CBAM for Aluminium: Scope, Emissions and Cost Guide

Which aluminium goods are covered by CBAM?

The legal basis of the product scope is Annex I of Regulation (EU) 2023/956. The definitive methodology treats aluminium in two aggregated goods categories: (A) Unwrought aluminium — CN 7601; (B) Aluminium products — powders and flakes (7603), bars and profiles (7604), wire (7605), plates, sheets and strip (7606), foil (7607), tubes and fittings (7608, 7609 00 00), structures (7610), containers and casks (7611 00 00, 7612, 7613 00 00), stranded wire and cables (7614) and other articles of aluminium (7616).

Two important exclusions (Guidance No. 5e): CN 7602 00 — aluminium waste and scrap — is NOT included as a CBAM aluminium good, and household articles under CN 7615 are excluded from the aluminium goods list. Do not over-generalise: your product’s CN code is decisive.

The aluminium value chain: two routes, two goods categories

Not every installation contains every step — some only melt, some only form. The methodology’s core distinction is between the goods categories: UNWROUGHT ALUMINIUM (ingots, blocks, billets, slabs and similar) and the ALUMINIUM PRODUCTS made from it follow different CBAM rules (sections 6 and 7 below).

Primary aluminium: the electrolysis route

On the primary route, unwrought aluminium is produced by electrolytic smelting of alumina using carbon anodes. The main DIRECT emissions counted where applicable: CO₂ from the consumption of carbon electrodes/electrode paste, CO₂ from fuels, relevant flue-gas treatment sources and — the aluminium-specific item — PFC emissions from anode effects: CF₄ and C₂F₆.

Guidance No. 5e discusses two anode systems: pre-baked anodes and Søderberg anode paste, self-baked in the cell. These describe the installation’s anode technology; they are NOT separate CBAM benchmark routes. At benchmark level, the relevant high-level route indicator, where applicable, is K = primary aluminium.

Secondary aluminium: the recycling route

Per Guidance No. 5e, secondary aluminium is mainly produced from aluminium scrap. The critical rule: scrap — whether pre-consumer or post-consumer — is treated as a RAW MATERIAL under this CBAM methodology and carries ZERO embedded emissions. Careful: this does not mean “recycled aluminium has zero CBAM emissions” — it is the SCRAP INPUT that has zero embedded emissions.

The secondary production process itself still generates direct emissions: scrap pre-treatment, drying, de-coating/de-oiling where relevant, melting furnaces, fuels, casting and relevant treatment processes. Guidance No. 5e also states explicitly: there are NO PFC emissions from the secondary aluminium process. At benchmark level the route indicator, where applicable, is L = secondary aluminium.

Electricity: the counterintuitive part

Primary aluminium production is electricity-intensive — electrolysis electricity is often the largest item in the sector’s carbon footprint. And yet: for aluminium CBAM goods listed in Annex II of Regulation (EU) 2023/956, ONLY direct emissions are taken into account in the definitive CBAM embedded-emissions calculation (Art. 7(1)). Indirect emissions from electricity consumption are therefore currently NOT included in CBAM embedded emissions for those aluminium goods — Guidance No. 5e confirms this explicitly.

This does not make electricity operationally ignorable. Electricity data remains highly relevant for installation monitoring, internal decarbonisation, LCA, EPD, PCF, other reporting frameworks and possible future regulatory changes. Do not read this as “electricity does not matter”; read it as “it does not enter today’s CBAM certificate calculation for these goods”.

Unwrought aluminium: a simple good

Guidance No. 5e defines unwrought aluminium as a SIMPLE good. For PRIMARY unwrought aluminium, raw materials such as alumina, carbon anodes/anode paste, cryolite and relevant additives are treated as raw materials rather than CBAM precursors for this purpose — their upstream embedded emissions are not added as precursor embedded emissions. Read carefully: this is not a claim that these materials have zero environmental impact; it means zero embedded emissions for this CBAM precursor treatment.

