INSIGHTS

CBAM for aluminium exporters: what the definitive regime actually requires

CBAM has been in its definitive regime since January 2026, but the parts that matter most to exporters are the ones that have not happened yet. This is where the regime stands as of September 2026, what it asks of producers outside the EU, and which pieces are still being negotiated.

Reviewed and current as of 6 October 2026.

Transitional, definitive, and what comes next

Transitional period, 2023 to 2025. Reporting obligations only, no financial payments, while systems and methodology were tested.

Definitive regime, from 1 January 2026. CBAM applies in full. EU importers above the 50-tonne annual threshold must hold authorised CBAM declarant status and declare embedded emissions. The threshold is assessed on cumulative annual imports at importer level and applies to all covered goods except hydrogen and electricity. Importers who applied for authorisation by 31 March 2026 were allowed to continue importing while a decision was pending.

Proposed extension, earliest 1 January 2028. Covered in section 5 below. Not yet law.

The legal obligation started in 2026. The cash lands in 2027.

This is the single most commonly misstated part of CBAM, and getting it right changes how you plan.

The definitive regime began on 1 January 2026, so emissions embedded in goods imported during 2026 already count. But certificate sales only begin in February 2027, and the first annual CBAM declaration and certificate surrender fall due on 30 September 2027, covering the 2026 reporting year.

Certificates are priced against EU ETS allowance prices. Each 2026 quarterly price is calculated by the Commission in the first calendar week after the quarter ends, based on publicly available EU ETS auction information.

For an exporter, the practical consequence is that 2026 is a cost your customer is accruing commercially now and settling in cash later. The data they need from you covers shipments already made. That is why data requests began arriving well before any money changed hands.

Embedded emissions for aluminium

Embedded emissions are the greenhouse gases generated in producing a given quantity of a good.

Under current rules, aluminium's CBAM obligation is based on 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. This differs by sector. Cement and fertilisers include indirect emissions from purchased electricity; aluminium and iron and steel currently do not.

That distinction matters commercially. A smelter running on low-carbon grid power gets no benefit for it under the current aluminium methodology, since purchased electricity sits outside the calculated scope. Notably, the European aluminium industry's own trade body has consistently opposed adding indirect emissions to CBAM, arguing it would weaken European producers' competitiveness and push production toward more carbon-intensive regions rather than cut global emissions.

Like other elements of CBAM's methodology, this scope is set out in the regulation's sector annex and remains subject to regulatory updates.

Actual data versus default values

A producer can report actual, installation-level emissions, or the EU importer can fall back on an EU-published default value where actual data is not available.

Defaults are usually described as expensive. The more durable objection is that they are undifferentiated: a default describes a country and a production route, not a specific installation. A plant with a cleaner power mix, a higher recycled share or a better process than the regional norm is priced identically to its least efficient competitor.

Default values are also revised. The Commission issued corrected default values during 2026 through implementing regulation, so any analysis resting on a specific default figure should be checked against the current published set rather than an earlier one.

The free allocation adjustment

Frequently overlooked, and material to what an importer actually pays.

The number of CBAM certificates an importer must surrender is reduced to reflect the free allocation still granted to EU producers under the EU ETS. That adjustment tightens progressively as ETS free allocation phases out through 2034. One of the Commission's four general guidance documents deals specifically with calculating it.

For an exporter negotiating with an EU buyer, this is worth understanding: the headline carbon cost and the net cost your customer bears are not the same number, and a buyer using the headline figure in a price conversation is overstating their own exposure.

The bottleneck nobody priced in

CBAM requires verification by an independent accredited body. Two dates explain why this is currently a constraint rather than a formality.

The Commission published guidance on CBAM verification and accreditation on 24 August 2026, aimed at verifiers and National Accreditation Bodies. Verifier access to the CBAM Registry opened on 1 September 2026.

So the accreditation infrastructure became operational roughly twelve months before the first declaration deadline of 30 September 2027. Accredited verifier capacity is being built out against a fixed deadline and a large population of importers.

