Incoterms® (International Commercial Terms) are codified rules published by the International Chamber of Commerce (ICC) that define the responsibilities of the seller and buyer in an international transaction: Place of delivery: where the goods pass under the buyer's responsibility Transfer of risk: at what moment the buyer assumes the risk of loss or damage Allocation of costs: who pays for what (freight, insurance, customs clearance, taxes) Legal force: Incoterms are not law — they must be expressly stated in the sales contract to apply. You must write: "FOB Casablanca Incoterms® 2020". They do not cover: transfer of title, payment terms, penalties, or remedies in the event of a dispute (governed by the law applicable to the contract).
Incoterms® 2020 comprise 11 terms divided into two groups by mode of transport: Group 1 — Any mode of transport (7 terms): EXW | FCA | CPT | CIP | DAP | DPU | DDP These terms apply to any mode of transport: road, air, rail, containerized sea freight, or a combination of several modes. Group 2 — Sea and inland waterway transport only (4 terms): FAS | FOB | CFR | CIF These terms should only be used when the port is the point of delivery (bulk cargo, conventional vessels, non-containerized goods). Progression of seller responsibility: EXW → FAS → FOB → CFR → CIF → CPT → CIP → DAP → DPU → DDP (minimum seller responsibility → maximum seller responsibility)
Incoterms ≠ payment terms: this is a common confusion. | | Incoterms | Payment terms | |---|---|---| | Define | Place of delivery, risk transfer, cost allocation | When and how the buyer pays | | Examples | FOB, CIF, DAP | 30-day transfer, sight CREDOC, CAD | | Independent | Yes — can be freely combined | Yes | Example: a contract can be "CIF Rotterdam, payment by confirmed irrevocable CREDOC at 90 days". CIF defines where the risks are transferred; the 90-day CREDOC defines when the exporter is paid. Interaction: some Incoterms pair better with certain payment instruments (CIF is preferred for CREDOC because it provides a transferable maritime B/L).
No, using Incoterms is not legally mandatory. They are optional rules adopted by the parties in their contract. Incoterms 2010 still valid: if a contract signed before 2020 mentions "FOB Casablanca Incoterms 2010", those rules apply. Incoterms are not retroactive. ICC recommendation: use Incoterms® 2020 for all new contracts, as they provide important clarifications (notably on FCA and insurance under CIP). Mandatory mention: always specify the version ("Incoterms® 2020") and the precise place ("FOB Port de Casablanca") to avoid any ambiguity of interpretation. Alternative rules: similar rules exist (American RAFTD, Scandinavian terms) — check the practice of your sector and partner country.
Correctly mentioning an Incoterm in a contract or an invoice must include three elements: Standard format: [Term] [Named place] Incoterms® 2020 Examples: "FOB Port de Casablanca Incoterms® 2020" "CIF Port du Pirée Incoterms® 2020" "DAP 12 Rue Friedland, 75008 Paris Incoterms® 2020" "EXW Zone Industrielle Ahl Lough, Lot n°12, Settat Incoterms® 2020" Common mistakes: Omitting the version ("Incoterms" without "2020") → ambiguity Not specifying the place ("FOB" without a port) → invalid Using "FOB destination" → does not exist in the Incoterms Writing "CIF + costs" → contradicts the definition (costs are already included in CIF) On the commercial invoice, the Incoterm mention generally appears in a dedicated field or in the delivery terms.
EXW — Ex Works is the Incoterm under which the seller has the minimum obligations. It simply makes the goods available at its premises (factory, warehouse, depot) at the agreed place. Seller's obligations: Make the goods available on the agreed date Package the goods appropriately Notify the buyer of the availability date Buyer's obligations: Everything else: loading the truck at the seller's premises, transport to the port, export formalities in the seller's country, international freight, import clearance, final delivery Transfer of risk: as soon as the goods are available at the seller's premises — even before loading. Major issue: the buyer must carry out export customs formalities in the seller's country — often legally impossible (only the seller/a resident can export in many countries, including Morocco).
