Does woodchip or charcoal in a Samalaju ferrosilicon furnace count as zero emissions under CBAM?
Ferrosilicon is not a CBAM good, so no CBAM figure is due on it. The question matters for the product footprint EU buyers ask for: woodchip or charcoal carbon counts as biogenic only with evidence of a sustainable source; otherwise count it like coal. Coal, coke and electrode carbon always count.
Not covered by CBAM
Ferrosilicon is declared under CN 7202 21 or 7202 29. The only ferro-alloys in Annex I are ferro-manganese, ferro-chromium and ferro-nickel, so an EU importer of ferrosilicon files no CBAM figure for it. Check Annex I again before each contract season, as the scope can be amended.
What buyers still ask
EU steel, foundry and silicone customers count purchased ferrosilicon in their Scope 3 and ask for a footprint per tonne. Direct emissions come from the carbon in reductants and electrodes, worked out by mass balance; electricity from the grid sits alongside as Scope 2.
Biomass evidence to keep
- The source of the woodchips or charcoal: plantation, sawmill residue or other.
- Certification or a documented chain of custody.
- Quantities and carbon content for each delivery.
If evidence is missing
Count the biomass carbon as fossil. Claiming biomass without records is a common reason for a buyer or verifier to reject a footprint.
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.