The practical implication for a producer is that the value of having your data already structured is not only that verification goes faster. It is that you can book verification early, when capacity exists.

The development most likely to catch exporters out

This is the part of CBAM most likely to affect producers who currently believe they are outside scope.

In December 2025 the Commission proposed extending CBAM beyond basic materials to downstream products with high steel or aluminium content. The Council agreed its negotiating position on 12 June 2026. The European Parliament adopted its position on 15 September 2026, backing a wider list that reportedly runs to several hundred product lines and includes finished and semi-finished goods such as fasteners, wire, springs and household articles, alongside strengthened anti-circumvention provisions.

The three positions differ materially in scope. The Commission's original proposal covered roughly 180 additional products, the Council's position around 200, and Parliament's reportedly considerably more.

Current CBAM scope for aluminium products Unwrought and semi-finished aluminium is in scope now. Most finished aluminium articles in Chapter 76 are also in scope now, except household articles under CN 7615, so check your CN code. Other goods containing aluminium, such as vehicle parts, are not in scope today. A proposed extension could bring some into scope from 1 January 2028; it is not yet law. Unwrought and semi-finished aluminium Ingots, bars, profiles, wire, plates, foil, tubes and fittings In scope now Finished aluminium articles Structures, containers, cables and other articles (not 7615) In scope: check CN code Other goods containing aluminium Such as vehicle parts. Proposed extension could add some from 2028 Not in scope today Current CBAM scope for aluminium products Unwrought and semi-finished aluminium is in scope now. Most finished aluminium articles in Chapter 76 are also in scope now, except household articles under CN 7615, so check your CN code. Other goods containing aluminium, such as vehicle parts, are not in scope today. A proposed extension could bring some into scope from 1 January 2028; it is not yet law. Unwrought and semi-finished aluminium Ingots, bars, profiles, wire, plates, foil, tubes and fittings In scope now Finished aluminium articles Structures, containers, cables and other articles (not 7615) In scope: check CN code Other goods containing aluminium Such as vehicle parts. Proposed extension could add some from 2028 Not in scope today

Three things to be precise about:

It is not law. The final scope will be settled in negotiation between Parliament and the Council.

The existing product scope stays in force until an amending regulation is enacted.

The earliest proposed effect is 1 January 2028.

Most finished aluminium articles in Chapter 76 are already in scope. The extension matters most if you export goods classified in other chapters that contain significant aluminium, such as components and assemblies. Check your CN codes against current scope, and track the file.

What the Commission has actually issued

On 14 August 2026 the Commission published a series of ten guidance documents for non-EU operators in the definitive period: four general documents covering CBAM concepts, a quick guide for non-EU operators, calculation of embedded emissions, and calculation of the free allocation adjustment, plus six sector-specific guides. Guidance No. 5e covers aluminium. Separate guidance on verification and accreditation followed on 24 August 2026.

The pace of technical publication through 2026 is itself informative. CBAM's detail is still being actively developed, which is why we treat current requirements as current rather than final, and why figures produced under one version of the methodology are worth revisiting.

A short checklist for exporters

  1. Establish which of your products fall within current scope, CN code by CN code.
  2. Find out whether your EU customers have registered as authorised CBAM declarants and what data format they expect.
  3. Determine whether you can produce installation-level direct emissions data, or whether your customer will default.
  4. Build the documentation alongside the calculation, not afterward. A figure without a traceable basis will not survive verification.
  5. Book verification early rather than close to the deadline.
  6. Track the downstream extension if you ship goods classified outside the aluminium chapter.

We work with aluminium producers and exporters on exactly this: embedded-emissions calculation, documentation, and verification readiness. If you want a scoped first look at where you stand, our CBAM advisory page sets out how that works.

Sources

European Commission, Taxation and Customs Union

Council and Parliament, downstream scope extension, procedure 2025/0419(COD)

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