Aluminium products: complex goods

Downstream aluminium products are COMPLEX goods: they include the embedded emissions carried by the precursor UNWROUGHT ALUMINIUM. Where data is known, primary and secondary unwrought aluminium must be treated separately, because their embedded emissions differ. Other aluminium products used as inputs may also be relevant precursors where applicable.

Primary vs secondary: what actually changes?

This is a technical comparison; neither route is declared “always superior” economically or environmentally in every case.

Default values and production route

Default values depend on the country, the CN code and — where represented in the official data — the production route. For aluminium, the route distinction runs along the primary/secondary axis where the data supports it.

Sample rows for Türkiye (from the live dataset):

Dataset: IR (EU) 2025/2621 + IR (EU) 2026/1740 · updated: 2026-08-10

In the current dataset, Türkiye’s aluminium default-value rows are published with route K (primary); the value applicable after the mark-up — and your own code — can be checked in the lookup tool.

Free allocation adjustment: routes K and L

In the benchmark dataset of Implementing Regulation (EU) 2025/2620, the aluminium route indicators, where they apply, are K = primary aluminium and L = secondary aluminium — and their benchmark values differ markedly (for 7601, Column B: K = 1.423 tCO₂e/t vs L = 0.091 tCO₂e/t, read dynamically from the dataset). K/L do not define the whole embedded-emissions methodology; they are benchmark/route indicators used in the relevant calculation context.

Our calculator applies the adjustment through the shared engine: benchmark × CBAM factor × CSCF. Where the route is unknown, the engine selects the conservative (lower) benchmark — and since the K/L gap is large in aluminium, correct route information changes the result markedly.

Illustrative cost example: Türkiye, CN 7601, 500 tonnes, 2026

Every value comes at build time from the SAME shared calculation engine used by the cost calculator, the steel guide and the comparison pages — nothing typed by hand. Scenario: declaring with the default value, route K (primary).

Illustrative estimate — not an official CBAM declaration. As the current official dataset carries no secondary-route (L) default-value row for Türkiye, no default-based primary-vs-secondary cost comparison is fabricated here; see section 10 for the official benchmark values of the two routes.

Default value or actual emissions for aluminium?

Actual data can differ significantly from default values; in aluminium the main drivers are the primary/secondary route, the installation’s actual fuel and process emissions, PFC performance in primary smelting (anode-effect management), the precursor mix in downstream products (share of primary vs secondary unwrought aluminium) and installation-specific production data.

A critical caution: low-carbon electricity does NOT automatically reduce today’s aluminium CBAM certificate cost — because indirect electricity emissions are currently excluded for these Annex II aluminium goods. If your electricity is green, today that shows up in other frameworks (EPD/PCF, corporate reporting), not in the CBAM bill.

What data should an aluminium producer prepare?

Verification readiness

An aluminium producer aiming to declare with actual data needs the items above traceable down to source evidence before contacting a verifier — especially the route distinction, scrap input records and PFC monitoring on the primary route. The full process is covered on a dedicated page, and you can gauge your readiness in two minutes.

Common aluminium CBAM mistakes

• Assuming indirect electricity emissions are currently priced in aluminium CBAM.
• Concluding the opposite — that electricity data is therefore irrelevant; it matters for monitoring, EPD/PCF and future rules.
• Reading the zero embedded emissions of scrap input as “zero-emission secondary aluminium”.
• Failing to distinguish primary and secondary precursor aluminium in downstream products where data is known.
• Forgetting PFC (CF₄, C₂F₆) emissions in primary smelting.
• Adding upstream alumina emissions as precursor emissions without checking the CBAM methodology.
• Using EPD recycled-content methodology as if it were CBAM scrap methodology.
• Automatically including cutting, welding and finishing inside the aluminium-product system boundary.
• Using the wrong K/L benchmark route.
• Assuming actual emissions always reduce CBAM exposure.

Frequently asked

Free CBAM tools for aluminium manufacturers

All four are free, no registration required:

Related guides: Default vs Actual Emissions · How to Calculate CBAM Cost · The Verification Process