Executive answer
Five findings define the aluminium position
The evidence supports a sharper conclusion than a single dependence score: Europe faces different constraints at each stage of the aluminium chain, and current CBAM accounting captures only one part of the physical carbon exposure.
- 01
Registry estimates are not installation intensity
Aluminium was source-rounded to 5% of non-electricity import mass but 24% of default-based estimated emissions across Q4 2023–Q2 2025. The source prints 81 MtCO₂e against 343 MtCO₂e overall; 81/343 is 23.615%, rounded to 24%. The separate 38.4 MtCO₂e value is calendar 2024 and is not merged here.S-013
- 02
Product output is not route output
PRODCOM provides exact 2025 product categories, but non-alloy/alloy cannot be renamed primary/secondary and the categories cannot be totalled across stages.S-007
- 03
- 04
Trade direction changes by stage
Ore and unwrought metal show net imports while aluminium oxide and scrap show net exports in the bounded 2025 slices. None is a dependence ratio.S-006
- 05
Use this report
Start with the record you need to defend
Importer / declarant
Useful evidence: Goods code, origin, installation, route, precursor and reporting-period records.
Do not: Substitute an origin average or sector figure for supplier evidence.
Procurement
Useful evidence: Product stage, alloy specification, quantity, supplier, source basis and contract responsibility.
Do not: Treat net trade or a project announcement as available supply.
Sustainability / carbon
Useful evidence: Direct, power-related and lifecycle boundaries recorded as separate fields.
Do not: Call current direct-only aluminium CBAM accounting a lifecycle footprint.
Finance / strategy
Useful evidence: Asset event, capacity versus output, status date, energy contract and delivery milestone.
Do not: Convert a capacity announcement, TRL or policy instrument into operating output.
Producer / project owner
Useful evidence: Route, process stage, maturity, project state, measured output and source wording.
Do not: Use one technology label as proof of performance or commercial deployment.
Adviser / researcher
Useful evidence: Document identity, legal status, geography, period, unit, denominator and prohibited inference.
Do not: Merge law, proposal, policy programme, award and observed outcome.
Canonical boundary
This report owns the cross-source evidence—not the execution workflow
For the current legal inventory and high-level goods scope, use the aluminium sector page. For supplier records, threshold and cost preparation, use the aluminium importer guide. This report integrates sector evidence and its limits without reproducing either owner.
Question → canonical owner
Scroll table →| Question | Owner | Treatment here |
|---|---|---|
| Which aluminium CN code is covered? | Sector page / goods checker | Stage summary and link only. |
| What supplier data and cost inputs are needed? | Importer guide | Evidence boundary, not checklist duplication. |
| What did the full Transitional Registry show? | CBAM by the Numbers | One aluminium-specific bounded callout. |
| How do I test threshold or cost? | Threshold checker / cost calculator | No calculator inputs or result here. |
Part 1
Where each number sits matters more than its size
Ore, aluminium oxide, unwrought metal, semi-finished products and scrap are related physical stages, but their reported tonnes are not additive. Trade statistics, PRODCOM product output, plant capacity, realised output, energy use and embedded emissions also answer different questions. V-01 gives each stage equal width deliberately.
V-01 · Evidence-boundary diagram · no quantity encoding
Where each number sits in the aluminium chain
Stage boxes have equal visual weight and no quantity-width encoding.
01
Ore / concentrate
CN 26060000 trade
02
Aluminium oxide
CN 28182000 trade + PRODCOM product
03
Primary / unwrought
CN 7601 trade; unwrought PRODCOM products
04
Semi-finished / products
Separate PRODCOM categories
Do not infer: Do not infer a material balance, complete CBAM scope inventory or contained-aluminium conversion.
Part 2
Official output data are precise about products—and silent about route
PRODCOM reports 618,341.697 t of unwrought non-alloy aluminium and 6,642,252.281 t of unwrought aluminium alloys for EU27_2020 in 2025. Those labels do not identify primary or secondary metal. The deeper packet contains 15 product categories; no total is shown because output can feed later categories and summing would double count.S-007
V-05 · 2025 PRODCOM aluminium product-output map · no total row
Scroll table →| Product code | Short source label | Actual production, t | Flag |
|---|---|---|---|
| 24421130 | Unwrought non-alloy aluminium | 618,341.697 | — |
| 24421154 | Unwrought aluminium alloys | 6,642,252.281 | — |
| 24421200 | Aluminium oxide | 2,478,608.349 | — |
| 24422100 | Aluminium powders and flakes | 60,993.283 | — |
| 24422230 | Non-alloy bars, rods and profiles | 509,368.700 | — |
| 24422250 | Alloy bars, rods and profiles | 3,208,122.295 | — |
| 24422330 | Non-alloy wire | 93,216.904 | — |
| 24422350 | Alloy wire | 172,073.004 | — |
| 24422430 | Non-alloy plate, sheet and strip >0.2 mm | 448,632.014 | — |
| 24422450 | Alloy plate, sheet and strip >0.2 mm | 5,282,176.101 | — |
| 24422500 | Aluminium foil ≤0.2 mm | 1,396,424.419 | — |
| 24422630 | Non-alloy tubes and pipes | 13,873.487 | — |
| 24422650 | Alloy tubes and pipes | 114,375.883 | — |
| 24422670 | Tube or pipe fittings | 17,438.795 | — |
| 38212500 | Secondary raw materials of aluminium | 2,221,713.589 | :E |
Held — not claimed Current EU27 primary output, current secondary-metal output and a defensible route time series remain held. PRODCOM product categories cannot close those gaps. National rows also need not reconcile to EU aggregates where confidential values, estimates and controlled rounding apply; the residual cannot be allocated to countries.
