CBAM and Manganese: What SA Mining Exporters Must Know

CBAM and Manganese: What SA Mining Exporters Must Know

South Africa is the world's dominant manganese producer, holding approximately 80% of the world's known manganese ore reserves in the Kalahari Manganese Field in the Northern Cape. The country exports manganese ore, ferromanganese, and silicomanganese to markets worldwide, with the EU representing a significant and growing destination.

Current CBAM Status for Manganese

As of January 2026, manganese ore (HS 2602) is not formally included in CBAM Annex I. However, this situation is changing rapidly:

• ▸Ferromanganese (HS 7202.11, 7202.19) — used in steel production — is under active review for CBAM Phase 2 inclusion
• ▸Silicomanganese (HS 7202.30) — a key input for stainless steel — is similarly flagged
• ▸The European Commission's Phase 2 review, expected to conclude in 2026–2027, is widely expected to include these products

SA manganese exporters who wait for formal inclusion before preparing face a compressed compliance timeline. The time to start is now.

South Africa's Manganese Export Profile

The Kalahari Manganese Field, centred around Hotazel in the Northern Cape, is the world's largest known manganese ore deposit. Key SA manganese producers include:

• ▸Assmang (Nchwaning and Gloria mines)
• ▸South32 (Hotazel Manganese Mines)
• ▸Kalagadi Manganese
• ▸United Manganese of Kalahari (UMK)

These operations produce approximately 16–18 million tonnes of manganese ore annually, with a significant portion processed into ferromanganese and silicomanganese at smelters in the Northern Cape and Gauteng.

Embedded Carbon in Manganese Production

The embedded carbon intensity of manganese products varies significantly by product type and production method:

| Product | Typical Embedded Carbon | Notes | |---------|------------------------|-------| | Manganese ore (run-of-mine) | 0.3–0.8 tCO₂/tonne | Mining and transport | | Ferromanganese (high-carbon) | 1.5–2.0 tCO₂/tonne | Smelting energy-intensive | | Silicomanganese | 2.0–2.5 tCO₂/tonne | Higher energy input |

South Africa's electricity grid remains coal-dominated (approximately 80% coal-fired), which significantly increases the embedded carbon of electricity-intensive smelting operations compared to producers in countries with cleaner grids.

Preparing for CBAM Phase 2

SA manganese exporters should take the following steps now:

1. Establish a carbon baseline Commission a scope 1 and scope 2 emissions inventory for your mining and processing operations. This baseline will be the foundation of your CBAM declarations when Phase 2 takes effect.

2. Engage a third-party verifier CBAM requires that embedded emissions declarations be verified by an accredited third party. Identify a South African or international verifier with CBAM expertise now, before demand peaks.

3. Register with the EU CBAM Registry Even if your products are not yet formally covered, registering as a prospective declarant establishes your presence in the system and reduces administrative burden when Phase 2 takes effect.

4. Explore decarbonisation pathways The lower your embedded carbon intensity, the lower your CBAM liability. Opportunities include switching to renewable electricity for smelting, improving process efficiency, and investing in carbon capture.

The Gate 2 Compliance Requirement

CBAM is not a future requirement — it is live now. As of January 1, 2026, South African exporters shipping goods above 50 tonnes to the EU must have a Carbon Border Adjustment declaration or their shipment will be blocked. This is Gate 2 of 3. Complete your KYC identity verification first, then return here to understand your CBAM obligations, then register at the Digital Product Passport Registry to complete all three gates in one place.

Complete your CBAM compliance registration at the Digital Product Passport Registry.