Does CBAM apply to my product if my customer ships through a non-EU port?

CBAM applies on EU customs entry. The shipping route does not change scope. CN Chapter 76 covers unwrought aluminium and primary processed products; verify your specific code against Annex I of Regulation (EU) 2023/956.

What CN codes are covered for aluminium under CBAM?

CBAM covers goods under Chapter 76 of the EU Combined Nomenclature, including unwrought aluminium (7601), bars/rods (7604), plates and sheets (7606), and tubes (7608). Selected downstream products under 7616 are also included from 2026. Verify your exact CN code against Annex I of Regulation (EU) 2023/956.

How does CBAM calculate emissions if I do not submit verified data?

Under Regulation (EU) 2025/2621, importers without verified actual emissions data must use country × product default values published by the European Commission. Default values include a statutory markup: 10% in 2026, 20% in 2027, and 30% from 2028 onwards. Submitting verified actual data from your installation, verified by an accredited verifier, almost always produces a lower CBAM liability than the default.

When is the first CBAM declaration due for aluminium?

The first annual CBAM declaration is due 30 September 2027, covering imports made during calendar year 2026. Quarterly transitional reports continued through Q4 2025. From 1 January 2026, only the EU importer filing with the EU Registry may import covered aluminium goods.

How are primary and secondary aluminium routes treated differently?

Annex IV of the CBAM Regulation distinguishes primary aluminium (produced via electrolysis from alumina) and secondary aluminium (recycled). EU benchmarks under Regulation (EU) 2025/2620 set primary at 1.423 tCO₂e/t and secondary at 0.091 tCO₂e/t — a 15× difference. Mixed-source producers must declare per-batch attribution.

Why is electricity sourcing critical for primary aluminium?

Primary aluminium production via electrolysis is highly electricity-intensive — typically 13-15 MWh per tonne. Grid carbon intensity drives the indirect emissions component. Producers using hydroelectric, nuclear, or renewable sources have substantially lower embedded emissions and lower CBAM liability than those on coal-heavy grids.

Are aluminium scrap inputs treated as zero-emission?

Recycled aluminium scrap carries the secondary route benchmark of 0.091 tCO₂e/t — not zero, but substantially below primary. Producers claiming secondary-route status must document scrap origin, processing, and chain of custody per Annex IV requirements.

What happens if my CBAM XML fails verification?

The EU importer filing with the EU Registry will reject the XML and request corrections. Common rejection reasons include CN code mismatches, missing primary vs secondary route declaration, electrolysis power source missing for primary aluminium, default values exceeding the 20% threshold imposed from July 2024, and missing Annex IV calculation method declarations. Carbon Mandate's free XML scan checks file structure against CBAM schema requirements for aluminium before transmission.

CN 76 · ALUMINIUM

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Default-value markup scheduleArt. 5(3) Reg (EU) 2025/2621

2026 default markupCurrent+10%above verified default

2027 default markup+20%above verified default

2028 default markup+30%above verified default

FREE EXPOSURE INSTRUMENT · ALUMINIUM

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Aluminium

In scope

Primary and downstream aluminium goods. Default benchmark applies until verified actuals.

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Emission data · Validation

The published Annex I defaults for this sector, and the rules every XML is checked against before release.

Annex I default emission values

Country	Route	tCO₂e/t	CN
Turkey	PRIMARY	1.70	7601
India	PRIMARY	1.87	7601
China	PRIMARY	3.00	7601
South Korea	SECONDARY	0.36	7601
Ukraine	SECONDARY	0.36	7601
Brazil	PRIMARY	1.70	7601
Egypt	PRIMARY	1.87	7601
Indonesia	PRIMARY	1.70	7601
Other	PRIMARY	2.20	7601

Source: Reg (EU) 2025/2621 Annex I · PDF-verified · carbonmandate.com

Validation rules applied to this sector

AL-01Declared CN code falls outside chapters 7601–7616 (aluminium) — verifier will reject.error

AL-02Root reportingPeriod element missing — required for every declaration.error

AL-03Producer EORI does not match member-state format pattern.warning

AL-04Total embedded emissions cannot be zero for declared production volume.error

AL-05calculationMethodId missing — Annex IV requires explicit declaration of method used.error

AL-06Primary (Bayer) route declared but aluminaConsumption missing — Annex IV requires alumina input attribution.warning

25 rules total · full rule set applied on every scan

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Regulatory calendar

The dates that move the liability.

Every deadline below is fixed by Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083. Plan verifier bookings, ACD applications, and supplier data collection against the regulatory calendar below — not the financial year.

1 Jan 2026Definitive period started—
31 Mar 2026Late ACD application deadline—
1 Feb 2027CBAM certificate purchasing opens—
30 Sep 2027First annual CBAM declaration due—

Source: Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083

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