Do ferroalloys from Zestaponi face CBAM in the EU?
It depends on the alloy. Ferro-manganese (CN 7202 1) is covered by CBAM; silico-manganese (7202 30) is not. Check the CN code on each shipment, and for covered alloys send direct emissions from coke, coal and electrodes per tonne.
Covered or not
- Ferro-manganese: covered.
- Silico-manganese: not covered.
- Ferro-chromium and ferro-nickel: covered.
- Ferro-silicon and other 7202 alloys: not covered.
For covered alloys
Direct emissions come from the carbon in coke, coal and electrode paste, worked out by mass balance, divided by tonnes of alloy. Electricity is reported, not charged.
Even when not covered
EU steel mills still ask for a figure for their own Scope 3. Keep the same records either way.
What Senseible does here
Senseible keeps each site's fuel, power and production records together, so the embedded emissions you send an EU importer trace back to dated documents.
Sources: Regulation (EU) 2023/956 (CBAM Regulation), consolidated, European Commission, CBAM definitive regime, 2006 IPCC Guidelines, Volume 2: Energy
Last reviewed 2026-10-21.