Aluminium and non-ferrous metals · Checklist

CBAM Regulation Regulation (EU) 2023/956 In force Key date:2026-01-01

• Obtain the status of authorised CBAM declarant Registration as an authorised CBAM declarant with the competent authority of a Member State is required before import. Trigger:Importing goods covered by CBAM (steel, aluminium, cement, fertilisers, hydrogen, electricity) · Evidence:Authorised declarant decision, registration details · Timing:Before import
• Submit the annual CBAM declaration Declare the quantity of imported goods, embedded emissions and carbon price paid. Trigger:Each quarter/year in which goods are imported as an authorised declarant · Evidence:CBAM declaration, supplier emissions data, verification documents · Timing:After each quarter; annual declaration by 30 September
• Purchase and surrender CBAM certificates Purchase and surrender CBAM certificates according to embedded emissions; the price is linked to the weekly average EUA price. Trigger:Embedded emissions confirmed in the annual declaration · Evidence:Certificate holding and surrender records, cancellation certificate · Timing:Surrendered after the annual declaration
• Use actual emissions data rather than default values Use of default values is restricted; verified actual emissions data from the production installation must be obtained. Trigger:Importers wishing to reduce certificate costs · Evidence:Verified emissions data provided by the producer, production route description · Timing:From the definitive period starting in 2026

CBAM Simplification Amendment Regulation (EU) 2025/2083 In force Key date:2025-10

• Apply the 50 t de minimis exemption An exemption applies where the total net weight of CBAM goods imported by a single importer in a calendar year does not exceed 50 t. Trigger:Imports of steel, aluminium, cement and fertilisers (aggregated) · Evidence:Import ledger, annual total net weight · Timing:After the 2024/2025 simplification enters into force
• Declare under the simplified rules and use default values The delegated act relaxes certain declaration fields and the use of default values. Trigger:CBAM declarants · Evidence:Simplified declaration records · Timing:After 2025/2083 enters into force

EU ETS Directive Directive 2003/87/EC In force Key date:2003

• Obtain a greenhouse gas emissions permit Before operating an installation covered by the ETS, obtain a GHG emissions permit from the competent authority of the Member State and draw up a monitoring plan. Trigger:Operating an activity listed in Annex I to the ETS Directive (power generation, energy-intensive industry, aviation, etc.) · Evidence:GHG emissions permit, monitoring plan · Timing:Obtained before operation; valid on a continuing basis
• Monitor and report annual emissions Calculate in accordance with the MRR and submit an annual emissions report after verification by an accredited verifier. Trigger:Each operating year in which an emissions permit is held · Evidence:Monitoring methodology document, verified annual emissions report (AVR) · Timing:Submitted by 31 March of the following year
• Surrender a sufficient number of allowances Surrender EUAs equal to annual emissions; in case of a shortfall, a penalty of €100/t applies and the allowances must still be surrendered. Trigger:Annual emissions verified and confirmed · Evidence:Allowance account surrender records, cancellation certificate · Timing:By 30 September of the following year

State Aid Guidelines on Indirect Cost Compensation (EEI) Guidelines on EEI compensation In force Key date:continuous

• Design indirect cost compensation in line with the EEI Guidelines Member State compensation for indirect electricity costs must comply with the State aid guidelines. Trigger:A Member State establishes an electricity indirect cost compensation scheme · Evidence:Member State aid notification, European Commission approval · Timing:2025–2030

CBAM Downstream Extension COM(2025) 989 final In progress Key date:proposed 2028-01

• Prepare supply chain emissions data for downstream products Around 180 steel- and aluminium-intensive downstream products are planned for inclusion; upstream emissions data must be obtained in advance. Trigger:Exporting fasteners, steel wire, springs, household appliances, machinery parts, etc. to the EU · Evidence:Supplier carbon footprint data, bill of materials (BOM) · Timing:Planned from 2028 [under review]

Critical Raw Materials Act CRMA Regulation (EU) 2024/1252 In force Key date:2024

• Due diligence and certification in critical raw material supply chains Carry out risk management and certification for critical raw material supply chains. Trigger:Companies using/processing critical raw materials · Evidence:Supply chain audits, certification evidence · Timing:Phased after 2024/1252 enters into force

Steel and Metals Action Plan COM(2025) 125 (19.3.2025) In force Key date:2025-03-19

• Monitor trade protection and CBAM expansion for steel and metals The action plan includes import monitoring, protection of primary steel and downstream expansion of CBAM. Trigger:Steel and metals producers/exporters · Evidence:Policy tracking, impact assessment · Timing:From 2025

Mining Waste Directive Directive 2006/21/EC In force Key date:2006

• Prepare an extractive waste management plan Prevent or minimise waste generation and ensure its safe disposal. Trigger:Generating or managing extractive waste · Evidence:Waste management plan, waste classification and ledger · Timing:Before operation and on a continuing basis
• Apply major accident prevention measures at Category A facilities Waste facilities classified as Category A by the competent authority must establish a major accident prevention policy and emergency procedures. Trigger:Facility classified as Category A · Evidence:Major accident prevention policy, emergency plan and drill records · Timing:Before operation

Product Environmental Footprint (PEF) Method Recommendation Commission Recommendation (EU) 2021/2279 In force Key date:2021

• Use PEF / OEF methods to measure and communicate environmental performance When voluntarily measuring or communicating life-cycle environmental performance, environmental footprint methods should be used. Trigger:Voluntary measurement or communication of life-cycle environmental performance · Evidence:PEF / OEF study report · Timing:Ongoing
• Use category rules where a PEFCR exists Where a PEFCR exists for a product category, the environmental footprint must be calculated according to the category rules. Trigger:A PEFCR exists for the product category · Evidence:PEFCR applicability statement and calculation documents · Timing:Ongoing
• Complete verification before disclosure to third parties PEF / OEF studies disclosed to third parties must be verified in accordance with the methodological requirements. Trigger:Disclosing a PEF / OEF study to third parties · Evidence:Verification report · Timing:Before disclosure