Which South African Exports Are Subject to CBAM?

Which South African Exports Are Subject to CBAM?

CBAM does not apply to all goods — it targets specific carbon-intensive sectors where the risk of carbon leakage is highest. Understanding which of your exports fall within CBAM's scope is the first step in compliance planning.

The Six CBAM Sectors

EU Regulation 2023/956 identifies six sectors subject to CBAM:

| Sector | SA Export Relevance | Key Products | |--------|---------------------|--------------| | Steel & Iron | Very High | Hot-rolled coil, rebar, wire rod, billets | | Aluminium | High | Primary aluminium, aluminium alloys, semi-finished products | | Cement | Medium | Portland cement, clinker | | Fertilisers | Medium | Urea, ammonium nitrate, mixed fertilisers | | Hydrogen | Emerging | Green hydrogen (SA's future export opportunity) | | Electricity | Low | Cross-border electricity trade |

South Africa's Priority CBAM Exposure

South Africa's most significant CBAM exposure comes from four product categories:

1. Steel and Iron Products South Africa exports approximately 1.2 million tonnes of steel products to the EU annually. With an average embedded carbon intensity of 2.18 tCO₂/tonne, this represents a potential CBAM liability of over EUR 170 million per year at current ETS prices.

2. Aluminium South Africa's aluminium smelters — including Hillside Aluminium (Richards Bay) and Bayside Aluminium (Richards Bay) — export significant volumes to EU markets. Aluminium has one of the highest embedded carbon intensities of any CBAM-covered product at 12.4 tCO₂/tonne.

3. Ferrochrome South Africa produces approximately 50% of the world's ferrochrome, used in stainless steel production. While ferrochrome is not yet formally listed in CBAM Annex I, it is expected to be included in Phase 2 expansion. SA exporters should begin tracking embedded emissions now.

4. Manganese South Africa holds approximately 80% of the world's known manganese reserves. Manganese ore and ferromanganese are under active consideration for CBAM inclusion. The EU has flagged these products in its Phase 2 review.

The 50-Tonne Threshold

CBAM applies to shipments above 50 tonnes per consignment. This threshold was designed to exempt small traders while capturing industrial-scale exports. Key points:

• ▸The threshold applies per shipment, not per year
• ▸Multiple small shipments that collectively exceed 50 tonnes do not trigger CBAM (each shipment is assessed individually)
• ▸However, EU authorities are monitoring for threshold manipulation — artificially splitting large shipments into sub-50-tonne consignments to avoid CBAM

What to Do Next

If your products fall within CBAM's scope, you need to:

1. ▸Register as an Authorised CBAM Declarant in the EU CBAM Registry
2. ▸Calculate the embedded emissions in your products
3. ▸Obtain third-party verification of your emissions data
4. ▸Purchase and surrender CBAM certificates annually

The Digital Product Passport Registry provides a complete CBAM compliance pathway for South African exporters, including CN code classification, emissions calculation, and certificate management.