How South African mining exporters calculate and declare carbon intensity for EU CBAM compliance. The carbon accounting methodology that determines whether SA minerals face EU carbon tariffs.
The EU Carbon Border Adjustment Mechanism (CBAM) entered its transitional phase in October 2023 and becomes fully operational from January 2026. CBAM applies a carbon price to imports of iron, steel, aluminium, cement, fertilisers, electricity, and hydrogen — all sectors where South Africa is a significant exporter. Under CBAM, EU importers must declare the embedded carbon content of their imports and purchase CBAM certificates to cover the carbon price difference between the EU ETS carbon price and the carbon price paid in the country of origin. South Africa's carbon tax (currently R190/tonne CO2e) is significantly lower than the EU ETS price (currently €50–70/tonne), meaning South African exporters face a carbon tariff on the difference.
The CBAM carbon intensity calculation for mining covers Scope 1 emissions (direct emissions from the mine, including diesel combustion, blasting, and ventilation) and Scope 2 emissions (indirect emissions from purchased electricity, using Eskom's published emission factor). The National DPP Registry provides a CBAM-aligned carbon calculator for South African mining companies that produces a compliant carbon intensity declaration in tonnes CO2e per tonne of mineral exported. The calculator uses the IPCC Tier 2 methodology for Scope 1 emissions and the South African National Greenhouse Gas Inventory emission factors for Scope 2.
The EU Battery Regulation's carbon intensity class system (Class A, B, C) for battery minerals is separate from CBAM but uses similar carbon accounting methodology. Class A (lowest carbon) batteries and minerals command premium pricing from EU battery manufacturers who need to demonstrate low-carbon supply chains to meet their own EU taxonomy obligations. South African manganese and cobalt producers who can demonstrate Class A carbon intensity — through renewable energy procurement, mine electrification, and efficient beneficiation — can command a significant price premium over Class C competitors from the DRC or China.
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