EXW creates difficulties for the foreign buyer: Practical problems: The foreign buyer cannot legally export from the seller's country (must be a resident or appoint a local freight forwarder) The buyer is responsible for loading at the seller's premises — if the seller damages the goods while loading, the risk is already the buyer's The buyer bears 100% of the transport risk without necessarily controlling it Recommended alternatives: FCA: the seller delivers to the buyer's designated carrier — the buyer still controls the freight but the seller handles the export FOB: the seller delivers on board the vessel — the buyer arranges the sea freight When to use EXW: for domestic transactions, catalog prices, or when the buyer has a local freight forwarder in the seller's country able to handle the export.
FCA — Free Carrier: the seller delivers the goods to the carrier designated by the buyer, at the agreed place. This is the term recommended by the ICC for containerized transport. Reason: in containerized transport, the goods are handed over to the terminal or container depot before being loaded on board the vessel. Under FOB, risk transfers "on board the vessel" — a moment by which the seller has often already lost control of the container. With FCA: The seller delivers the container to the freight forwarder's terminal/warehouse Transfer of risk: at that precise moment, at the seller's premises or at the terminal The buyer arranges the sea freight FCA 2020 option for CREDOC: the buyer can ask its bank to instruct the carrier to issue an "on board" B/L even though the term is FCA — a solution introduced in Incoterms 2020 to resolve the FCA/CREDOC incompatibility.
In practice in Morocco with FCA, the place of delivery is generally: For sea exports from Tanger Med: The Tanger Med container terminal (APM Terminals or Eurogate) — the seller delivers to the terminal gate, sealed and exported Or the freight forwarder's or shipping line's depot (CMA-CGM, MSC depot) For sea exports from Casablanca: The Port of Casablanca (Marsa Maroc), the CVE or SOMAPORT terminal For air exports: Mohammed V air freight (Casablanca cargo terminal) For road exports: The seller's premises if the buyer's truck picks up the goods there Or the border (Ceuta, Melilla, Tanger) for franco-frontier delivery The precise place must be stated in the contract, as it exactly determines the transfer of risk.
Historical FCA + CREDOC problem: documentary credits (L/C) generally require an "on board" B/L to release payment. But under FCA, risk transfers before the goods are loaded on board — the seller does not yet have the on-board B/L at the moment risk transfers. Incoterms® 2020 solution — FCA Option B: The 2020 text provides that the buyer can instruct the carrier to issue an on-board B/L and deliver it to the seller, even though the goods are sold FCA and are not yet on board when risk transfers. In practice: 1. The contract states "FCA + on-board B/L required" 2. The buyer instructs the shipping line (via its bank) 3. The shipping line issues the on-board B/L once loaded and delivers it to the seller 4. The seller presents the B/L to its bank for CREDOC payment This solution makes FCA fully compatible with documentary credits.
