Answer box
Ferro-alloys are iron-alloy intermediates used in making stainless and alloy steel. Some are in CBAM scope and some are not — Annex I of Regulation (EU) 2023/956 covers chapter 72 excluding specific CN 7202 subheadings. Ferromanganese, ferrochromium and ferronickel are in scope at the subheadings listed below. Ferrosilicon and most other ferro-silico and ferro-complex alloys are out of scope. Importers of stainless or alloy steel should also ask their mill about the embedded emissions of ferro-alloys consumed as precursors — those flow into the finished steel regardless of the ferro-alloy’s own scope status.
In CBAM scope today
| CN subheading | Product |
|---|---|
| 7202 11 | Ferro-manganese with carbon > 2% |
| 7202 19 | Other ferro-manganese |
| 7202 41 | Ferro-chromium with carbon > 4% |
| 7202 49 | Other ferro-chromium |
| 7202 60 00 | Ferro-nickel |
Source: Annex I to Regulation (EU) 2023/956 (as published and subsequently amended). Check the consolidated text on EUR-Lex for the current list before relying on it in a declaration.
Out of CBAM scope (ferro-alloy headings)
- Ferro-silicon (CN 7202 21, 7202 29)
- Ferro-silico-manganese (CN 7202 30)
- Ferro-silico-chromium (CN 7202 50)
- Ferro-molybdenum, ferro-tungsten, ferro-titanium, ferro-vanadium, ferro-niobium and other “ferro-” alloys under CN 7202 7x–9x
These are out of CBAM scope as goods you import. They are still relevant as precursors when they are consumed by a non-EU steel mill whose output you import — because the mill’s embedded emissions include the ferro-alloy input.
Why ferro-alloys matter even when out of scope
Ferro-alloy production is extremely energy-intensive:
- Submerged-arc furnace smelting with coke / coal as reductant.
- Significant electricity use (not counted in CBAM steel direct scope, but part of the ferro-alloy’s own embedded profile).
- Process emissions from reduction and gas-cleaning operations.
When a stainless mill consumes ferrochromium or ferronickel, the embedded emissions of that ferro-alloy flow into the stainless-steel product (CN 7219, 7222, etc.).
What to ask your mill supplier
- Ferro-alloy procurement: FeCr, FeNi, FeMn supplier names, with country of origin.
- Mass used per tonne of stainless or alloy steel.
- Existing emissions data from the ferro-alloy supplier, if any.
- Alloy element origin: Cr, Ni, Mo, Mn, Nb.
Common questions
- Are ferro-alloys themselves in CBAM scope? Some are, some aren’t — see the tables above. Check the exact 8-digit CN subheading before assuming either way.
- Does CBAMWorks support ferro-alloy data? As a precursor to stainless or alloy steel, yes — your mill supplier adds it as a precursor in the installation profile.