What changed from 2026
The European Commission states that the CBAM definitive period started on 1 January 2026. For importers of CBAM goods above the applicable mass threshold, the regime shifts from learning-phase reporting to a real compliance cycle: importers must seek authorised declarant status, declare embedded emissions, and surrender the corresponding number of CBAM certificates each year.
The supplier is no longer just selling metal. They must also supply traceable emissions data, installation-level information and carbon-price evidence where applicable.
- Aluminium remains a covered CBAM sector.
- Importers or indirect customs representatives above the threshold need authorised CBAM declarant status.
- CBAM certificates are purchased from national authorities and priced off the EU ETS auction price.
- If a carbon price was already paid in the country of origin and can be proven, that amount can be deducted.
Which aluminium goods are covered
European Commission guidance groups aluminium goods in scope under unwrought aluminium and a wider list of aluminium product codes. For most industrial importers, the headline point is that unwrought aluminium under CN 7601 is covered, alongside multiple semi-finished and finished aluminium categories.
| Category | Included CN codes | Commercial meaning |
|---|---|---|
| Unwrought aluminium | 7601 | Primary ingot and unwrought forms relevant to A7 and many remelters |
| Aluminium products | 7603–7608 | Powders, bars, profiles, wire, plates, sheets, strip, foil, tubes and pipes |
| Additional product groups | 7609, 7610, 7611, 7612, 7613, 7614, 7616 | Fittings, structures, tanks, drums, gas containers, cables and other aluminium articles |
| Explicit exclusions in guidance | 7615, 7602 00 | Certain household articles and aluminium scrap are excluded in the Commission guidance document |
What your supplier must provide
The Commission guidance for CBAM reporting requires much more than a mill cert. Importers need supplier information that links the shipment to the producing installation, the production route and the embedded emissions calculation.
| Data block | What is needed |
|---|---|
| Goods data | Quantity of each type of good, by installation, with the relevant CN code |
| Direct emissions | Actual direct embedded emissions per tonne of product |
| Indirect emissions | Relevant indirect emissions data where applicable under the methodology |
| Installation details | Identity, location, contact details and production route of the facility |
| Precursors | Upstream precursor quantities and embedded emissions where relevant |
| Carbon price paid | Evidence of carbon price due or paid in the country of origin, plus rebates or free allocation data where relevant |
| Aluminium-specific fields | Tonnes of scrap used and alloy content percentage as highlighted in the sector guidance |
| Methodology | How emissions were calculated, data quality approach and any justified use of defaults during the permitted period |
Importer action plan
Authorised declarant: what matters commercially
The Commission urges EU importers and indirect customs representatives to apply for authorised CBAM declarant status as soon as possible. German authority guidance goes further and warns companies to apply well in advance of exceeding the threshold so imports are not blocked. That makes supplier readiness a commercial issue: even if the metal price is competitive, missing emissions data can delay or derail imports.
Ask every non-EU aluminium supplier the same question: can you provide verified embedded-emissions data, installation details, product-level traceability and evidence of any carbon price paid in origin? If the answer is vague, the customs risk is yours.
How Tech Aluminum helps reduce CBAM friction
- Structured product documentation aligned to European procurement expectations
- CBAM-ready embedded-emissions data pack for covered aluminium shipments
- Direct commercial support through Noel Murphy in Ireland
- Shorter Mediterranean logistics routes versus many Asian supply chains
- Positioning around Egypt's lower-carbon power narrative, including hydroelectric advantages
Frequently asked questions
Does CBAM apply to aluminium ingots?
Yes. Unwrought aluminium under CN 7601 is explicitly included in the Commission guidance, which makes CBAM directly relevant for primary ingot and certain remelting supply chains.
What is the main threshold importers should watch?
The Commission states that importers or indirect customs representatives importing more than the single mass-based threshold of 50 tonnes of CBAM goods into the EU need to apply for authorised CBAM declarant status.
How are CBAM certificate costs linked to carbon prices?
CBAM certificate prices are based on the auction price of EU ETS allowances, expressed per tonne of CO2 emitted. The Commission indicates a quarterly average in 2026 and a weekly average from 2027 onward.
Can paid carbon costs in the origin country reduce the CBAM bill?
Yes, if the importer can prove that a carbon price was already paid during production in the country of origin, the corresponding amount can be deducted.
What is the biggest operational mistake buyers make?
Treating CBAM as a customs problem only. In practice it is also a supplier-data, procurement and documentation problem, so it should be built into sourcing decisions before purchase orders are placed.