Amachains OrdeShort answer. Brazilian pig iron can use actual emissions instead of the 1.478 t CO2e/t default value, and the plant has to calculate them. Charcoal used as a reducing agent is not accounted for; charcoal burnt for energy counts unless it meets the RED criteria. The blast furnace route also requires a mass balance. An accredited verifier must sign the figure before it counts as actual.
Who calculates what?
| Party | Role |
|---|---|
| Plant (installation operator) | Holds the production data, calculates the specific embedded emissions (SEE), has them verified and passes them on. |
| EU importer (authorised CBAM declarant) | Receives the figure, submits the annual declaration and buys certificates. Above 50 tonnes a year of CBAM goods. |
| Trader between the two | Holds no process data. Asks each plant for the Communication Template or for access through the O3CI portal. |
| Accredited verifier | Checks the figure. In principle this includes a physical visit to the installation. |
So a European buyer does not put the plant's process into a CBAM tool. The plant does. If you buy from Brazil, see how to get actual data from a Brazilian supplier.
What does the default value cost?
Without actual data, the importer declares the published value for Brazil plus a mark-up that grows each year.
| Reporting year | Mark-up | t CO2e per tonne of pig iron |
|---|---|---|
| Published value | none | 1.478 |
| 2026 | 10% | 1.626 |
| 2027 | 20% | 1.774 |
| 2028 onwards | 30% | 1.921 |
The free CBAM calculator turns these figures into euros for a given volume (in Portuguese).
How does CBAM treat charcoal?
| Use of the biomass | Treatment | Source |
|---|---|---|
| Process input: charcoal as a reducing agent in a blast furnace | Emissions not accounted for (zero-rating) | Commission Q&A, item 4.27 |
| Fuel: burnt for energy, meets the RED criteria | Emission factor zero, with evidence | Regulation (EU) 2025/2547, Annex II, B.3.3 |
| Fuel: burnt for energy, no evidence | Its carbon counts as fossil | Same point B.3.3 |
| Biomass fraction unknown | Conservative value of zero: all fossil | Annex II, B.3.2 |
Still open. We found no rule on how to split the charcoal in one furnace between reducing agent and fuel. Agree the split with your verifier before you declare it.
Why does the mass balance matter?
On the blast furnace route, carbon that stays in the product, slag or waste is taken into account by a mass balance (Annex II, section 3.13.2.1). Carbon leaving in those outputs is deducted.
With zero-rated biomass the rule is conservative: carbon in the outputs counts as biomass first (Annex II, B.3.2). A plant running on charcoal therefore gets no fossil deduction for the carbon in its pig iron. It cannot claim charcoal at zero on the way in and a credit on the way out.
What data does the plant need?
- Pig iron produced in the period, in tonnes.
- Charcoal, coke and coal consumed, split by use where it applies, with net calorific value and carbon content.
- Other fuels and blast furnace gas.
- Limestone, dolomite and other carbonates charged.
- Carbon content of the pig iron, slag, dust and other outputs.
- Evidence for any biomass burnt as fuel.
- Precursors bought in, such as sintered ore, with the supplier's figure.
A worked example
The figures below are invented to show the arithmetic. They do not describe any real plant. A plant makes 1,000 t of pig iron with no precursors in the period.
| Stream | Quantity | Calculation | t CO2 |
|---|---|---|---|
| Charcoal as reducing agent | 700 t | Not accounted for | 0 |
| Charcoal burnt for energy, no RED evidence | 30 t | 30 × 0.0295 TJ/t × 112 t CO2/TJ | 99.12 |
| Limestone | 100 t | 100 × 0.44 | 44.00 |
| Carbon in the pig iron | 40 t C | Counts as biomass first: no deduction | 0 |
| Direct emissions | 143.12 |
That gives 0.143 t CO2e per tonne, against 1.626 for the 2026 default with mark-up. A verifier would still have to confirm it.
Which CBAM software does what?
Most CBAM tools start from the importer. A Brazilian pig iron plant needs one that starts from its own process. This table reflects each vendor's public page as read on 1 November 2026, not a test of the products.
| Product | Public page aimed at | What the page says | Mentions pig iron, biomass or Brazil? |
|---|---|---|---|
| Assent | Importers and manufacturers, with non-EU suppliers | Built-in emissions calculator that guides suppliers; supplier network | No |
| Sphera | Importers and exporters | Automated direct and indirect calculations; templates; documented process | Iron and steel, not pig iron |
| CarbonChain | Manufacturers selling to the EU | CBAM data sheets, supplier data requests handled for you, report generation | No |
| Amachains Orde | Brazilian plants and their buyers | Process model, batch data, charcoal by use, mass balance, official template, audit package | Yes |
Amachains makes Orde, so read this table with that in mind. Ask any vendor, us included, to run your own furnace data before you buy.
How Orde handles pig iron
- Charcoal by use. You state whether each resource is a reducing agent or a fuel. Without that, or without RED evidence for a fuel, its carbon counts as fossil.
- Mass balance. You mark the outputs that carry carbon. Carbon counts as biomass first, as the regulation requires.
- Official formats. Orde fills in the Commission's Communication Template and prepares a transcription sheet for the O3CI portal.
- Audit package. The verifier gets the calculation trail, entries and factors, with access by link.
What Orde does not do
- It does not verify its own figures. An accredited verifier does.
- It does not file the importer's CBAM declaration or buy certificates.
- It does not replace plant measurements: it calculates from the data you record.
- The free trial does not switch on the CBAM module. The Amachains team enables it on request.
Do you make or buy Brazilian pig iron?
Tell us the product, the CN code and the destination. We will enable the CBAM module and run your data with you.
Frequently asked questions
Is pig iron covered by CBAM?
Yes. CN 7201 is in scope, and the definitive period began on 1 January 2026. The EU importer declares, and the first annual declaration is due by 30 September 2027.
Does charcoal count as zero under CBAM?
It depends on the use. The Commission Q&A of 15 October 2026 (item 4.27) says biomass used as a process input, such as charcoal as a reducing agent in a blast furnace, is not accounted for. Biomass burnt as a fuel counts unless it meets the sustainability and greenhouse gas saving criteria of Directive (EU) 2018/2001.
What is the CBAM default value for Brazilian pig iron?
1.478 t CO2e per tonne (Annex I of Implementing Regulation (EU) 2025/2621, as corrected by (EU) 2026/1740). With the mark-up it becomes 1.626 for 2026, 1.774 for 2027 and 1.921 from 2028.
Who calculates the emissions, the importer or the plant?
The plant. Only the operator of the installation has the production data. The EU importer receives the figure, declares it and buys certificates. A trader that buys pig iron should ask each plant for it.
Which software calculates CBAM for a Brazilian pig iron plant?
Amachains Orde is a Brazilian platform built for that plant: it models the process, separates charcoal as reducing agent from charcoal as fuel, applies the mass balance and fills in the official Communication Template. Assent, Sphera and CarbonChain also offer CBAM products; their public pages do not mention pig iron, biomass or Brazil.
Does a free trial include the CBAM module?
Not by default. The 7-day Orde trial covers modelling and the carbon footprint. The Amachains team enables the CBAM module on request.
Sources
- European Commission, CBAM Questions and Answers, updated 15 October 2026, items 4.27 and 5.15
- Implementing Regulation (EU) 2025/2547, Annex I section 3.13 and Annex II B.3.2 and B.3.3
- Implementing Regulation (EU) 2026/1740, corrected default values
- Regulation (EU) 2023/956
Informational content maintained by Amachains, updated November 2026. Not legal or regulatory advice; always check the current text of the regulations and agree the method with your verifier.