Part 3
Current CBAM is direct-only for aluminium; physical exposure is wider
Current Article 7 says only direct emissions are calculated and taken into account for Annex II goods, and the listed aluminium goods sit in Annex II. That legal accounting boundary does not erase smelting electricity, alumina heat or wider lifecycle emissions—it keeps them outside the current aluminium calculation field.S-008S-010
Historical primary-smelting power ranges
Scroll table →| Boundary / technology | MWh/t Al |
|---|---|
| Electrolysis-specific · point-feed prebaked | 13.2–15.0 |
| Electrolysis-specific · Søderberg | 14.5–17.0 |
| Total electrical power · point-feed prebaked | 13.6–15.7 |
| Total electrical power · Søderberg | 15.1–17.5 |
2025 EU27 industrial electricity context
Scroll table →| Period | EUR/kWh | EUR/MWh |
|---|---|---|
| January–June 2025 | 0.1026 | 102.6 |
| July–December 2025 | 0.0998 | 99.8 |
The power ranges are historical technology references using 2008 input in a 2017 BAT synthesis. The price rows are consumption-weighted EU aggregates for all final non-household consumers using at least 150,000 MWh/year, excluding taxes and levies. They are not aluminium tariffs, PPAs, wholesale prices or viability thresholds. They must not be multiplied into a plant-cost estimate.S-028S-029
Held — not claimed No 65/15/11/9 emissions chart and no Europe/global intensity ranking. The retained candidates fail the licensing, population and method-comparability gates.S-017
Part 4
2025 trade points in different directions at different stages
V-02 · EU27_2020 extra-EU trade · 2025 · tonnes
Scroll table →| CN code | Stage lens | Gross imports | Gross exports | Imports − exports | Direction |
|---|---|---|---|---|---|
| 26060000 | Aluminium ores and concentratesOre/concentrate trade; not contained aluminium or domestic bauxite consumption. | 10,693,654.661 | 17,868.948 | 10,675,785.713 | net imports |
| 28182000 | Aluminium oxide (excluding artificial corundum)Aluminium-oxide trade; not smelter-grade alumina only or refinery output. | 834,083.146 | 1,773,448.214 | -939,365.068 | net exports |
| 7601 | Unwrought aluminiumBounded unwrought-product lens; not primary route or all aluminium. | 6,334,671.095 | 350,007.971 | 5,984,663.124 | net imports |
| 7602 | Aluminium waste and scrapWaste/scrap trade; no composition, quality, recoverability or secondary-output measure. | 652,349.688 | 1,273,397.351 | -621,047.663 | net exports |
These are four separate CN-code lenses. No cross-stage total, contained-aluminium conversion, material balance or dependence percentage is calculated. Import reliance would require stage-compatible production and apparent consumption, plus product-boundary and stock controls that this packet does not contain.S-004S-006
Part 5
Unwrought imports are concentrated, but origin is not installation evidence
For the admitted CN 7601 slice, 2025 extra-EU imports total 6,334,671.095 t. The ten largest country-or-territory origins represent 81.2293% of mass. The chart retains an other-country row and the two not-specified classifications so every displayed value reconciles to the aggregate.
V-03 · Official statistics · 2025
2025 CN 7601 import origins
Country of origin is not supplier, producer, installation or emissions intensity.
Accessible source tableOpen data
| Origin row | Row type | Net mass, t | Share |
|---|---|---|---|
| Norway | country or territory | 1,340,664.874 | 21.2% |
| Iceland | country or territory | 741,969.646 | 11.7% |
| Canada | country or territory | 593,055.781 | 9.4% |
| Mozambique | country or territory | 573,813.761 | 9.1% |
| Bahrain | country or territory | 476,112.590 | 7.5% |
| United Arab Emirates | country or territory | 454,313.632 | 7.2% |
| Russia | country or territory | 303,085.282 | 4.8% |
| India | country or territory | 247,621.432 | 3.9% |
| United Kingdom | country or territory | 218,727.923 | 3.5% |
| South Africa | country or territory | 196,244.243 | 3.1% |
| Other country or territory rows | country or territory | 1,186,495.216 | 18.7% |
| Not specified | not specified | 2,566.715 | 0.0% |
| EU27 extra-EU aggregate | 6,334,671.095 | 100.0% | |
The ten named origins total 5,145,609.164 t (81.2293%). Other country/territory rows add 1,186,495.216 t and not-specified rows add 2,566.715 t, reconciling exactly to the aggregate.
