CBAM Advisory for Aluminium Exporters
The carbon math your EU buyer now has to defend.
Since 1 January 2026, EU importers of aluminium above the 50-tonne annual threshold must hold authorised CBAM declarant status and declare the embedded emissions of what they bring in. That obligation is theirs. It runs on data you supply. Suppliers who can hand over clear, verifiable figures make their customer's compliance straightforward. Suppliers who cannot are more likely to face questions during sourcing and onboarding.
The obligation is your customer's. The data is yours.
A 30-second check.
CBAM in 60 seconds
- Who is liable: the EU importer, or their indirect customs representative. Not you.
- What they need from you: installation-level embedded-emissions data for what you ship, documented well enough that a third-party verifier can follow it.
- What happens if you cannot supply it: your customer falls back on EU default values, and you lose the ability to show that your product is cleaner than the sector average.
- Why it is moving now: the first annual declaration covering 2026 imports is due 30 September 2027, and verification capacity is still being built out.
The financial leg lags the legal one deliberately. Emissions embedded in your 2026 shipments already count, but certificate sales only begin in February 2027 and the first declaration and surrender fall due on 30 September 2027. So 2026 is a cost to account for commercially now and to settle in cash later. The 2028 marker is a proposal, not law.
What's covered now, and what isn't yet.
Defaults are a ceiling, not a verdict.
Your EU customer can use your actual installation data, or fall back on an EU-published default value. The usual framing is that defaults are expensive. The more durable point is that defaults are undifferentiated. A default describes a country and a production route, not your plant. If you run a cleaner power mix, a higher recycled share or a more efficient process than the regional norm, a default erases that advantage and prices you alongside your least efficient competitor.
What your customer actually pays
From plant data to a defensible number.
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Data Collection:
production, fuel, process and precursor data, gathered against a defined checklist.
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Calculation:
data run through our CBAM Calculation Workbook, using actual or default methodology as applicable.
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Review:
figures checked against validation flags and source documentation.
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Embedded Emissions:
a Specific Embedded Emissions figure, per tonne and in total, for the reporting period.
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CBAM Output:
structured emissions data, ready to hand to your EU importer or verifier.
We built our own calculation workbook for aluminium because a CBAM figure is only useful if it can be traced. It separates your own production data from purchased precursors, applies actual-data or default logic across primary and recycled routes, flags gaps before a figure is treated as final, and outputs what an importer or verifier needs. It is a preparation tool: it does not replace third-party verification or your customer's own declaration obligations.
What we add around the calculation
- Scope and classification. What current rules mean for your specific products and CN codes.
- Documentation. The record of sources, assumptions and logic that makes a figure auditable.
- The free allocation adjustment. Often missed, and material to what your customer pays.
- Verification readiness. Structured so verification is a review, not a reconstruction.
- Regulatory tracking. What changes mean for figures already produced.
- Ongoing readiness. Data organised ahead of customer requests, not after them.
For the full regulatory picture, including the definitive regime, the August 2026 guidance series and the proposed downstream extension, see our CBAM explainer.
What your EU customer will ask you for
A one-page data request checklist covering the production, fuel, process and supplier data points a verifier expects to see.
Built for the supplier side of the obligation.
- Aluminium producers and exporters outside the EU, across Asia and the Gulf, shipping into the EU.
- Exporters whose EU customers have started asking for emissions data and who do not yet have a defensible answer.
- Private equity firms and portfolio operators with holdings carrying EU revenue exposure in covered sectors.
What the difference looks like.
Illustrative scenario, built with the Akiva StratIQ CBAM Aluminium Calculation Engine using sample data.
A secondary producer in India, remelting scrap into aluminium plates and sheets (CN 7606), ships 250 tonnes to the EU in a reporting period. Run through our calculation engine using sample installation and precursor data, the Specific Embedded Emissions figure comes out at 0.267 tCO2e per tonne, against the CBAM default of 4.126 tCO2e per tonne for this product from India: roughly 93.5% lower. Across the 250 tonnes, that is about 67 tCO2e of calculated embedded emissions.
CBAM default: 4.126 tCO2e/t
Calculated, from installation data: 0.267 tCO2e/t
About 93.5% lower than the default
The gap comes from the data behind the number, not from the arithmetic. A default is one figure applied to every producer on a given route; it describes a country and a process, not a specific plant. A calculated figure is only as good as the production, fuel and precursor data it is built from. This example shows the shape of that difference, not a promised outcome or a saving.
Who runs this practice
Our CBAM methodology is built and maintained by Sahana K, Associate, Carbon Markets & Strategy. She built the calculation workbook that underpins our engagements and tracks the regulation's technical development week to week.