FOB — Free On Board: the seller delivers the goods on board the vessel designated by the buyer, at the agreed port of shipment. This is the most widely used Incoterm for Moroccan exports. Transfer of risk: at the moment the goods cross the ship's rail at the port of shipment. Before that moment: seller's risk. After: buyer's risk. Seller's obligations: Transport the goods to the vessel (local transport, port handling) Carry out export customs formalities (DEM, BADR) Obtain the bank domiciliation visa if required Deliver "on board" — loading onto the vessel is done by dockers, but risk passes to the buyer once delivered on board Buyer's obligations: Choose the vessel and book the space Pay the ocean freight Take out transport insurance (recommended)
Morocco's main export ports for container and general cargo trade: Tanger Med (Tangier): A leading transshipment and export hub — 9 million TEU capacity Direct connections to 80 countries, 160 ports Integrated free zone (Tanger Free Zone) Specialization: automobiles (Renault, Stellantis), textiles, wiring harnesses Casablanca (Port of Casablanca): Historic port, Morocco's leading import port Specialization: bulk products (cereals, sugar), regional containers, agri-food Managed by Marsa Maroc, Somaport terminal Nador (Port of Nador / Beni Ensar): Exports of citrus, early produce, canned fish (eastern region) Connections to Spain and Italy (ferries and cargo) Agadir: Exports of citrus, tomatoes, seafood Direct connections to European ports (Rotterdam, UK)
For imports into Morocco, the customs value is calculated on a CIF (Moroccan port) basis — that is, the price paid + freight + insurance up to the Moroccan port. If the invoice is in FOB: The freight forwarder must reconstruct the CIF value by adding: The sea freight (freight charges billed by the shipping line or the freight forwarder) The insurance (generally 0.5% to 1% of the FOB value) If the invoice is already in CIF: the value is used directly. Impact on duties: FOB Shanghai value: 100,000 USD Sea freight: 2,000 USD Insurance: 510 USD CIF customs value: 102,510 USD Customs duty 17.5%: 17,939 USD VAT 20%: 24,090 USD The higher the FOB value, the higher the duties. Hence the (legitimate) interest in minimizing international freight.
The ICC strongly discourages using FOB for containerized transport and recommends FCA instead. Main reason: The "on board" issue: Under FOB, risk transfers when the goods are "on board the vessel". But in containerized transport: 1. The seller hands over the sealed container to the depot terminal (days before loading) 2. The container is stored at the port under the terminal's responsibility 3. The vessel loads hundreds of containers — it is impossible to determine exactly when a specific container "goes on board" Practical problem: if a container is damaged at the terminal, between hand-over and loading, who is responsible? Under strict FOB, the seller. But the seller no longer has access to the container. Solution: use FCA with a place of delivery at the container terminal.
FAS — Free Alongside Ship: the seller delivers the goods alongside the vessel at the agreed port of shipment. The goods are not loaded on board — they are simply on the quay or on a barge alongside the vessel. Difference from FOB: under FAS, loading on board is at the buyer's expense and risk. Under FOB, the seller delivers "on board" (loading included). Typical use: bulk or oversized cargo (phosphates, ores, heavy industrial equipment) where loading requires specific cranes controlled by the buyer. In Morocco: used by OCP (phosphates from Casablanca, Safi, Jorf Lasfar) and ore exporters. Uncommon for ordinary SME exports. Export formalities: the seller carries out export clearance (as under FOB).
CFR (Cost and Freight) and CIF (Cost, Insurance and Freight) are identical except on one point: insurance. | | CFR | CIF | |---|---|---| | Costs up to the destination port | Seller | Seller | | Transport insurance | Buyer (optional) | Seller (mandatory, minimum) | | Risk on board at the port of shipment | ← Transfer here → | ← Transfer here → | Important: in both cases, risk transfers on board at the port of shipment — not at the destination port! Even though the seller pays freight to destination, if the goods sink at sea, the risk is already the buyer's. CIF Incoterms 2020: minimum insurance = Institute Cargo Clauses C (the most basic risks). For full coverage, negotiate all-risks insurance (Clauses A).
Morocco (like most countries) uses the CIF value as the basis for calculating import customs duties, in accordance with the WTO customs valuation agreement. Why CIF? The CIF price represents the real acquisition cost of the goods delivered to the Moroccan port It includes freight and insurance — two elements with definite economic value This maximizes the taxable base (from the importing country's fiscal viewpoint) Comparison: if customs duty were calculated on the FOB price at origin, importers would pay less duty. With CIF, countries collect more. International convention: the WTO valuation agreement (Tokyo Round) allows countries to choose FOB or CIF as the basis — Morocco has chosen CIF. The USA and Canada use FOB.
