# Does woodchip or charcoal in a Samalaju ferrosilicon furnace count as zero emissions under CBAM?

Canonical: https://senseible.earth/answers/samalaju-ferrosilicon-woodchip-reductant-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.

- [Charcoal pig iron from Minas Gerais](https://senseible.earth/answers/charcoal-pig-iron-minas-gerais-cbam-zero)
- [Ferro-alloy coke and coal records](https://senseible.earth/answers/ferro-alloy-plant-coke-and-coal-records)
- [Electrode paste CO2](https://senseible.earth/answers/ferro-alloy-electrode-paste-co2-per-tonne)

Sources: [CBAM Regulation (EU) 2023/956, consolidated](https://eur-lex.europa.eu/eli/reg/2023/956/2025-10-20), [European Commission, CBAM Guidance 5d: iron and steel](https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism/cbam-legislation-and-guidance_en), [Implementing Regulation (EU) 2023/1773, Annex II (ferro-alloys: 7202 1, 7202 4 and 7202 6 only)](https://eur-lex.europa.eu/eli/reg_impl/2023/1773/oj/eng)

Last reviewed 2026-10-21.