Source: Eurostat international trade in goods / Comext, EU27_2020 extra-EU trade, extracted 12 August 2026.
Transformation: CBAM Pulse transformed the source data by converting 100 kg units to tonnes, computing shares or net flow where stated, and grouping only the explicitly labelled residual rows.
Eurostat notice: Eurostat accepts no responsibility for the transformed data or conclusions drawn from it.
Do not infer: Do not infer supplier performance, carbon intensity or bilateral shipment paths.
Part 6
Scrap is a trade flow and a chemistry constraint
CN 7602 records 652,349.688 t of gross imports and 1,273,397.351 t of gross exports in 2025, yielding 621,047.663 t of net exports. That arithmetic does not establish a recoverable domestic pool, alloy suitability, secondary output or a shortage. Import rows mean country of origin; export rows mean last known destination. They are never connected as shipment paths.S-006
V-04 · Official statistics · 2025
2025 CN 7602 gross trade and leading partners
Import-origin and export-destination semantics remain separate.
Gross imports
652,349.688 t
Gross exports
1,273,397.351 t
Arithmetic result: exports exceeded imports by 621,047.663 t. This is a net trade flow—not a measure of recoverable domestic scrap, alloy quality, recycling output or shortage.
Leading import origins
Country of origin for extra-EU imports
- 1158,719 tSwitzerland24.3%
- 2113,738 tUnited Kingdom17.4%
- 346,146 tNorway7.1%
- 434,172 tTürkiye5.2%
- 532,887 tIsrael5.0%
Leading export destinations
Last known country of destination for extra-EU exports
- 1382,502 tIndia30.0%
- 2149,163 tThailand11.7%
- 3126,585 tChina9.9%
- 4106,705 tHong Kong8.4%
- 5103,822 tPakistan8.2%
Accessible source tableOpen data
| Flow | Partner semantics | Gross mass, t | Boundary |
|---|---|---|---|
| Imports | Country of origin | 652,349.688 | Not a domestic-availability measure |
| Exports | Last known destination | 1,273,397.351 | Not proof of recovery at destination |
Source: Eurostat international trade in goods / Comext, EU27_2020 extra-EU trade, extracted 12 August 2026.
Transformation: CBAM Pulse transformed the source data by converting 100 kg units to tonnes, computing shares or net flow where stated, and grouping only the explicitly labelled residual rows.
Eurostat notice: Eurostat accepts no responsibility for the transformed data or conclusions drawn from it.
Do not infer: Do not infer scrap shortage, domestic availability, secondary output, recovery or shipment paths.
JRC technical synthesis says the secondary route uses about 5% of the energy required for primary aluminium. That route-level comparison does not mean every collected tonne is clean, substitutable or suitable. Wrought-alloy production can require segregated chemistry and primary metal for dilution; casting-alloy routes can tolerate different impurities.S-002S-004
Part 7
Technology maturity is not project operation
V-06 · JRC maturity and native-unit evidence · no ranking
Scroll table →| Intervention | Stage | JRC maturity | Native evidence | Boundary |
|---|---|---|---|---|
| Inert anodes | Primary smelting / electrolysis | TRL 4–5 | EUR 110–120/t Al estimated competing anode price | Not a retrofit cost, realised market price, measured abatement or deployment result. |
| Inert-anode retrofit illustration | Existing electrolysis cells | TRL 4–5 | EUR 1–2m capital cost per cell replacement | Illustrative source-wide arithmetic, not a project budget or comparable abatement cost. |
| Hydrogen co-feeding / calcination heat | Alumina refining | General TRL 7–9; aluminium calcination 5–6 | EUR 3–5/kg renewable hydrogen | Hydrogen input cost is not an aluminium abatement cost or evidence of availability. |
| Hydrogen as reducing agent | Alternative primary-metal concept | Laboratory tests; no proof of concept | Not reported | Laboratory work does not establish feasibility, cost or operation. |
| Absorption-based CCUS | Refining and primary smelting | Aluminium-specific TRL 3–4 | EUR 50–80/t CO₂ refinery; EUR 180–300/t CO₂ smelter | Unlike flue-gas conditions; excludes transport, storage and energy penalties. |
| Direct electrification | Alumina heat and steam | Technology-specific; no aggregate TRL | 70% contextual fossil-fuel share used for steam | Cited context, not an EU observation or measured benefit. |
| Induction electrification | Casting / remelting heat | Well-understood; no TRL reported | 37% / 50% source comparisons against named gas-furnace baselines | Not an EU fleet average, universal baseline or emissions result. |
| Waste-heat recovery | Primary smelting | TRL 7–9 | 30–45% of smelting heat reported as waste heat | Waste-heat share is not recoverable energy or measured savings. |
| Fluidised-bed calciners | Alumina calcination | TRL 9 | Up to 30–35% source-reported energy/cost reduction | Technology potential is not a guaranteed or fleet-average saving. |
| Electric boilers | Low/mid-temperature heat | TRL 4–5 | Not reported | No aluminium-wide cost, abatement or deployment population. |
