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CBAM for aluminium exporters
For aluminium, only direct emissions count. EU default values for unwrought aluminium (CN 7601) range from 0.360 to 3.198 tonnes of CO₂e per tonne across 67 countries, and your customer pays for 2.5% of the embedded emissions in 2026, rising to 100% by 2034.
If you ship aluminium to the European Union, your customer now pays for the carbon embedded in it — and pays more when you send no data. This is what the rules ask of you.
Compare with the EU default free →
What is covered
CN chapter 76 — unwrought aluminium and aluminium products. The code on your export invoice decides it, not the name of the product.
Which emissions count
In the definitive period, direct emissions only. That means fuels burned in fixed equipment at your site, process emissions from materials such as carbonates and electrodes, and the emissions embedded in the CBAM material you purchased. Electricity is reported but not counted — sintered ore is the single exception.
COUNTS
- Fuels burned — drying, de-coating, melting
- Anode consumption during smelting
- PFC emissions from anode effects
- Emissions embedded in the unwrought aluminium you bought
REPORTED, BUT DOES NOT COUNT
- Electricity you consume — the largest input of a primary smelter, and it still does not count
- Scrap fed in — it counts as zero, which is why recyclers show a very low figure
- Alumina, anodes and cryolite as purchased goods — they carry zero embedded emissions
(your direct emissions + emissions of the material you bought) ÷ saleable output= tonnes of CO₂e per tonne of product. Anode consumption counts as your own process emission; the anodes you bought carry no embedded emissions of their own.
- Primary smelting — anode consumption and PFC emissions from anode effects both count. Alumina, anodes and cryolite themselves carry zero embedded emissions. This tool does not yet calculate PFC, so it does not handle primary smelters.
- Secondary melting — scrap counts as zero, so recyclers often show a very low figure. Fuel for drying, de-coating and melting still counts.
- Extruders and rollers — the unwrought aluminium you buy carries its emissions into your product; your own furnaces add the rest.
What the number looks like
The figure is tonnes of CO₂e per tonne of product: your own direct emissions plus the emissions of the material you bought, divided by your saleable output. Scrap and returned product are excluded from output; offcuts and losses stay in the input side.
What it costs your customer
Certificate cost is tonnes × your value × the EU carbon price × the phase-in factor, which is 2.5% in 2026 and rises to 100% by 2034. With no data from you, the country default plus mark-up is used instead. The gap between the two is what you are negotiating over.
Compare against your country's default →
Verification
From 2026, actual values must be checked by an accredited verifier before they can be used. Plan for it, and until then describe your figures honestly as verification-ready, not verified.
Questions exporters ask
Which products does CBAM cover?
CBAM covers cement, iron and steel, aluminium, fertilisers, hydrogen and electricity, identified by CN code rather than by product name.
For metals, iron and steel sit mainly in CN chapters 72 and 73 and aluminium in chapter 76, from unwrought metal to finished items such as screws, tubes and structures. Check the code on your export invoice against Annex I of the Regulation.
Source: Regulation (EU) 2023/956, Annex I
How is the CBAM emissions value per tonne calculated?
It is your installation's direct emissions attributed to the product, plus the emissions embedded in the CBAM materials you bought and consumed, divided by the tonnes of product you made.
The result is tonnes of CO₂e per tonne of goods for one calendar year. Scrap and returned product are excluded from output; offcuts and losses stay on the input side.
Source: Regulation (EU) 2023/956, Annex IV
Do electricity emissions count for steel and aluminium under CBAM?
No — in the definitive period only direct emissions count for iron, steel and aluminium; electricity is reported in the template but does not enter the product's value, with sintered ore as the single exception.
Electric arc furnace producers still count electrodes, natural gas and the carbon in scrap and alloys.
Source: Regulation (EU) 2023/956, Annex II; Commission Guidance No. 5d/5e, pp. 8–9
How much does CBAM cost my EU customer?
Roughly: tonnes imported × emissions per tonne × the EU carbon price × the phase-in factor, which is 2.5% in 2026 and rises to 100% by 2034.
Using the default value with its mark-up instead of your real figure raises the emissions per tonne, and therefore the cost, for every tonne.
Source: Regulation (EU) 2023/956, Article 31
Is steel or aluminium scrap covered by CBAM?
No — ferrous waste and scrap (CN 7204) and aluminium waste and scrap (CN 7602) are not CBAM goods, so no default value or emissions data applies to scrap you sell.
Scrap you melt into a covered product enters your own calculation with zero embedded emissions; the fuel and process emissions of melting it still count.
Source: Regulation (EU) 2023/956, Annex I; Guidance 3 on embedded emissions
Last updated 2026-10-05.
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