CBAM Country Intelligence Colombia 2026: Carbon Boundary Misalignment through Cerro Matoso Concentration, Coke Invisibility, and Caribbean EU Exposure

Executive Summary

Colombia's exposure to the European Union Carbon Border Adjustment Mechanism, or CBAM, is easy to mischaracterise when analysis starts from national averages. The country is not a large diversified supplier across all CBAM sectors, and a comparatively renewable electricity system does not translate mechanically into a low CBAM burden. The economically relevant exposure is concentrated in a few products and installations, while several large Colombian industrial flows sit partly outside the boundaries used by CBAM accounting. Physical production, emissions accounting, regulatory scope, customs geography and commercial markets can each assign a different identity to the same Colombian industrial flow.

This volume names that condition Carbon Boundary Misalignment: two or more legally or economically relevant boundaries assign materially different carbon, production, geographic or cost identities to the same industrial flow, and the difference changes its CBAM treatment or commercial interpretation. Colombia offers unusually clear examples because its major carbon-intensive exports occupy very different positions relative to the EU regime.

Ferronickel is the most concentrated direct exposure on the production side. Colombia exported 151,520 tonnes of ferronickel in 2024, valued at US$542.1 million, and ranked third among world exporters after Indonesia and Brazil.[1][2] EU destinations (the Netherlands, Italy, Spain and Sweden) took about 42,100 tonnes, or 28 per cent. Almost all of this output comes from Cerro Matoso, the integrated laterite mine and ferronickel smelter in Córdoba that CoreX acquired from South32 on 1 December 2025.[3] CoreX reported 2025 output of 140,228 tonnes of ferronickel containing 36,422 tonnes of nickel, an average product grade of 25.97 per cent.[4]

The EU assigns Colombian ferronickel (CN 7202 60 00) a country-specific base default of 3.480 tCO₂e per tonne, all of it direct. The listed total is increased by 10 per cent in 2026, 20 per cent in 2027 and 30 per cent from 2028, giving a 2026 value of 3.828 tCO₂e/t.[5] Indirect emissions are excluded by law, because ferro-nickel is an Annex II good for which only direct emissions count.[6] Colombian hydropower has no bearing on this default. What matters is the direct-emissions performance of a changing RKEF asset relative to a fixed regulatory value.

That asset has changed materially. Processed ore grade was 1.73 per cent Ni in FY2022 and 1.48 per cent by FY2025, while payable nickel fell from 41.7 kt to 37.1 kt.[7][8][9] South32 had already invested in the OSMOC project to offset natural grade decline, and CoreX has set lower gas and electricity use and higher ferronickel grades as 2026 priorities.[4][10] Ore grade, product grade, furnace utilisation, reductant use and energy demand can shift while the default stays fixed.

These conditions create a Default Shelter: a permitted default that lies below a plant's actual emissions and so becomes the economically preferable declaration. With the 2026 free allocation adjustment applied, a tonne of Colombian ferronickel declared on the default carries a net obligation of about 1.50 certificates, roughly €113 at the 2026 quarterly certificate prices. The benchmark is identical under the actual and default pathways, so actual reporting lowers the obligation only if verified embedded emissions are below 3.828 tCO₂e/t. Cerro Matoso's 2022 Scope 1 inventory of 704,426 tCO₂e, set against gross output of 140,000–160,000 tonnes, gives a site-level intensity of 4.4–5.0 tCO₂e/t, 15–31 per cent above the default.[11] The default stays the better declaration unless emissions outside the CBAM production-process boundary, chiefly the mine fleet, exceed 13–24 per cent of site Scope 1. The shelter narrows as the mark-up rises to 30 per cent in 2028.

Metallurgical coke creates a different kind of misalignment. Colombia exported 3.957 million tonnes of coke and semi-coke in 2024, worth US$1.094 billion, the fourth-largest reported flow in the world.[12][13] Brazil took 43 per cent; EU Member States together took about 540,600 tonnes, or 13.7 per cent. Coke is not an Annex I good, and an input becomes a CBAM precursor only if it is itself listed in Annex I.[14] Three gaps follow. Coke imported into the EU carries no CBAM obligation, although coke production inside the EU is an ETS activity. The coking-stage emissions of Colombian coke burned in Turkish, Brazilian or Indian furnaces do not travel with the steel those furnaces send to Europe. And coal used in Colombian coke ovens is exempt from the domestic carbon tax.[15] Coke is a billion-dollar carbon-intensive industry positioned beside the current CBAM perimeter rather than inside it.

Cement clinker shows a third form of misalignment and, measured by cost against value, the most intense exposure of the three. France reported imports of 115,940 tonnes of Colombian clinker in 2024, against total EU imports from Colombia of 115,996 tonnes.[16] The customs label is France, but the physical market includes French Guiana, where the Argos grinding plant near Cayenne processes imported Colombian clinker.[17][18] French Guiana, Guadeloupe and Martinique are inside the Union customs territory; Aruba, Curaçao and the other Dutch Caribbean islands a few hundred kilometres from Colombia's coast are not.[19] At the 2026 Colombian grey-clinker default of 1.221 tCO₂e/t, the net obligation is about 0.57 certificates per tonne, roughly €43, or 35–40 per cent of the declared import value. The corresponding figure for ferronickel is 3–4 per cent.

Domestic carbon pricing adds a fourth boundary problem. Law 2277 of 2022 caps Colombia's no-causación mechanism at 50 per cent of the tax otherwise caused, exempts coke-oven coal, taxes natural gas only when sold to the refining and petrochemical industries, and phases coal in at 50 per cent of the full rate in 2026.[15] Decreto 969 of 4 August 2026 created the regulatory chapter for the PNCTE.[20] Article 9 of the CBAM Regulation, as amended in 2025, recognises only carbon prices effectively paid for the declared embedded emissions, net of rebates and compensation, and documented.[6][21] For Cerro Matoso's natural gas the recognisable Colombian carbon price is zero.

The CBAM outcome for a Colombian product cannot be read from one national carbon-intensity figure, one electricity factor or one headline tax rate. It emerges from the interaction of Physical Production Space, Emission Accounting Space, Regulatory Space, Customs Geography and Commercial Market Space. Cerro Matoso concentration, coke invisibility, Caribbean EU clinker trade and carbon-price recognition are distinct mechanisms, and each shows what happens when these boundaries fail to coincide.