| Mechanical vapour recompression | Alumina digestion steam | TRL 7–8 | Not reported | Pilot citation is not European commercial deployment or measured performance. |
| Lower-temperature electrolysis | Primary smelting | TRL 7–8 | 1–1.5 MWh/t theoretical reduction | Theoretical potential is not measured savings or deployment. |
Unlike costs, percentages, theoretical energy reductions and maturity labels stay in native units. The matrix therefore cannot be sorted into a common cost curve or a winning-technology league table.S-002
Direct-source project exemplars · exact status wording separated
Scroll table →| Project | Date | Controlled category | Exact status | Do not infer |
|---|---|---|---|---|
| Hydro HalZero test facility | 2026-Q1 | demonstrated/pilot | test facility commissioned | Not commercial aluminium production, proven full-process performance or measured abatement. |
| Hydro HalZero industrial concept pilot | Page updated 8 January 2026 | announced | construction aim toward the end of the decade | Not under construction, funded, operating or commercially deployed. |
| Constellium hydrogen-fired slab casting | July 2024 | demonstrated/pilot | 12-tonne slab demonstrated at C-TEC | Not routine commercial production, verified renewable hydrogen or measured lifecycle abatement. |
Part 8
Selected smelter events form a dated register—not a census
EV-01
paused/curtailed
Slovalco, Slovakia
17 August 2022 · mothballing announced
175,000 t/year capacity
Boundary: Announcement with deadline; not measured output or permanent closure.
EV-02
announced
Slovalco, Slovakia
1 July 2026 · partial restart agreement announced
75,000 t/year capacity
Boundary: Agreement/restart announcement; not completion or realised output.
EV-03
closed
Speira Rheinwerk, Germany
2023 announcement; 2025 corroboration · smelting ramp-down, later called former smelter
70,000 t remaining liquid production named
Boundary: Smelting exit only; the whole Rheinwerk site did not close.
EV-04
operating
Alcoa San Ciprián, Spain
7 April 2026 · smelter restart completed
No site-output quantity retained
Boundary: Completion event; no utilisation or annual-output inference.
Slovalco’s 2026 agreement enables a restart of 75,000 t/year of curtailed capacity; it does not prove realised output. Rheinwerk’s smelting exit does not mean the whole site closed. San Ciprián’s completed restart does not disclose site utilisation. These are direct operator statements, not independent causal analysis.S-030S-032S-033
Part 9
Policy delivery must be read action by action
V-07 · Steel and Metals Action Plan follow-up at the research cutoff
Scroll table →| Action | Announced | Observed | Status | Legal / operational meaning | Do not infer |
|---|---|---|---|---|---|
| PA-01Clean Industrial Deal State Aid Framework | Q2 2025 | 25 June 2025 | Adopted within announced quarter | Commission framework enabling qualifying Member-State schemes. | No proof that an aluminium project received aid. |
| PA-02Future-proof network-charge guidance | Q2 2025 | 2 July / July 2025 | Published after announced quarter | Commission guidance; national regulators retain tariff-design roles. | No aluminium-specific tariff, price reduction or Member-State implementation. |
| PA-03Low-carbon hydrogen methodology | Coming weeks from 19 March | 8 July 2025 | Adopted after programme announcement | Adopted methodology for low-carbon hydrogen and fuels. | No proof of hydrogen availability, price, aluminium uptake or project savings. |
| PA-04Third European Hydrogen Bank call | Q3 2025 | 4 Dec 2025–19 Feb 2026 | Opened later; awards reported | Auction awards reported; grant agreements still expected on the retained page. | No aluminium award, production or signed-grant inference. |
| PA-05Export-carbon-leakage options | Q2 2025 | 2 July 2025 | Communication after announced quarter | Commission considered options and stated an intention for a proposal. | No adopted compensation scheme or exporter entitlement. |
| PA-06Downstream CBAM / anti-circumvention | Q4 2025 | 17 December 2025; checked 12 Aug 2026 | Proposal delivered; procedure ongoing | Legislative proposal, not current law. | No adopted downstream scope, scrap treatment or date. |
| PA-07Metal-scrap availability measures | By Q3 2025 | Bounded audit to 12 Aug 2026 | No positive follow-up admitted | Unresolved in this bounded packet. | Absence of an admitted record is not proof of non-delivery or new trade rules. |
CISAF adoption, network-charge guidance, a hydrogen methodology, auction awards, a communication, a legislative proposal and an unresolved bounded search are not one implementation score. Instrument publication does not prove Member-State implementation; an award does not prove a signed grant or operation; absence of an admitted scrap follow-up does not prove non-delivery.S-012S-020S-021S-034
Part 10
Seven decisions turn the evidence into an operating discipline
D-01
Classify every number by stage, route and metric before use.
