CBAM data for aluminium foil exporters
Foil mills and converters are often surprised to receive CBAM requests. Your own emissions are usually small; the foil stock you roll carries most of the number.
Quick answer
Aluminium foil up to 0.2 mm thick (CN 7607), backed or not, is covered by CBAM. Your direct emissions mainly come from fuel-fired annealing, while the foil stock you roll, itself a CBAM good, usually carries most of the figure. Electricity isn't counted.
Is this product covered by CBAM?
Yes. Aluminium foil not thicker than 0.2 mm, whether or not backed with paper, paperboard or plastics, falls under CN heading 7607, which is within CBAM's aluminium sector.
| CN code | Goods |
|---|---|
| 7607 | Aluminium foil, thickness up to 0.2 mm, backed or not |
| 7606 | Aluminium coil and strip, a common precursor (foil stock) |
Always confirm the exact code your buyer declares your goods under. Scope is set by CN code, not by how the product is described.
What counts toward your figure
Aluminium goods are on the CBAM list where only direct emissions count in the definitive period. Electricity used in your plant isn't part of the CBAM figure, even if the template asks you to report it.
Direct emissions at a typical foil mill or converter come from:
- Fuel-fired annealing furnaces
- Fuel used in lacquering or laminating ovens, if on site
- Any in-house casting of foil stock
Your precursors: usually the biggest number
Most foil producers roll bought-in foil stock, which is aluminium coil under CN 7606 and a CBAM good with its own embedded emissions. Converters who laminate or slit foil they bought have the purchased foil as their precursor. Ask your supplier for CBAM data at the time of ordering.
What your buyer will ask for
- Embedded emissions per tonne of foil, by product
- Foil stock or coil suppliers, quantities and countries of origin
- How backed or laminated products are made and declared
- Whether data is actual and verified
Documents to gather
- Fuel invoices per furnace or oven
- Production by product and gauge
- Foil stock purchase invoices with supplier and origin
- Scrap and yield records
Common mistakes
- Assuming foil is too thin or too processed to be covered
- Reporting electricity-heavy rolling as CBAM emissions
- Ignoring the foil stock's embedded emissions
- Not agreeing with the buyer how backed foil mass is declared
For the full method, see how to fill in the CBAM communication template and default values vs actual emissions.
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Send your requestFrequently asked questions
Is aluminium foil covered by CBAM?
Yes. Aluminium foil up to 0.2 mm thick, backed or not, falls under CN 7607, which is in scope.
I only laminate foil. Do I still need data?
Your buyer will still need embedded emissions for the goods. The foil you bought is your precursor, and your own direct emissions are added.
What is usually the biggest part of the figure?
The embedded emissions of the foil stock or coil you buy.
Sources
- European Commission: CBAM definitive regime
- European Commission: CBAM communication and news (guidance, templates, default values)
- EUR-Lex: summary of the CBAM Regulation (EU) 2023/956
This guide explains the rules in plain language. It isn't legal advice; see our disclaimer. Always check the current official texts and your buyer's instructions.