Is silicon metal made in Minas Gerais covered by CBAM?
No. Silicon metal, declared under CN 2804 69, is not in Annex I; the only chapter 28 element covered is hydrogen. Ferrosilicon (7202 21 and 7202 29) is not covered either: the only ferro-alloys in CBAM are ferro-manganese, ferro-chromium and ferro-nickel. Aluminium, chemical and solar buyers may still ask silicon makers for a product footprint.
Covered and not covered
- Not covered: silicon metal and high purity silicon under 2804 61 and 2804 69.
- Not covered: ferrosilicon under 7202 21 and 7202 29, and silico-manganese under 7202 30.
- Covered: ferro-manganese (7202 1), ferro-chromium (7202 4) and ferro-nickel (7202 6).
- Covered: hydrogen under 2804 10 00.
What buyers still ask
Aluminium alloy makers, silicone producers and solar wafer makers count purchased silicon in Scope 3. They want a figure per tonne that includes reductant carbon, electrodes and electricity, and evidence for any charcoal counted as biomass.
What Senseible does here
Senseible reads coal, coke, gas and electricity invoices and production records into a dated, fingerprinted record per site, so the direct emissions behind each tonne can be traced to the documents. Emissions factors outside India are entered from the official source and labelled.
Sources: CBAM Regulation (EU) 2023/956, consolidated, European Commission, CBAM Guidance 5d: iron and steel, Implementing Regulation (EU) 2023/1773, Annex II (ferro-alloys: 7202 1, 7202 4 and 7202 6 only)
Last reviewed 2026-10-21.