Natural stone is not in scope of the EU Carbon Border Adjustment Mechanism. Neither is chromite ore. A quarry shipping granite blocks into Antwerp and a trader moving chromite out of Karachi carry no CBAM exposure on those cargoes, today or on any date currently written into law.
We say that plainly because the opposite is being told to sellers across the region, sometimes with a fee attached. The correction is worth money on its own. It is also fragile in a particular way, and the reason for the fragility is the more useful half of this piece.
Six sectors, and nothing outside them
CBAM covers six sectors: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. That is the Commission's own list and it has not widened.
Cement is where the confusion about stone starts, because a mineral that comes out of the ground and ends up in a building sounds like it should belong to the same family. It does not, because the sector is not defined by material description. It is defined by a closed list of Combined Nomenclature codes: 2507 00 80, and 2523 10, 2523 21, 2523 29, 2523 30 and 2523 90. That is the entire cement sector for CBAM purposes.
Slate is classified under CN 2514. Marble and travertine fall under CN 2515. Granite falls under CN 2516. None of those three headings appears anywhere in Annex I of the regulation. We hold that finding with high confidence, and it is not a matter of interpretation: the codes are either printed in the annex or they are not, and they are not.
The same reasoning disposes of chromite ore. Chromite is CN 2610, and no Chapter 26 ore of any kind appears in Annex I. An ore shipment is not a CBAM shipment.
Once it goes through a furnace, the answer changes
Ferrochrome is in scope, and the drafting that puts it there is worth understanding because it works in the opposite direction to the cement provisions.
For Chapter 72, Annex I does not list what is covered. It takes the chapter wholesale and then names what is carved out. The exclusions are 7202 2 ferro-silicon, 7202 30, 7202 50 ferro-silico-chromium, 7202 70, 7202 80, 7202 91, 7202 92, 7202 93, and 7202 99 10, 7202 99 30 and 7202 99 80.
Ferro-chromium sits at 7202 41 and 7202 49. Neither code appears on that exclusion list. It is therefore covered, not because anybody wrote "ferrochrome is in scope" but because nobody wrote it out.
The trap sits at eight digits
Hold the two chromium ferroalloys side by side. Ferro-silico-chromium under 7202 50 is expressly excluded. Ferro-chromium under 7202 41 and 7202 49 is not. Same metal, same industry, frequently the same customer, and a completely different regulatory position. Nothing about the material name tells you which side of the line a parcel falls on. The eight digit code does, and it does so per shipment.
| Material | CN code | CBAM position | | --- | --- | --- | | Slate | 2514 | Out of scope | | Marble, travertine | 2515 | Out of scope | | Granite | 2516 | Out of scope | | Chromite ore | 2610 | Out of scope | | Ferro-silico-chromium | 7202 50 | Excluded by name | | Ferro-chromium | 7202 41, 7202 49 | In scope | | Cement clinker and related | 2523 10 to 2523 90 | In scope |
The asymmetry in how those two blocks are drafted is the thing to carry away. Stone and ore are out because they are absent from a closed list, so widening the annex to catch them would take a deliberate legislative act naming them. Ferrochrome is in because it is absent from an exclusion list, so anything that lands in Chapter 72 and is not carved out is caught by default. Exemption by omission is stable. Exposure by omission is not, and it is the one that moves quietly.
What the October 2025 amendment did
The definitive regime applies from 1 January 2026. The instrument that reshaped it is Regulation (EU) 2025/2083, published on 17 October 2025 and in force from 20 October 2025.
The change that matters most to anyone selling ferroalloy is the new de minimis. The old threshold was a 150 euro consignment value, which caught almost everything. It has been replaced by 50 tonnes of cumulative net mass per importer per calendar year, excluding hydrogen and electricity. The Commission's own estimate is that this exempts around 90 per cent of importers while still capturing 99 per cent of embedded emissions, which tells you exactly what kind of threshold it is: it clears out the small and the occasional and leaves the tonnage untouched.
Read the wording carefully before treating it as relief. It is cumulative and it is annual, and it attaches to the importer rather than to the consignment. A European buyer who takes one small parcel from you and nothing else in the year may sit beneath it. A buyer who takes three does not, and the third shipment retroactively drags the first two into the accounting.
Three timing changes came with it. Certificate sales begin on 1 February 2027, so imports made during 2026 are settled retroactively in 2027 rather than as they happen. The first annual declaration deadline moved from 31 May to 30 September of the following year. The quarterly certificate holding requirement fell from 80 per cent of embedded emissions to 50 per cent. All three loosen your buyer's cash flow position, which is relevant to you in negotiation even though none of them is your obligation.
The duty is your buyer's, the data request is yours
The CBAM obligation sits on the EU importer or the authorised CBAM declarant. It has never sat on the exporter, and nothing in the amended regime moves it. No seller in Pakistan or the Gulf will ever file a CBAM declaration.
That is a smaller comfort than it sounds. Your buyer holds a liability priced in certificates and cannot discharge it without emissions data from the installation that made the material, and the installation is yours. The legal duty and the evidentiary burden have been placed in different countries, and the mechanism by which they are reunited is your sales contract. Expect the data request to arrive as a commercial condition rather than a regulatory one, because that is the only form it can take.
What follows here is our reading of the published instruments and general commentary rather than legal advice. Classification is finally a matter for the customs authority in the member state of import, so where a product sits near a boundary the answer is a binding tariff information ruling and your own counsel, not an article.
What is proposed, and what is law
There is a downstream extension in motion. The Commission published a proposal on 17 December 2025, and the Council agreed a general approach on 12 June 2026. It would add roughly 180 downstream steel and aluminium intensive CN codes from 1 January 2028, bringing an estimated 7,500 new importers into scope, and it carries anti-circumvention powers aimed at artificial splitting of shipments.
It is not law. It remains inside the ordinary legislative procedure, which means both the code list and the date can still move. We would not build a 2028 cost line on it yet. What we would note is that no stone and no ore appears anywhere in the downstream proposal either, so the exemption we opened with survives the next visible round of expansion.
The anti-circumvention limb deserves a moment. Once a threshold is expressed in tonnes per importer per year, the arithmetic invites a seller to spread volume across more importers, and somebody in a meeting will eventually suggest it. That practice is already being legislated against by name, before the thresholds it targets have even produced their first settlement cycle. A structure built to sit under 50 tonnes is not a compliance position. It is a paper trail with a date on it.