CBAM and Aluminium Imports: Understanding Your Obligations

Aluminiumis unique among CBAM-covered materials because its carbon footprint isdominated not by direct combustion but by the electricity consumed during theelectrolytic smelting process. This makes indirect emissions — from electricitygeneration — central to CBAM calculations, and the carbon intensity of theelectricity grid supplying a smelter directly determines embedded emissions.

Which aluminium products are in scope

In-scopealuminium products include:

•      Primary aluminium —unwrought

•      Aluminium alloys

•      Plates, sheets, and strip

•      Aluminium foil

•      Tubes, pipes, and profiles

•      Certain fabricatedaluminium goods

Why country of origin matters so much

Aluminiumproduced in Norway — where the electricity grid is almost entirelyhydroelectric — has dramatically lower indirect emissions than aluminiumproduced in China or India using coal-dominated grids. This means that the samephysical product can have embedded emissions that differ by a factor of five ormore depending solely on where it was made. For no other CBAM-covered materialis the sourcing decision as financially consequential as it is for primaryaluminium.

Secondary aluminium: a lower-cost route

Aluminiumproduced from recycled scrap — secondary aluminium — bypasses theenergy-intensive electrolytic smelting process entirely. Its embedded emissionsare typically 90–95% lower than primary aluminium. Importers sourcing secondarymaterial may have materially lower CBAM obligations. Verification of therecycled content and production methodology is required to claim this benefit.

What aluminium importers should do now

1.    Confirm which products inyour import portfolio match the CBAM CN codes for aluminium.

2.    Identify the primary vssecondary split in your supply chain.

3.    For primary aluminium, mapthe electricity grid intensity at each smelter you source from.

4.    Engage suppliers to obtainverified emissions data, prioritising your highest-volume sources.

5.    Assess whether switching tosecondary aluminium or low-carbon-grid primary sources could reduce yourcertificate liability.

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