What does CBAM mean for aluminium imports?

What you must concretely do

What is expected of you

CBAM (the Carbon Border Adjustment Mechanism, Regulation (EU) 2023/956) stipulates that the import of certain goods from countries outside the EU receives a price corresponding to the CO2 costs that a European producer bears via the EU emissions trading system. Aluminium is on the list of goods to which this applies. For a company that imports aluminium — as a raw material, as a semi-finished product or processed into certain products — something changes in the administration surrounding that import, apart from the customs formalities that already exist.

Verifying whether the imported goods fall under CBAM

The regulation works with a list of commodity codes. A company that imports aluminium products does well to check per item whether the code appears on that list. At a company with 10 to 100 employees, this is usually not a separate compliance department but someone within procurement or logistics who is already familiar with customs codes — the work is mainly: placing the existing code list alongside the CBAM list and keeping track of which purchasing lines are relevant.

Collecting data on embedded emissions

For CBAM goods, information is requested about the emissions that arose during production — the so-called embedded emissions. That data does not come from the company itself, but from the foreign producer or supplier. This means that the importer is dependent on information that another party must provide, and the quality of that information varies greatly per supplier and per country. For companies that work with varying or smaller suppliers outside the EU, this is often the most time-consuming part: not filling in a form, but convincing a supplier to share figures that are sometimes regarded as commercially sensitive.

Reporting via the applicable system

The regulation provides for reporting obligations for CBAM goods, which after the transition period will also have a financial component. In practice, this amounts to a recurring administrative task for an importing company: recording per period which quantities were imported and which emission data goes with them. That is a different rhythm than the one-off documentation that comes with a product passport — CBAM requires something that is repeatedly updated, not a file that is compiled once and then remains valid for years.

Recognising who fulfils the CBAM role within the company

Because it concerns imports, responsibility usually lies with whoever actually brings the goods into the EU — often not the same person or department involved with the aluminium product passport. At a company of this size, it is advisable to determine early on who has which role: who requests the emission data from the supplier, who processes it in the report, and who is the contact if customs asks for substantiation.

Where things go wrong in practice

A first recurring problem is that companies confuse CBAM and the digital product passport, because both concern aluminium and CO2. They are different instruments with a different purpose: CBAM regulates a border adjustment on imports, the passport documents product information for the entire life cycle. To keep these apart, the question what is the difference between my technical file and the digital product passport can be used as a starting point — that explanation is also useful to avoid putting CBAM reporting and passport data in the same box.

A second situation: the supplier outside the EU provides no emission data, or provides it late. Because the importer is dependent on that supplier, delays arise that cannot be resolved by internal measures alone — only by timely contact and clear agreements in advance.

A third pitfall is that companies think that CBAM data and the CO2 data for the product passport use the same source and the same method. That is not a matter of course: the way emissions are determined for CBAM need not coincide with the method requested for the passport. Those who want to know more about this for the passport part will find it at according to which method must I measure the values for the passport.

A fourth situation arises when a company assumes that CBAM only concerns raw materials, and does not recognise that certain processed aluminium products may also appear on the goods list. This leads to incomplete reporting, not because there is any lack of willingness, but because the code list has not been systematically checked.

A fifth point: companies record CBAM data in loose emails and spreadsheets with the relevant buyer, without this being established as a business process. Once that person goes on holiday or changes position, the information is difficult to retrieve.

What you can document now

• An overview of which imported goods codes occurring within the company appear on the CBAM list, with the date of the last check.
• Per supplier outside the EU: whether, how and when emission data are provided, and in what form.
• An internal instruction of who within the company is responsible for CBAM reporting, separately from who compiles the product passport.
• A file per reporting period with the imported quantities and the corresponding emission data, so that in case of questions from customs, recourse can quickly be had to supporting documents.
• Correspondence with suppliers on emission data, kept separately from correspondence on product data for the passport — these two easily run together while they are requested for a different purpose.
• A brief internal note on the distinction between CBAM obligations and passport obligations, so that new employees do not again fall into the confusion that most frequently occurs in practice.