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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