CIF is particularly well suited to documentary credits because it provides the necessary documents within the required timeframe: CIF documents required for an L/C: 1. "On board" maritime B/L — available because the goods are indeed on board 2. Insurance policy or insurance certificate — the seller takes out the insurance and presents it 3. Commercial invoice covering cost + freight + insurance 4. Other documents per the L/C (certificate of origin, packing list, phytosanitary certificate…) Advantage for the seller under CIF: it controls the insurance (can negotiate better terms) and manages the freight (can leverage volumes with its freight forwarder). Advantage for the buyer under CIF: it receives a complete document set, easily verifiable by its bank.
A point often misunderstood: under CFR (and CIF), the seller pays freight to the destination port BUT risk transfers much earlier. Illustrative scenario: A Moroccan exporter sells 100,000 EUR of dried tomatoes CFR Rotterdam The vessel sinks in the middle of the Atlantic The Moroccan exporter is NOT liable for the loss — risk transferred on board at Casablanca But the seller paid the freight to Rotterdam and does not get it back The buyer pays for the goods (sales contract) because the risk is its own Conclusion: under CFR and CIF, the seller "sells expensive" (includes freight in the price) but does not bear the voyage risk. It is a combination favorable to the seller. Advice: the importing buyer should always take out its own insurance in addition to the seller's minimum coverage under CIF.
CPT — Carriage Paid To: the seller pays freight to the agreed place of destination, but risk transfers to the first carrier at the place of dispatch. Analogy with CFR: CPT is to all modes of transport what CFR is to sea transport only. Applications in Morocco: Truck: CPT Brussels — the seller pays for the Moroccan truck + ferry + European truck Air: CPT Paris CDG — the seller pays air freight to CDG Multimodal: CPT Marseille — truck + ferry + truck Transfer of risk: to the first carrier (the trucker who takes charge at the seller's premises). If the truck breaks down in Spain, the risk is the buyer's. Note: as with CFR, the seller bears the cost of transport but not the risk during the journey.
CIP and CIF are similar (the seller pays freight + insurance) but apply to different modes of transport and have distinct insurance levels. | | CIP | CIF | |---|---|---| | Mode of transport | Any mode | Sea only | | Insurance level (Incoterms 2020) | All risks (ICC A) | Minimum (ICC C) | | Risk transferred to | 1st carrier | On board at the port of shipment | CIP Incoterms 2020: following the 2020 revision, the insurance level under CIP was raised to all risks (Institute Cargo Clauses A) — a significant improvement over Incoterms 2010 (which required only ICC C for CIP as well). Recommendation: for valuable goods shipped by air freight or multimodal transport, CIP is preferable to CPT because the buyer receives full insurance coverage.
DAP — Delivered At Place: the seller delivers the goods at the agreed place of destination in the buyer's country, ready for unloading — but without import clearance. Seller's obligations: Arrange and pay for full transport to the place of destination Bear all transport risks up to destination Carry out export formalities in the country of dispatch Not pay the buyer's country's import customs duties Buyer's obligations: Carry out import clearance in its country Pay local customs duties and VAT Unload the goods from the truck/aircraft on arrival Popularity: widely used for shipments to Europe (DAP Paris, DAP Amsterdam). The European buyer handles its own European clearance (it knows the local procedures better).
Under DAP, import clearance clearly falls to the buyer. But in practice, coordination is sometimes tricky. Typical DAP Paris scenario: 1. The Moroccan exporter appoints a Moroccan freight forwarder to arrange the truck to Paris 2. The truck arrives at the Franco-Spanish or Franco-Moroccan border 3. The buyer's French freight forwarder carries out the EU declaration with customs 4. In France, the driver/truck waits for customs release 5. Final delivery to the Paris address Points of attention: The European buyer must have its EORI number (European Operator Registration and Identification) If the buyer delays clearance, the seller bears the cost of the truck's waiting time (land demurrage) Specify in the contract who bears any waiting costs
DPU — Delivered at Place Unloaded (a new name since 2020, formerly DAT): like DAP but with unloading included in the seller's obligations. Sole difference between DAP and DPU: DAP: delivery at destination, unloading is the buyer's responsibility DPU: delivery AND unloading are the seller's responsibility Typical use of DPU: Delivery to a warehouse or terminal where the seller controls unloading operations Industrial projects (construction materials delivered to a site, unloaded by the seller) Agri-food logistics (delivery to a cold room, the seller handles the refrigerated unloading) Place of unloading: must be specified (e.g., "DPU Plateforme Logistique de Lesquin, Lille Incoterms® 2020"). Unloading at a sea or air terminal is possible.