Decision test: Can the record name product/stage, route, value, unit, period, geography, denominator and evidence class?
Stop: Never sum ore, oxide, metal, semis or scrap tonnes into one material balance.
D-02
Refuse comparisons until geography, period, route, denominator and method align.
Decision test: Do both values share the same product, population, period and system boundary?
Stop: Never average conflicts, allocate confidential residuals or splice output with capacity.
D-03
Keep sector context separate from supplier and installation evidence.
Decision test: Does the value identify a producer and reporting period, or is it an aggregate/default/origin record?
Stop: Never assign an origin share, default or EU price to a producing installation.
D-04
Separate the current direct-only CBAM boundary from lifecycle exposure.
Decision test: Is the question legal accounting, physical emissions or a transition lever?
Stop: Never call current direct-only accounting a complete aluminium footprint.
D-05
Use gross/net trade as stage context; require a compatible denominator for dependence.
Decision test: Are production, imports, exports and stock/product boundaries aligned?
Stop: Never call net imports dependence or net scrap exports a shortage.
D-06
Record technology maturity and project delivery in different fields.
Decision test: Is the evidence model, lab, pilot, construction, operation, capacity or realised output?
Stop: Never turn TRL, a demonstration or an announcement into operating capacity.
D-07
Route execution questions to the existing CBAM Pulse workflow owners.
Decision test: Is the reader asking for evidence context or a goods, supplier, threshold, cost or filing workflow?
Stop: This flagship never determines obligations, final liability or compliance.
Method
One reviewed snapshot; explicit admission and refusal rules
The research cutoff is 12 August 2026. The immutable corrected-v2 packet contains 171 research files and passed independent bounded review at SHA-256 7e3774dfa99cd5f73e121b839222fe2a14a7d1db7308c26638d0baac04908dfc. Live packet bytes matched the reviewed files before the cutoff was frozen.
- Source-first: current law owns legal claims; Eurostat owns official product/trade/price observations; JRC owns attributed synthesis and scenarios; company pages own only their exact dated statements.
- Atomise: every retained claim carries source IDs, locator, evidence class, limitation, prohibited inference and canonical owner.
- Separate: stage, route, capacity, output, direct/power/lifecycle emissions, gross/net trade, proposal/law and announcement/operation never collapse into one field.
- Fail closed: unsupported or commercially blocked values remain Held — not claimed; removed canonical duplication remains visible in the audit trail.
- Reuse responsibly: CBAM Pulse transformed Eurostat data, identifies the changes and includes the Eurostat non-responsibility disclaimer. Third-party material and listed reporting-country exceptions remain excluded.
Audit trail
Claim ledger: 30 supported, 7 held, 1 removed
Open the complete reviewed claim ledger38 records
Q-001Current Annex I lists aluminium under CN 7601, 7603–7614 and 7616; exact goods discovery remains with the sector page and goods checker.
Adopted law
Current Annex I lists aluminium under CN 7601, 7603–7614 and 7616; exact goods discovery remains with the sector page and goods checker.
- Source / locator
- S-008 · Annex I, aluminium rows
- Evidence class
- Adopted EU law
- Limitation
- The report summarises stages rather than reproducing the legal inventory.
- Prohibited inference
- Do not infer that a commercial product name establishes its CN classification or CBAM status.
- Canonical owner
- /sectors/aluminium
Q-002Current Annex II includes the listed aluminium goods, so Article 7 requires direct emissions only to be calculated and taken into account for them.
Adopted law
Current Annex II includes the listed aluminium goods, so Article 7 requires direct emissions only to be calculated and taken into account for them.
- Source / locator
- S-008, S-010 · Article 7(1), Annex II; IR 2025/2547 Article 3 and Annex I
- Evidence class
- Adopted EU law
- Limitation
- This is the current CBAM calculation boundary, not a lifecycle boundary.
- Prohibited inference
- Do not add smelting-power emissions to the current direct-only aluminium calculation or call it a lifecycle footprint.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-003The corrected definitive default rule uses total emissions plus the applicable markup; direct and indirect columns are informational, with route indicators for primary and secondary aluminium where applicable.
Adopted law
The corrected definitive default rule uses total emissions plus the applicable markup; direct and indirect columns are informational, with route indicators for primary and secondary aluminium where applicable.
- Source / locator
- S-027 · Article 2 and Annex I opening rules
- Evidence class
- Adopted EU law
- Limitation
- Default rows are regulatory defaults, not measured installation values.
- Prohibited inference
- Do not present a country/product default as actual producer or installation performance.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-004Current ETS law and the CBAM free-allocation adjustment apply the operative CBAM-factor path through 2034, with actual/default evidence handled separately.