She works alongside Ankur Bansal, Co-Founder, whose background is in deal execution, financial modelling and portfolio operations for private equity and investment banking clients. That combination matters here: CBAM is not only a compliance exercise. It is a cost that lands in contracts, sourcing decisions and valuations, and it is usually negotiated commercially before it is ever calculated technically.
Three ways to start.
CBAM Exposure Diagnostic
Which products fall in scope, what data you hold, where the gaps are, what your customers will ask for. Ends with a written summary.
Typical duration: 1 to 2 weeks from kickoff to written summary
Calculation Cycle
Full embedded-emissions calculation for a reporting period, ending in a structured output package for your importer or verifier.
Typical duration: 3 to 5 weeks for a single product and facility; 8 to 12 weeks for multiple products, facilities or rounds of data clarification
Ongoing Retainer
Refreshed calculations, regulatory tracking against figures already produced, and customer data requests handled as they arrive.
Typical commitment: Minimum six-month term, reviewed quarterly
FAQ
What is CBAM, in simple terms?
An EU mechanism that prices the carbon emitted in producing certain imported goods, so imports and EU-made goods face a comparable carbon cost. It currently covers cement, iron and steel, aluminium, fertilisers, electricity and hydrogen.
Who is responsible for declarations and certificates?
The EU importer, or their indirect customs representative. Your role is to provide accurate, documented emissions data. Your exposure is commercial rather than regulatory: it shows up in sourcing decisions and contract terms, not in a filing you make yourself.
What counts as embedded emissions for aluminium?
The greenhouse gases generated in producing a given quantity of aluminium. Under current rules this means direct emissions only: CO2 from fuel combustion and from the production process itself, including anode consumption in primary smelting, plus process gases such as PFCs. Cement and fertilisers include indirect emissions; aluminium currently does not.
Is all aluminium covered?
CBAM covers unwrought aluminium and most semi-finished and finished aluminium products in Chapter 76 of the Combined Nomenclature: CN 7601, 7603 to 7614, and 7616. The exceptions are aluminium waste and scrap (7602) and table, kitchen and household articles (7615). Goods classified in other chapters, such as vehicle parts, are not covered even when they are made largely of aluminium. Classification should be checked CN code by CN code.
We export components, not unwrought metal. Are we affected?
It depends on how your goods are classified. Finished aluminium articles in Chapter 76, such as structures, containers, cables and fasteners, are mostly in scope today. Components classified in other chapters, such as vehicle or machinery parts, generally are not. A proposal to extend CBAM to downstream steel and aluminium goods passed a Council position in June 2026 and a European Parliament position in September 2026, with an earliest proposed effect of 1 January 2028. It is not yet law and the final product list is still being negotiated. Check your CN codes against current scope now, and track the extension.
When do the costs actually start?
The definitive regime began on 1 January 2026, so emissions embedded in 2026 imports already count. Certificate sales begin in February 2027 and the first annual declaration and surrender fall due on 30 September 2027 for the 2026 reporting year. Certificates are priced against EU ETS allowance prices, with each 2026 quarterly price calculated by the Commission in the first calendar week after the quarter ends.
What is the free allocation adjustment?
The number of certificates your customer surrenders is reduced to reflect free allocation still granted to EU producers under the EU ETS. That adjustment tightens as ETS free allocation phases out through 2034. It is often missed and it changes the commercial picture behind any CBAM cost conversation with an EU buyer.
What if we don't have complete actual data yet?
Your customer can use EU default values. A default describes a country and a production route rather than your installation, so it removes any advantage a cleaner plant could otherwise demonstrate. Default values are themselves subject to revision: the Commission corrected them in 2026 through Implementing Regulation (EU) 2026/1740, applied retroactively from 1 January 2026.
Do we need a third-party verifier, and can you be it?
CBAM requires verification by an independent accredited body, and we are not one. It would also not be appropriate for the same party to prepare and verify a figure. We prepare your data so verification is straightforward. Worth noting that verifier access to the CBAM Registry only opened on 1 September 2026, so accredited capacity is limited and early booking matters.
Does your workbook replace verification?
No. It prepares and structures your figures. It does not replace third-party verification or your customer's declaration and registry obligations.
Has the Commission published aluminium-specific guidance?
Yes. On 14 August 2026 it published a series of ten guidance documents for non-EU operators, including Guidance No. 5e on aluminium, followed on 24 August 2026 by separate guidance on verification and accreditation.
How do you handle our production data?
Emissions data is commercially sensitive and we treat it that way. Data stays within the systems we agree with you, it is not shared beyond the engagement, and it is not put through third-party AI tools.
Contact and enquiry
Ask a CBAM question
Request a CBAM exposure review
Prefer email? ankur@akivastratiq.com
Sources
Sourced from European Commission, Taxation and Customs Union guidance, and Council and Parliament positions on procedure 2025/0419(COD). Full references in our CBAM explainer.