DPU is rare for Moroccan exporters but can be relevant in certain situations: Case 1 — Construction materials (bricks, tiles): A Moroccan exporter delivers ceramic tiles to a construction site in Spain. The DPU Barcelona Incoterm lets it deliver and unload at the site — the buyer does not need to arrange a crane or forklift. Case 2 — Moroccan industrial equipment: A Moroccan manufacturer of industrial machines exports to Côte d'Ivoire. DPU Abidjan includes installing the machine at the buyer's site. Case 3 — Refrigerated agri-food: A citrus exporter delivers DPU to a European distributor's distribution center — it controls the cold chain up to actual unloading. Risk: the seller bears the risk until actual unloading — any incident during unloading (even caused by the buyer's equipment) is its responsibility.
DDP — Delivered Duty Paid is the Incoterm under which the seller has the maximum obligations. It delivers the goods at the agreed place in the buyer's country, with import customs duties and VAT paid, ready to be unloaded. Seller's obligations (EVERYTHING): Full transport from the factory to destination Export formalities + import formalities in the buyer's country Import customs duties Local VAT or taxes Risks throughout transit Risks for the seller: Must know the buyer's country's customs regulations Must have an agent (freight forwarder) in the buyer's country If duties are higher than expected: the seller bears the difference VAT recovery in certain countries can be complicated Popularity: widely used for B2C sales (e-commerce) where the individual buyer cannot handle customs clearance.
Under DDP to an EU destination, the seller pays import VAT in the European country. Recovery of that VAT depends on the seller's status: If the seller is EU-VAT registered: The seller can recover the VAT paid on import if it was paid in its own name. It must register for VAT in the destination country (or use the EU's OSS — One Stop Shop — for certain cases). If the seller is not EU-VAT registered: The VAT is paid but not recoverable. It becomes a definitive cost that reduces the margin. Practical solution: Use DAP: the buyer (who is VAT-registered) pays and recovers the VAT easily Or use a fiscal representative in the EU B2C e-commerce: since 2021, the EU's OSS system allows non-EU sellers to manage EU VAT simply.
For a standard container from Casablanca, the ICC recommends FCA. Why: In containerized transport, the "on board" risk point (FOB) does not match operational reality — the container is closed and sealed well before it even reaches the vessel Under FCA, risk passes exactly when the seller hands the container over to the freight forwarder/terminal — a precise, documented moment Choose FOB when: The buyer or its bank insists on FOB for documentary-credit reasons (habit) Bulk cargo (no container) — e.g., bulk phosphates at Jorf Lasfar Sector convention (some sectors use FOB by tradition) Choose FCA when: Standard container (most cases) Documentary credit (use the FCA 2020 Option B) The buyer wants a precise, documented delivery point Bottom line: for the majority of Moroccan containerized exports, FCA is technically more correct, but FOB remains very widely used by commercial convention.
Simple rule: Bulk or conventional sea transport → CIF Any other mode (container, air, road, multimodal) → CIP Level of insurance (important): CIF: minimum insurance (ICC C — named risks only) CIP: all-risks insurance (ICC A) since 2020 Practical recommendations: Low-value bulk goods by sea → CFR or CIF (minimum insurance is sufficient) Valuable goods in containers → CIP (all risks included) Perishable agri-food products by air → CIP (full coverage) Note: buyers receiving goods under CIF should always take out supplementary insurance, as ICC C does not cover common risks (seawater, theft, contamination).