Adopted law
Current ETS law and the CBAM free-allocation adjustment apply the operative CBAM-factor path through 2034, with actual/default evidence handled separately.
- Source / locator
- S-022, S-023 · Directive Article 10a(1a); IR 2025/2620 Articles 1–3
- Evidence class
- Adopted EU law
- Limitation
- The report does not reproduce a calculator or company-specific adjustment.
- Prohibited inference
- Do not merge the separate 2026 proposal schedule into operative law.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-005COM(2025)989 proposes downstream aluminium scope and pre-consumer-scrap treatment from 2028; procedure 2025/0419(COD) was ongoing at cutoff.
Proposal — not law
COM(2025)989 proposes downstream aluminium scope and pre-consumer-scrap treatment from 2028; procedure 2025/0419(COD) was ongoing at cutoff.
- Source / locator
- S-020, S-021 · Proposal recitals 19–20, 39–47 and 53; procedure page
- Evidence class
- Proposal — not law
- Limitation
- The legislative text and dates can change during the procedure.
- Prohibited inference
- Do not present the proposed downstream goods, scrap rules or dates as adopted obligations.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-006COM(2026)616 proposes a different CBAM-factor path and conditional additional free allocation; procedure 2026/0212(COD) was ongoing at cutoff.
Proposal — not law
COM(2026)616 proposes a different CBAM-factor path and conditional additional free allocation; procedure 2026/0212(COD) was ongoing at cutoff.
- Source / locator
- S-024, S-025 · Proposed Article 10a; procedure page
- Evidence class
- Proposal — not law
- Limitation
- The current Directive remains the operative source at the cutoff.
- Prohibited inference
- Do not use the proposal schedule in current-law calculations or claim adoption.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-007Commission transitional data display aluminium at a source-rounded 5% of non-electricity import mass and 81 MtCO₂e of default-based estimated emissions over Q4 2023–Q2 2025.
Official data
Commission transitional data display aluminium at a source-rounded 5% of non-electricity import mass and 81 MtCO₂e of default-based estimated emissions over Q4 2023–Q2 2025.
- Source / locator
- S-013 · Annex IV, Figures 5 and 17–19
- Evidence class
- Official administrative estimate
- Limitation
- The emissions are unverified estimates derived from transitional defaults, not actual installation intensities.
- Prohibited inference
- Do not infer certificate demand, cost, verified emissions or producer performance.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-008The 24% displayed aluminium emissions share reconciles at source precision: 81 / 343 = 23.615%, rounded to 24%.
Institutional synthesis
The 24% displayed aluminium emissions share reconciles at source precision: 81 / 343 = 23.615%, rounded to 24%.
- Source / locator
- S-013 · Annex IV, Figures 17–19
- Evidence class
- Official estimate plus deterministic arithmetic
- Limitation
- The separate calendar-2024 estimate of 38.4 MtCO₂e must not be merged with the seven-quarter 81 MtCO₂e value.
- Prohibited inference
- Do not divide the rounded emissions and mass totals into an actual intensity or liability estimate.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-009PRODCOM reports 2025 EU27 output of 618,341.697 t unwrought non-alloy aluminium and 6,642,252.281 t unwrought aluminium alloys.
Official data
PRODCOM reports 2025 EU27 output of 618,341.697 t unwrought non-alloy aluminium and 6,642,252.281 t unwrought aluminium alloys.
- Source / locator
- S-007, S-035 · DS-059368 rows 24421130 and 24421154
- Evidence class
- Official statistics
- Limitation
- These are product categories and do not identify primary or secondary production routes.
- Prohibited inference
- Do not relabel non-alloy/alloy output as primary/secondary output or sum across stages.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-010No compatible admitted source establishes current EU27 primary-aluminium output.
Held — not claimed
No compatible admitted source establishes current EU27 primary-aluminium output.
- Source / locator
- S-001, S-002, S-007 · Conflicting route/output evidence in retained JRC and PRODCOM records
- Evidence class
- Held evidence gap
- Limitation
- Product output does not identify the primary route, and retained JRC values are not compatible enough to adjudicate a current total.
- Prohibited inference
- Do not publish a current EU27 primary-output total from these records.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-011No compatible admitted source establishes current European recycled or secondary aluminium-metal output.
Held — not claimed
No compatible admitted source establishes current European recycled or secondary aluminium-metal output.
- Source / locator
- S-001, S-002, S-003, S-007, S-017 · Route/population review
- Evidence class
- Held evidence and licensing gap
- Limitation
- The candidate populations and terms do not support a publishable, geography-compatible output total.
- Prohibited inference
- Do not relabel secondary raw materials, scrap processed or wider-Europe figures as EU27 secondary metal output.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-012The Commission described roughly half of EU primary-production capacity as inactive since 2021 in March 2025.
Institutional synthesis
The Commission described roughly half of EU primary-production capacity as inactive since 2021 in March 2025.
- Source / locator
- S-012 · COM(2025)125 aluminium passages
- Evidence class
- Official policy-programme synthesis
- Limitation
- The document alternates between more than 50% idled and around 50% curtailed, so no finer precision is retained.
