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EU carbon rules / Industry dossiers / Aluminium and non-ferrous metals

NACE C24.4–C24.5 4 duties 9 related regulations

Aluminium and non-ferrous metals

Indirect emissions (the electricity mix) are the main variable in CBAM cost; proof of green power is the competitive edge.

Reference only: this dossier is public compliance research, not legal advice, and draws no compliance conclusion. Whether a duty applies depends on product classification (CN code), role (importer, EU producer, downstream purchaser), cumulative volumes and Member State application; rely on the legal text and the competent authority.

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Duties

CCarbon: pricing, accounting, reporting, targets EEnvironment: pollution, waste, ecosystems, product attributes
Duty Trigger Evidence needed Timing Legal source
Carbon Calculate and declare embedded emissions per installation (including indirect emissions) Direct emissions and indirect electricity emissions are calculated together; for the indirect part, evidence of green electricity may be relied on for deduction. Imports of CBAM-covered products such as unwrought aluminium, aluminium sheet/profiles Direct emissions (including PFC/anode) plus indirect electricity emissions; proof of the electricity mix (PPAs, green certificates, sub-metering) Recording from 2026; annual declaration Reg (EU) 2023/956; indirect emissions rules in Reg (EU) 2025/2083
Carbon Establish an evidence chain for the electricity mix to claim indirect emissions Prove the source of electricity using PPAs, green certificates and sub-metering; transport emissions are not included. Electricity consumption in aluminium smelting/aluminium processing PPA contracts, renewable energy certificates, metering sub-meters (transport emissions not included) Ongoing during the definitive period Reg (EU) 2025/2083 (default country factor + deduction channel)
Carbon Prepare product-level ledgers for downstream aluminium products Establish aluminium content and emissions ledgers for products proposed for coverage, such as profiles and extrusions. Export of profiles, extrusions, metal parts for appliances, vehicle components, etc. Product-level aluminium content and embedded emissions; supplier data Proposed for 2028-01 〔under review〕 COM(2025) 989 final
Carbon ETS and indirect cost compensation for EU installations Electrolysis installations in the EU must report under the ETS and may apply for indirect cost compensation from the Member State. Electrolysis/smelting installations in the EU MRV report; application documents for the EEI Member State compensation scheme Ongoing Directive 2003/87/EC; EEI Guidelines
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Related regulations

Regulation Number Status Key date Applies to
CBAM Regulation Regulation (EU) 2023/956 In force 2026-01-01 Imports of iron and steel, aluminium, cement, fertilisers, electricity and hydrogen
CBAM Simplification Amendment Regulation (EU) 2025/2083 In force 2025-10 Imports of goods covered by CBAM
EU ETS Directive Directive 2003/87/EC In force 2003 Power, energy-intensive industry, aviation (within the EU/EEA)
State Aid Guidelines on Indirect Cost Compensation (EEI) Guidelines on EEI compensation In force continuous Electricity-intensive sectors (steel, aluminium, chemicals, paper, etc.)
CBAM Downstream Extension COM(2025) 989 final In progress proposed 2028-01 Steel/aluminium-intensive downstream products (fasteners, machinery parts, household appliances, etc.)
Critical Raw Materials Act CRMA Regulation (EU) 2024/1252 In force 2024 Companies extracting, processing and importing critical raw materials
Steel and Metals Action Plan COM(2025) 125 (19.3.2025) In force 2025-03-19 Steel and metals industry
Mining Waste Directive Directive 2006/21/EC In force 2006 Extractive industry and mining waste facility operators
Product Environmental Footprint (PEF) Method Recommendation Commission Recommendation (EU) 2021/2279 In force 2021 Companies issuing product environmental footprints and responding to customer data requests
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