For a European buyer (EU importer), the DAP vs DDP difference is both fiscal and operational: DAP (buyer handles clearance): The buyer pays customs duties → immediately recoverable if under a customs economic regime The buyer recovers import VAT on its monthly VAT return The buyer controls its freight forwarder and can optimize clearance The buyer must have a freight forwarder and an EORI number DDP (seller handles everything): The buyer receives the goods "turnkey" No need for customs organization on the buyer's side The seller includes duties in its price → an opaque cost for the buyer The buyer generally cannot recover VAT paid in the seller's name Recommendation: for professional buyers (European companies), DAP is often preferred because they recover VAT. For the general public (B2C), DDP simplifies the experience.
Main problem with EXW for a Moroccan buyer: A Moroccan buyer purchasing EXW (Ex Works in Germany, for example) must carry out export customs formalities in Germany — which is difficult because: It is not a resident of Germany It must appoint a German freight forwarder (additional cost) In the event of a German customs check, the Moroccan buyer is not easily reachable Practical problem: The truck is loaded at the seller's premises — if the goods are damaged during loading (by the seller's staff), the risk is already the Moroccan buyer's. FCA alternative: The seller carries out the export from Germany (as a resident), delivers to the carrier designated by the buyer (a Moroccan or European freight forwarder), and risk transfers at that precise moment. Advice: never accept EXW if your freight forwarder has no representative in the seller's country.
The Institute Cargo Clauses (ICC) define the extent of transport insurance coverage: Clauses A (All risks): Coverage of all risks of loss or damage, except the named exclusions (war, nuclear, inherent vice of the goods, insufficient packaging, delay). Clauses B: Intermediate named risks: total loss, sinking, stranding, collision, discharge at a port of distress, earthquake, flood. Clauses C: Minimum coverage — only the most serious risks: sinking, stranding, collision, fire, explosion. Does not cover theft, partial breakage, contamination, seawater damage. Practical recommendation: Ordinary goods in a secured container: ICC B minimum Valuable goods, electronics, agri-food: ICC A mandatory CIF minimum = ICC C — often insufficient, negotiate ICC A in the contract For Moroccan exporters: specify the applicable clause in the CIF contract ("CIF Rotterdam, minimum ICC A insurance").
Cargo transport insurance can be taken out in Morocco with several insurers approved by the Autorité de Contrôle des Assurances et de la Prévoyance Sociale (ACAPS): Active insurers: AXA Assurance Maroc, Saham Assurance, Wafa Assurance, Atlanta, Sanlam Maroc, RMA. Types of policies: Voyage policy (floating policy): covers a specific shipment — ideal for one-off shipments Open cover policy: automatically covers all of an exporter's shipments over a period — negotiated rate, monthly declaration of shipments Information to provide: Goods, country of origin/destination, CIF value, mode of transport, type of packaging, Incoterm used, presence of an all-risks or named-risks clause. Average premium: 0.3% to 1.5% of the CIF value depending on the goods and destination.
Subrogation is an important mechanism after a transport claim: Principle: if the insurer indemnifies the insured for a loss caused by the fault of a third party (carrier, handling agent), the insurer is subrogated to the insured's rights — it can pursue the responsible third party to recover its indemnification. Practical implications: Even if you are indemnified by your insurance, do not "release" the carrier from its liability without the insurer's agreement Note reservations on the B/L or the CMR as soon as damage is observed on delivery Keep all evidence (photos, incident reports, expert reports) Recourse deadlines: Against the sea carrier: 1 year (Brussels/Hamburg Convention) Against the CMR road carrier: 1 year (3 years for intentional faults) Always notify the claim within 3 days of delivery for apparent damage.
