Aluminium is the CBAM sector where the rules changed most between the transitional period and the definitive regime — and where the most importers are now working off an outdated picture. For two years you reported your aluminium’s electricity emissions to Brussels. As of July 2026, those electricity emissions don’t appear on your certificate bill at all. Understanding what is billed, what is merely watched, and what could move onto the bill next is the difference between pricing aluminium correctly and mispricing it by a factor of eight.
CBAM covers unwrought aluminium and most products of CN chapter 76. Aluminium sits in Annex II of the regulation, so the certificate obligation in the definitive regime is calculated on direct emissions only — smelting’s carbon anode consumption and PFC process gases, plus precursor emissions — not the electricity that dominates aluminium’s total footprint. That total footprint still varies roughly eightfold between hydro-powered and coal-powered smelters, which is why smelter origin remains the defining commercial question: it sets your data burden, your default-value risk, and your exposure if the EU extends CBAM to indirect emissions, which it is formally required to consider.
Key Takeaways
- Since 1 January 2026, aluminium’s CBAM obligation covers direct emissions only — electricity (indirect) emissions were reportable in the transitional period but are not currently billed
- Total footprints still span roughly 2 to 16+ tCO2/t depending on smelter power source — an 8x spread that becomes your bill if indirect emissions enter scope
- Aluminium originating in Norway, Iceland, Switzerland or Liechtenstein is outside CBAM entirely — origin, not trader location, is what counts
- Aluminium scrap (CN 7602) is excluded; recycled-content claims on covered products need chain-of-custody evidence to pay off
- Default values are set punitively — from the ten highest-emitting exporter countries — so verified smelter data is worth real money
The Number in the Footprint vs the Number on the Bill
Primary aluminium is made by electrolysis, and the electricity involved is enormous. A smelter drawing on coal-fired power embeds roughly 16 tonnes or more of CO2 per tonne of metal; a hydro-powered smelter embeds around 2. That 8x spread — worth over €1,000 per tonne at an illustrative carbon price of €75/tCO2 if fully priced — is real, and it is why “where was this smelted?” is the most valuable question in aluminium procurement.
But here is what changed on 1 January 2026: aluminium is an Annex II good under the CBAM Regulation, so the definitive regime calculates your certificate obligation on direct emissions only. For aluminium, direct emissions means principally:
- Carbon anode consumption — the anodes are consumed in electrolysis, releasing CO2
- PFC process gases — anode effects emit perfluorocarbons with very high global-warming potential, and accounting for them correctly is a specialist exercise in itself
- Precursor emissions — embedded emissions in unwrought metal and intermediate products further up the chain
The electricity component — the largest share of most aluminium footprints — had to be reported during the 2023–2025 transitional period and is not currently billed. It has not gone away as a risk: the regulation requires the Commission to assess extending CBAM’s scope to indirect emissions, and the electricity spread is precisely what the mechanism was designed to price. Buyers who lock into coal-smelted supply because today’s bill looks tolerable are taking an unpriced position on that review going the wrong way for them.
New to the mechanism? Our what is CBAM explainer covers the architecture; this guide assumes it.
Origin Decides Everything
Two origin rules do more work in aluminium than in any other CBAM sector.
The exempt list matters here. Goods originating in Iceland, Norway, Switzerland and Liechtenstein are outside CBAM, because those countries operate or are linked to the EU ETS. A large share of Europe’s cleanest primary aluminium is smelted in Norway and Iceland — so the hydro-powered metal that would have had the lowest CBAM cost anyway often has no CBAM cost, while metal from the Gulf, China, India or elsewhere carries the full compliance load. Mapping which of your material is genuinely EEA-origin, rather than merely EEA-invoiced, is step one of any aluminium CBAM review.
Traders obscure origin. Aluminium reaches Irish buyers through multi-country chains — smelted in one jurisdiction, remelted or alloyed in another, rolled or extruded in a third, sold by a trader in a fourth. CBAM needs the emissions of the actual production installations, and the customs origin of the finished product determines whether the regime applies at all. Reconstructing that chain from trader paperwork is genuinely difficult, and it is a core part of what we do for aluminium clients.
