CBAM and Aluminium Imports: Understanding Your Obligations

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

Which aluminium products are in scope

In-scope aluminium products include:

•      Primary aluminium —unwrought

•      Aluminium alloys

•      Plates, sheets, and strip

•      Aluminium foil

•      Tubes, pipes, and profiles

•      Certain fabricated aluminium goods

Why country of origin matters so much

Aluminium produced in Norway — where the electricity grid is almost entirely hydroelectric — has dramatically lower indirect emissions than aluminium produced in China or India using coal-dominated grids. This means that the same physical product can have embedded emissions that differ by a factor of five or more depending solely on where it was made. For no other CBAM-covered material is the sourcing decision as financially consequential as it is for primary aluminium.

Secondary aluminium: a lower-cost route

Aluminium produced from recycled scrap — secondary aluminium — bypasses the energy-intensive electrolytic smelting process entirely. Its embedded emissions are typically 90–95% lower than primary aluminium. Importers sourcing secondary material may have materially lower CBAM obligations. Verification of the recycled content and production methodology is required to claim this benefit.

What aluminium importers should do now

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

2.    Identify the primary vs secondary split in your supply chain.

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

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

5.    Assess whether switching to secondary aluminium or low-carbon-grid primary sources could reduce your certificate liability.

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