Documentary credits (L/C UCP 600) require presentation of an "on board" B/L for sea shipments. Compatibility with the Incoterms: Compatible without difficulty: CIF: the seller naturally holds the on-board B/L CFR: same FOB: the seller delivers the goods on board, but the B/L is made out to order of the bank FCA + 2020 Option B: the buyer instructs the shipping line for an on-board B/L Compatible with arrangements: FCA without option B: risk of non-compliance if the L/C strictly requires an on-board B/L CPT/CIP: the document presented will be a B/L, LTA or multimodal document depending on the transport Difficult with a standard L/C: EXW: the exporter does not control the transport or the documents DAP/DPU/DDP: the buyer handles everything, the seller does not easily hold the transport documents Advice: when opening the L/C, specify the Incoterm precisely and ensure the L/C's terms match the documents the seller can actually produce.
A documentary discrepancy occurs when the documents presented under a documentary credit do not fully comply with the L/C's terms. The Incoterm can be a source of discrepancies. Common discrepancies linked to the Incoterm: B/L showing a port of shipment different from the place named in the L/C An invoice with a CIF value but a FOB Incoterm (or vice versa) Missing insurance documents when the L/C requires CIF (the seller must provide the policy) "Freight collect" noted on the B/L when the L/C requires "freight prepaid" (CIF or CFR) Procedure in the event of a discrepancy: 1. The advising bank informs the seller of the discrepancies within 5 banking days 2. The seller can request document corrections if time allows 3. Alternative: the seller requests the buyer's agreement ("waiver") 4. If the buyer accepts the discrepancies, payment is released Prevention is better than cure: read the L/C carefully before preparing the documents.
The documents required under a documentary credit vary by Incoterm and destination. Summary table: CIF Rotterdam (typical): Commercial invoice (CIF) Maritime B/L "on board, to order, notify applicant" Insurance policy or certificate (ICC A or minimum ICC C per the L/C) Packing list EUR.1 if to the EU FOB Casablanca (typical): Commercial invoice (FOB) Maritime B/L "on board, to order" Packing list EUR.1 *No insurance* (buyer's responsibility) FCA + option B (for L/C): Commercial invoice (FCA) Maritime B/L "on board" (issued at the buyer's request) Packing list EUR.1 *No insurance* Key point: the exact terms of the documents (ports, dates, amounts) must match the L/C's fields exactly.
The Moroccan textile-garment industry (the leading export industry) mainly uses: FOB Tanger Med or Casablanca: standard for large European buyers (Inditex/Zara, H&M, C&A) who have their own freight forwarders and negotiate freight directly with shipping lines. FCA Tanger Free Zone or factory premises: for brands doing CMT (Cut-Make-Trim) — the fabric is delivered in advance and the finished product ships out FCA. CPT or DAP: for small European brands without a freight forwarder — the Moroccan seller arranges the truck to Paris, Berlin or Madrid. Trend: large retailers impose their own Incoterms (FOB or EXW) in their framework contracts. Moroccan SMEs have little room to negotiate. Independent exporters (showrooms, direct B2B) prefer CIF or DAP to keep control of logistics.
For perishable fresh produce (cherry tomatoes, citrus, strawberries, peppers), choosing the right Incoterm is crucial to avoid losses in transit. Specific constraints: Short shelf life (5 to 30 days) Need for certified ATP refrigerated trucks ONSSA phytosanitary controls on export + SPS controls in the EU Recommendations: FOB (refrigerated truck loaded on the Tanger-Algeciras/Barcelona ferry): standard for organized exporters to Spain, France CFR or CIF: if the Moroccan exporter controls refrigerated logistics all the way to Rungis or Rotterdam DAP (delivery to the importer's logistics platform): for contracts with large retailers (Carrefour, Leclerc) — the distributor receives the goods "turnkey" Insurance: always take out an "all risks + refrigeration" policy covering cooling-unit breakdowns. Clause: specify the required transport temperatures in the contract (e.g., +2°C to +8°C) — failure to comply can be grounds for refusal on delivery.