- Prohibited inference
- Do not treat the observation as measured output, current utilisation or proof of one cause.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-013No defensible same-route output-and-capacity time series is available from the admitted records.
Held — not claimed
No defensible same-route output-and-capacity time series is available from the admitted records.
- Source / locator
- S-001, S-002, S-007 · Output/capacity conflict review
- Evidence class
- Held comparability gap
- Limitation
- PRODCOM product series, primary-route values and capacity cannot be spliced into one trend.
- Prohibited inference
- Do not publish an output-versus-capacity trend or average incompatible values.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-014The 2025 PRODCOM packet provides 15 exact aluminium product-output categories with official labels, units and flags.
Official data
The 2025 PRODCOM packet provides 15 exact aluminium product-output categories with official labels, units and flags.
- Source / locator
- S-007, S-035 · DS-059368, 15 retained product rows
- Evidence class
- Official statistics
- Limitation
- Categories can feed later categories and therefore have no valid total row.
- Prohibited inference
- Do not call product names extrusion, rolling or casting routes without source evidence; do not sum the rows.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-015Member-State unwrought rows do not fully allocate the EU aggregate where confidentiality, unavailable values, estimates and rounding intervene.
Official data
Member-State unwrought rows do not fully allocate the EU aggregate where confidentiality, unavailable values, estimates and rounding intervene.
- Source / locator
- S-007, S-035 · PRODCOM 2025 Member-State dissemination populations
- Evidence class
- Official statistics
- Limitation
- National published rows are not required to add to the EU aggregate.
- Prohibited inference
- Do not allocate the residual to countries or convert missing/confidential rows to zero.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-016Four direct-operator records support a bounded event history for Slovalco, Rheinwerk and San Ciprián using controlled status categories.
Direct operator statement
Four direct-operator records support a bounded event history for Slovalco, Rheinwerk and San Ciprián using controlled status categories.
- Source / locator
- S-030, S-032, S-033 · Operator event table EV-01–EV-04
- Evidence class
- Direct operator communications
- Limitation
- These selected events are not a complete asset census and capacities are not realised output.
- Prohibited inference
- Do not infer EU-wide capacity change, utilisation or causality from selected company statements.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-017No publishable quantitative power/process/thermal emissions split is admitted.
Held — not claimed
No publishable quantitative power/process/thermal emissions split is admitted.
- Source / locator
- S-001, S-002, S-017 · IAI-derived split review
- Evidence class
- Held licensing and provenance gap
- Limitation
- The candidate 65/15/11/9 split depends on commercially blocked third-party material.
- Prohibited inference
- Do not publish the split, transform it into a chart or call it an EU observation.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-018The 2017 BAT reference reports historical primary-smelting electrical-power ranges of 13.2–17.5 MWh/t across named technology boundaries using 2008 input.
Institutional synthesis
The 2017 BAT reference reports historical primary-smelting electrical-power ranges of 13.2–17.5 MWh/t across named technology boundaries using 2008 input.
- Source / locator
- S-028 · Table 4.9
- Evidence class
- Historical Commission/JRC technical synthesis
- Limitation
- The rows separate electrolysis-specific energy from total electrical power and are not a current EU fleet average.
- Prohibited inference
- Do not multiply these historical ranges by 2025 market prices to estimate a plant bill.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-019No publishable quantitative split separates refinery fuel, smelting electricity and anode/PFC emissions across a compatible population.
Held — not claimed
No publishable quantitative split separates refinery fuel, smelting electricity and anode/PFC emissions across a compatible population.
- Source / locator
- S-001, S-002, S-004, S-017 · Stage-specific emissions review
- Evidence class
- Held evidence and licensing gap
- Limitation
- Qualitative stage distinctions are retained, but the candidate numeric split is not publishable.
- Prohibited inference
- Do not blend unlike stage emissions into one aluminium footprint.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-020No method-complete European primary-aluminium intensity is admitted for publication.
Held — not claimed
No method-complete European primary-aluminium intensity is admitted for publication.
- Source / locator
- S-001, S-017 · Intensity-method review
- Evidence class
- Held population and licensing gap
- Limitation
- Geography, reporting population, lifecycle boundary, allocation, energy mix and reuse rights are not jointly resolved.
- Prohibited inference
- Do not publish a universal European primary-aluminium footprint.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-021No compatible European/global intensity pair is admitted for a ranking or ratio.
Held — not claimed
No compatible European/global intensity pair is admitted for a ranking or ratio.
- Source / locator
- S-001, S-017 · Regional/global method comparison
- Evidence class
- Held comparability gap
- Limitation
- The candidate series do not share product, stages, gases, year, allocation, electricity treatment or population.
- Prohibited inference
- Do not rank regions or calculate a European/global advantage from unlike methods.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-022JRC technical synthesis states that the secondary route uses about 5% of the energy required for primary aluminium.
