Aluminium CBAM: Direct Emissions Guide

Aluminium is one of the six CBAM-covered product categories. But there's a critical distinction that many importers get wrong: aluminium is an Annex II sector, which means only direct emissions are chargeable for CBAM certificate purposes. This guide covers what that means for your reporting and your costs.

"Under Regulation 2023/956 Article 7(1), indirect emissions for Annex II sectors — aluminium included — are reported for transparency but excluded from the CBAM chargeable calculation." — European Commission CBAM Regulation

Why Aluminium Importers Need to Pay Attention

With the EU importing roughly 4.5 million tonnes of primary aluminium each year, even small reporting errors add up. But the real risk is misunderstanding what counts toward your CBAM bill. Many importers assume their electricity-intensive smelting process drives their CBAM cost. Under Annex II, it does not.

Your CBAM liability for aluminium depends on direct emissions only — the emissions from the smelting process itself, not the power used to run it. Get this wrong and you could overpay by thousands or under-report and face penalties.

CN Codes for Aluminium Products

Aluminium products fall under CN Chapter 76:

CN Code	Product Description
7601	Unwrought aluminium
7602	Aluminium waste and scrap
7603	Aluminium powders and flakes
7604	Aluminium bars, rods and profiles
7605	Aluminium wire
7606	Aluminium plates, sheets and strip
7607	Aluminium foil
7608	Aluminium tubes and pipes
7609	Aluminium tube fittings
7610	Aluminium structures
7611–7616	Other aluminium articles

Most aluminium CBAM reporting falls under CN 7601 (unwrought) and CN 7604–7606 (semi-finished products).

The Annex II Distinction: Direct vs Indirect Emissions

This is the single most important concept for aluminium CBAM reporting. Regulation 2023/956 divides products into two categories:

Category	Direct Emissions	Indirect Emissions (Electricity)
Annex I sectors (steel, cement, fertilisers)	Chargeable	Chargeable
Annex II sectors (aluminium, chemicals, hydrogen)	Chargeable	Reported only, not charged

For aluminium importers, this means:

• Your CBAM cost is based on direct emissions only — what comes out of the smelter's own process
• Indirect emissions from electricity must still be reported in your quarterly declaration, but they do not add to your certificate cost
• But there's a catch coming in 2027 — the scope may expand, so keep tracking both

Direct Emissions by Smelting Technology

Aluminium smelting technology directly determines your direct emissions. The three main technologies have significantly different emission factors:

Smelting Technology	Direct Factor (tCO₂e/t)	Common Regions
Pre-bake (Centre Worked Pre-Bake / CWPB)	1.4–1.7	Global standard — China, Canada, UAE
Søderberg (Horizontal Stud Søderberg / HSS)	1.7–2.2	Older plants — Russia, India
Inert Anode	<0.5	Emerging technology — pilot stage

Pre-bake technology is the global standard and produces lower direct emissions per tonne. Søderberg technology, found in older smelters, produces higher direct emissions due to less efficient anode consumption. Inert anode technology — still in development — would dramatically reduce direct emissions if commercialised.

Default Direct Emission Factors by Country

Every country's smelting fleet has a different mix of technologies, which means every country has a different direct emission factor. Here are the IR 2025/2621 default values:

Country	Direct (tCO₂e/t)	Dominant Technology	CBAM Cost (per tonne, at €75/tCO₂e)
China	1.672	Pre-bake	€125.40
India	1.583	Pre-bake	€118.73
Russia	1.548	Søderberg / Pre-bake	€116.10
Canada	1.514	Pre-bake (hydro-powered)	€113.55
UAE	1.521	Pre-bake	€114.08
Norway	1.428	Pre-bake (hydro-powered)	€107.10

Notice that the cost difference between the highest (China, €125/t) and lowest (Norway, €107/t) is only about €18 per tonne — roughly a 13% spread. This is very different from the misleading 60x spread people cite for total emissions.

What About Electricity and Indirect Emissions?

Aluminium smelting uses massive amounts of electricity (14,000–16,000 kWh per tonne). Coal-fired smelters can produce indirect emissions of 8–12 tCO₂e/t, while hydro-powered smelters are near zero. That 60x difference is real — but it does not affect your CBAM certificate cost.

Energy Source	Indirect Factor (tCO₂e/t)	Reported?	Chargeable?
Coal-fired grid	~8.0–12.0	Yes	No (Annex II)
Natural gas	~4.0–6.0	Yes	No (Annex II)
Hydroelectric	~0.1–0.5	Yes	No (Annex II)
Nuclear	~0.0–0.1	Yes	No (Annex II)
Renewable	~0.0–0.2	Yes	No (Annex II)

Under the current rules (2026), electricity source matters for your report but not your bill. This might change when the CBAM scope review happens in 2027–2028.

Data Requirements for Aluminium

For Each Product

• Specific CN code (8-digit)
• Quantity imported (tonnes)
• Smelting technology (pre-bake, Søderberg, inert anode) — this determines your direct factor
• Country of origin
• Supplier verification (if using actual values)

Documentation

• Smelter technology declarations
• Anode consumption records
• Supplier emission declarations
• Verification certificates (for actual values)

Common Aluminium-Specific Challenges

Confusing direct vs indirect — The most common compliance error is reporting indirect (electricity) emissions as chargeable and overpaying CBAM certificates. Always check: aluminium is Annex II, direct only.

Using the wrong technology factor — Each smelting technology has a different direct emission factor. Using a generic factor can lead to inaccurate reporting.

Country-specific factors vary less than you think — Unlike the 60x spread in total emissions, direct emission factors vary by only 13% between countries. The cost saving comes from accurate reporting, not from choosing a low-indirect country.

Upcoming scope changes — The European Commission is reviewing Annex II treatment. Indirect emissions may become chargeable after 2027. Track both now to avoid a compliance gap later.

FAQ

If I switch to hydro power, does my CBAM cost go down? Not under current rules. Aluminium is Annex II, so only direct emissions are chargeable. Switching electricity source reduces your reported total emissions but not your CBAM certificate cost. This may change in the 2027 scope review.

Can I use the EU average emission factor for aluminium? No. Aluminium factors are country-specific and technology-specific. Using incorrect factors will result in inaccurate reports.

How do I report aluminium imported from multiple countries? Report each shipment separately with its country-specific and technology-specific factors. Do not average across countries.

Does recycled aluminium have different reporting requirements? Secondary (recycled) aluminium has lower direct emissions. Different default factors apply.

Simplify Your Aluminium CBAM Reporting

Aluminium's Annex II treatment makes it unique among CBAM-covered sectors. CbamTrack automatically applies the correct country-specific and technology-specific direct emission factors, so you never confuse direct with indirect. Try it free or compare alternatives.