limited fiscal space and rising debt levels, which restrict its capacity to finance large-scale decarbonisation efforts. Second, social inclusion must be ensured to prevent the transition from exacerbating existing inequalities, particularly in regions and sectors most exposed to structural change. Third, effective governance and accountability are essential to guarantee transparent, efficient, and equitable implementation of transition policies.
In this context, the success of Tunisia’s response to CBAM will depend on its ability to align industrial strategy, fiscal policy, and social policy within a coherent and forward-looking transition framework. At the same time, it requires stronger international support in the form of concessional financing, technology transfer, and fairer cooperation mechanisms.
Ultimately, without such alignment at both national and international levels, CBAM risks reinforcing existing asymmetries in global trade and creating new barriers for developing economies. Conversely, if embedded within a framework of climate justice and equitable burden sharing, it could serve as a catalyst for a more sustainable, competitive, and inclusive development pathway in Tunisia.
References
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