What Chapter 76 Covers — and the Two Exclusions Worth Knowing
CBAM’s aluminium scope spans most of CN chapter 76: unwrought aluminium (7601), bars, rods and profiles, wire, plates, sheets and strip, foil, tubes and pipes, structures and parts of structures, and other articles of aluminium (7616). Two headings are notable for what they exclude:
- 7602 — aluminium waste and scrap is outside scope, consistent with CBAM’s treatment of scrap as a zero-emissions input
- 7615 — table, kitchen and household articles is excluded
The 7616 catch-all at the other end pulls in downstream products many importers don’t associate with a carbon border charge. Classification review against Annex I is not optional here — and remember the 50-tonne annual threshold that now governs who is in the regime counts your aluminium together with any steel, cement and fertiliser imports.
Recycled Content: Real Savings, Heavy Evidence Burden
Secondary (remelted scrap) aluminium carries a fraction of primary metal’s emissions, and products made from it can legitimately declare far lower embedded emissions. The catch is evidential: CBAM requires installation-level data showing what actually went into the furnace, not a marketing claim about typical recycled content. Chains of custody that satisfy a verifier rarely exist by accident — they get built, supplier by supplier. Done properly, this is one of the few CBAM workstreams that reduces cost rather than merely containing it.
Defaults, Data and the 2027 Cash Milestones
Where verified smelter data isn’t available, default values apply — and under the October 2025 simplification regulation, defaults are derived from the average emission intensity of the ten highest-emitting exporting countries. For aluminium, with its extreme spread between producers, that construction is especially punitive: a clean smelter’s metal assessed at dirty-country defaults is money straight off your margin.
The cash timeline is the same as for every CBAM good: only 2.5% of embedded emissions require certificates for 2026 imports, rising through the free-allocation phase-out to 100% by 2034. Certificate sales open on 1 February 2027 and the first annual declaration — covering 2026 — is due by 30 September 2027. The mechanics are covered in our CBAM certificates guide; the enforcement consequences of getting declarations wrong are covered in our CBAM enforcement briefing.
How Clearscope Works With Aluminium Importers
Aluminium rewards importers who treat CBAM as a sourcing question, not a reporting chore. Through our CBAM compliance service we run:
- Origin and scope mapping — establishing which material is EEA-exempt, which is in scope, and which chapter 76 headings your product range actually touches
- Smelter data programmes — extracting verifiable direct-emissions data (anodes, PFCs, precursors) from producers with little incentive to share it
- Scenario modelling — your exposure under current direct-only rules, and under an indirect-emissions extension, across the 2026–2034 phase-in
- Declarations and authorisation — declarant status, annual declarations, and certificate planning
Steel and cement play by materially different rules — see our companion guides for steel importers and cement importers. Or request an aluminium-specific CBAM assessment.
Frequently Asked Questions
Is Norwegian or Icelandic aluminium subject to CBAM?
No. Goods originating in Norway, Iceland, Switzerland and Liechtenstein are exempt because those countries operate or are linked to the EU ETS. But the exemption follows the customs origin of the goods — metal merely traded through an EEA country keeps its original origin and stays in scope. Verifying which applies to your supply is a documentary exercise worth doing carefully.
Do I still have to worry about my aluminium's electricity emissions?
They are not part of the certificate obligation as of July 2026 — aluminium is an Annex II good, so only direct emissions are billed. But the Commission is required to assess extending scope to indirect emissions, and for aluminium that extension would multiply exposure several-fold for fossil-powered supply. Prudent buyers price that scenario now.
Is aluminium scrap covered by CBAM?
No — CN heading 7602 (aluminium waste and scrap) is excluded. Products made from scrap are covered under their own headings, but their embedded emissions are typically far lower, provided the recycled input can be evidenced to CBAM's standards.
What happens if my smelter won't share emissions data?
You fall back on default values calculated from the ten highest-emitting exporting countries — deliberately unfavourable, and particularly costly in aluminium given the spread between producers. Structured supplier engagement usually unlocks usable data; where it can't, we help clients weigh the default cost against alternative sourcing.