Aluminium sits squarely inside CBAM, and for good reason: primary aluminium is one of the most electricity-intensive materials in trade, and its carbon footprint depends enormously on how that electricity was generated. For importers, that variability is exactly what makes the data work demanding.
Why aluminium is in scope
Aluminium was included as a core CBAM sector alongside iron and steel, cement, fertilisers, electricity, and hydrogen. The covered goods are defined by CN code in the regulation and span unwrought aluminium as well as a range of aluminium products and articles. As with steel, the in-scope line is drawn by code, so classification is the starting point — see CBAM CN codes for steel and aluminium.
Emissions vary more than almost any other sector
The embedded emissions of aluminium depend heavily on the electricity mix of the smelter that produced it. Metal from a hydropower-fed smelter and metal from a coal-grid smelter can differ by a factor of several times over. Two consequences for importers:
- A single generic emissions figure across all your aluminium is almost always wrong, and usually wrong in an expensive direction.
- Getting an accurate, supplier-specific number genuinely lowers your obligation — but only if you can collect and evidence it.
This rewards importers who do the supplier-data work properly and penalises those who fall back on conservative default values. The supplier emissions data process is where that value is won or lost.
The 50-tonne threshold
The 2025 Omnibus simplification set a 50-tonne annual mass-based de minimis per importer (per EORI). Aluminium products are lighter than steel, so some smaller importers may genuinely sit below it — but the moment cumulative imports cross 50 tonnes in a year, the whole year’s relevant imports fall into scope. If you import aluminium at any commercial scale, plan as if you are in scope. (Note: the de minimis does not apply to electricity or hydrogen.)
What to have in place
Your first annual CBAM declaration covering 2026 imports is due 30 September 2027 (full timeline). To get there calmly, build the file through the year:
- A shipment register linking invoices, customs declarations, and transport documents per covered consignment.
- The CN code and in-scope reasoning for each product.
- Smelter-level emissions data and production route — or a logged gap and the default value applied.
- A clean line from each declared figure back to its source document, ready for review.
That is the evidence archive your declarant or adviser signs off against.
How CarbonBorder Desk helps
We handle the operational layer: classifying your goods, chasing smelter and supplier data, tracking what is still missing, and keeping the evidence archive review-ready. We do not give legal or customs opinions and we do not file declarations — we make the file underneath the declaration correct and traceable. Most aluminium importers start with a pilot diagnostic on one import flow.