CBAM for aluminium extrusions: how embedded emissions are calculated

Aluminium extruders face a specific CBAM calculation. Get two things right, electricity and bought-in metal, and the rest is straightforward.

Which aluminium products are covered

CBAM covers aluminium goods in chapter 76 of the EU's Combined Nomenclature, including unwrought aluminium (7601) and bars, rods and profiles (7604), which is where most extrusions fall. Check the exact CN code your buyer declares your goods under. It decides which rules and default values apply.

Rule 1: Only direct emissions count

The CBAM Regulation lists certain goods in its Annex II. For these, only direct emissions are counted in the definitive period. Aluminium is on that list, along with most iron and steel goods and hydrogen. So the CO2 from your electricity use is not part of the embedded emissions your buyer pays for, even though electricity is a large part of aluminium's real-world footprint.

During the transitional period (2023 to 2025), indirect emissions were reported for aluminium. Guidance written then may still tell you to include them. For declarations from 2026, leave them out of the CBAM figure, though a template may still ask you to report electricity use separately.

For primary aluminium producers, direct emissions include perfluorocarbons (PFCs) from smelting. Extruders who don't smelt won't usually have PFC emissions of their own, but they sit inside the precursor figure for the primary metal you buy.

Rule 2: Bought-in metal carries its emissions with it

Unwrought aluminium you buy and extrude is a precursor. Its embedded emissions are added to yours. For a typical extruder, this is the largest part of the result, so the quality of your metal supplier's data matters more than anything you measure yourself.

If your ingot or billet supplier can give you its own verified CBAM data, use it. If not, the EU default value for that precursor and country of origin applies, including the mark-up.

Scrap

Under the current rules, scrap used as an input is treated as having zero embedded emissions. That makes remelting a real advantage. The Commission has signalled it is looking at how scrap is treated, so check the current rules before building a pricing argument on it.

A worked example

The numbers below are illustrative only. They show the method, not real factors for any plant or country.

With 1,240 tonnes of profiles produced, the specific embedded emissions are 2,555 ÷ 1,240 = about 2.06 t CO2e per tonne. That's the figure your buyer uses. If the precursor had no supplier data and a default value much higher than 1.6 applied, the result would rise sharply. That's why chasing your metal supplier is usually the best use of your time.

Checklist for extruders

• Record fuel use by process, not just for the whole site.
• Record every ingot or billet purchase with supplier name and country of origin.
• Ask metal suppliers for their CBAM data at the time of ordering, not a year later.
• Keep scrap records that separate your own process scrap from bought scrap.
• Keep electricity bills. They may still be requested, but keep them out of the CBAM total.

Frequently asked questions