CBAM by sector
CBAM and Aluminium
Aluminium is one of the six sectors covered by the EU Carbon Border Adjustment Mechanism (CBAM). If you import aluminium — unwrought metal or semi-finished forms such as bars, profiles, wire, plates, sheets and foil — you may have CBAM obligations once your annual imports cross the 50-tonne threshold. This page explains what is covered and what to do.
Aluminium
Direct emissions · 50 t threshold
TL;DR
- Aluminium is in scope under Regulation (EU) 2023/956, defined by the CN codes in Annex I.
- Covered forms include unwrought aluminium and semi-finished products: bars, rods, profiles, wire, plates, sheets, foil, tubes and structures.
- Embedded emissions for aluminium are largely direct (the indirect, electricity-based share is treated more narrowly than for cement or fertilisers).
- Aluminium counts toward the cumulative 50-tonne annual de-minimis threshold; importers under 50 tonnes/year of covered goods are exempt.
In scope
What CBAM covers for aluminium
- Unwrought aluminium (the primary metal, alloyed or not).
- Aluminium bars, rods and profiles.
- Aluminium wire.
- Aluminium plates, sheets and strip.
- Aluminium foil, and aluminium tubes, pipes and certain structures.
Annex I lists each product by its CN code, so confirm scope by matching your customs code. An aluminium sheet is covered, but an aluminium car door is not (its CN code sits outside Annex I).
These products are listed in Annex I of Regulation (EU) 2023/956 by their CN code, so you confirm scope by matching your product code, not the product name alone. Use the goods & CN-code reference to check a specific code.
Emissions
How embedded emissions are counted
Emissions are counted as direct emissions. For aluminium, CBAM focuses on direct emissions from the production process. The indirect, electricity-based share is treated more narrowly than for cement and fertilisers — relevant because primary aluminium smelting is highly electricity-intensive. Regulation (EU) 2023/956
Actual, verified emissions data is preferred and usually cheaper than the conservative default values. Where you cannot get verified figures, you can fall back to the published default values, which carry a mark-up. See the CBAM default-values reference for the figures and mark-up rates.
The 50-tonne threshold
Does the de-minimis exemption apply?
Aluminium counts toward the 50-tonne threshold
The hard part
The hard part for aluminium
- Confirming CN codes across many semi-finished forms (bars, profiles, wire, plate, foil), each potentially a different code.
- Electricity intensity: smelting is electricity-heavy, so even where the indirect share is treated narrowly, the upstream emissions picture is sensitive to the power source.
- Obtaining installation-level data from smelters and rolling mills, especially from origins new to emissions reporting.
- Tracking cumulative tonnage across all four mass-counted sectors to know when you cross 50 tonnes.
What to do
What to do for aluminium
- Confirm scope by matching every aluminium product line against the CN codes in Annex I.
- Add up your annual net mass across steel, aluminium, cement and fertilisers to see whether you cross the 50-tonne threshold.
- Ask your suppliers for actual, verified embedded-emissions data (usually cheaper than default values).
- If you import above the threshold, become an authorised CBAM declarant (or use an indirect customs representative who is) via the CBAM Registry.
- Gather embedded-emissions data from your suppliers, or fall back to the published default values, then file your annual CBAM declaration and surrender certificates by 30 September of the following year.
For the roles and how to apply, see the CBAM declarant guide; for when you need a verifier, see CBAM verification; and for collecting data from suppliers see the supplier data guide.
FAQ
Aluminium and CBAM: common questions
- Is aluminium foil covered by CBAM?
- Yes, where its CN code is listed in Annex I of Regulation (EU) 2023/956. Aluminium foil, plates, sheets, bars, profiles and wire are among the covered semi-finished forms. Confirm each product by its exact CN code.
- Are finished aluminium products like car parts in scope?
- Generally no. Coverage is driven by the CN code of the imported good. An aluminium sheet is covered, but an aluminium car door (a different CN code outside Annex I) is not. Always check your specific code against the current Annex I.
- Are indirect (electricity) emissions counted for aluminium?
- For aluminium, CBAM focuses on direct emissions, with the indirect (electricity) share treated more narrowly than for cement and fertilisers — even though smelting is electricity-intensive. Check the latest implementing rules for the precise treatment.
- When do aluminium importers have to comply with CBAM?
- The definitive period began on 1 January 2026. If your annual imports cross the 50-tonne threshold you must be (or use) an authorised CBAM declarant. The first annual declaration and surrender for 2026 imports is due 30 September 2027.
Get ready for CBAM
Work through the CBAM Readiness Checklist, then explore the tools and guides built for your role.
This is guidance, not legal advice
Sources
- [1]Regulation (EU) 2023/956, consolidated text including Annex I (EUR-Lex)retrieved 8 Jun 2026
- [2]European Commission (DG TAXUD): Carbon Border Adjustment Mechanismretrieved 8 Jun 2026
- [3]DG TAXUD: Simplifications for CBAM (Regulation (EU) 2025/2083)retrieved 8 Jun 2026
- [4]EUR-Lex: Carbon Border Adjustment Mechanism (summary)retrieved 8 Jun 2026
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