Institutional synthesis
JRC technical synthesis states that the secondary route uses about 5% of the energy required for primary aluminium.
- Source / locator
- S-002 · Abstract and section 3.1.3
- Evidence class
- Institutional technical synthesis
- Limitation
- This is a route-level literature synthesis without a complete common functional-unit specification.
- Prohibited inference
- Do not treat every recycled tonne as low-carbon, quality-equivalent or suitable for every alloy.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-023JRC distinguishes inert-anode, refinery-CCUS and smelting-power emissions boundaries rather than treating them as one intervention.
Institutional synthesis
JRC distinguishes inert-anode, refinery-CCUS and smelting-power emissions boundaries rather than treating them as one intervention.
- Source / locator
- S-002 · Printed pages 27–31
- Evidence class
- Institutional technical synthesis
- Limitation
- Technology discussion is not measured plant abatement or operating-project evidence.
- Prohibited inference
- Do not infer that one intervention removes electricity-generation, process and lifecycle emissions together.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-024Eurostat reports 2025 EU27 band-IG non-household electricity prices excluding taxes and levies of EUR 102.6/MWh in S1 and EUR 99.8/MWh in S2.
Official data
Eurostat reports 2025 EU27 band-IG non-household electricity prices excluding taxes and levies of EUR 102.6/MWh in S1 and EUR 99.8/MWh in S2.
- Source / locator
- S-029, S-035 · nrg_pc_205, EU27_2020, MWH_GE150000
- Evidence class
- Official statistics
- Limitation
- The consumption-weighted EU aggregates cover all final non-household band-IG consumers, not aluminium smelters.
- Prohibited inference
- Do not call the values smelter tariffs, PPAs, wholesale prices, plant costs or viability thresholds.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-025EU27 extra-EU CN 7601 trade in 2025 recorded 6,334,671.095 t gross imports and 350,007.971 t gross exports.
Official data
EU27 extra-EU CN 7601 trade in 2025 recorded 6,334,671.095 t gross imports and 350,007.971 t gross exports.
- Source / locator
- S-006, S-035 · DS-045409 aggregate rows
- Evidence class
- Official statistics
- Limitation
- CN 7601 is a bounded unwrought trade lens; imports are CIF and exports FOB.
- Prohibited inference
- Do not interpret the flow as supplier identity, installation performance, all aluminium trade or dependence.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-026The ten largest country-of-origin rows represented 81.2293% of 2025 CN 7601 extra-EU import mass.
Official data
The ten largest country-of-origin rows represented 81.2293% of 2025 CN 7601 extra-EU import mass.
- Source / locator
- S-006, S-035 · CN 7601 origin population, top ten rows
- Evidence class
- Official statistics
- Limitation
- Partner means country of origin, not seller, producer or installation.
- Prohibited inference
- Do not attach an emissions intensity or supplier conclusion to an origin share.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-027Import reliance requires net imports divided by compatible apparent consumption; the 2025 packet lacks the matching production denominator.
Institutional synthesis
Import reliance requires net imports divided by compatible apparent consumption; the 2025 packet lacks the matching production denominator.
- Source / locator
- S-004, S-006, S-007 · JRC125390 Figure 4 and footnote 19
- Evidence class
- Institutional method plus official statistics
- Limitation
- Gross and net stage flows remain sourcing context, not a dependence percentage.
- Prohibited inference
- Do not calculate dependence without compatible stage production, trade and denominator controls.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-028For CN 7601, 2025 gross imports minus gross exports equal 5,984,663.124 t derived net imports.
Official data
For CN 7601, 2025 gross imports minus gross exports equal 5,984,663.124 t derived net imports.
- Source / locator
- S-006, S-035 · CN 7601 aggregate rows
- Evidence class
- Official statistics plus deterministic arithmetic
- Limitation
- Stock changes, product-boundary reconciliation and compatible production are absent.
- Prohibited inference
- Do not call net imports apparent consumption, dependence or a physical shortage.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-029Separate 2025 trade slices show net imports of bauxite/ore, net exports of aluminium oxide and net exports of aluminium waste/scrap.
Official data
Separate 2025 trade slices show net imports of bauxite/ore, net exports of aluminium oxide and net exports of aluminium waste/scrap.
- Source / locator
- S-006, S-035 · CN 26060000, 28182000 and 7602 packets
- Evidence class
- Official statistics plus deterministic arithmetic
- Limitation
- Each code remains a separate stage lens with no contained-aluminium conversion.
- Prohibited inference
- Do not sum the stages into a material balance, shortage or dependence measure.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-030A wider Chapter 76 scope crosswalk was removed because exact scope and code checking have canonical owners elsewhere.
Removed
A wider Chapter 76 scope crosswalk was removed because exact scope and code checking have canonical owners elsewhere.
- Source / locator
- S-006, S-008 · Route ownership review
- Evidence class
- Canonical-ownership removal
- Limitation
- Removed content is recorded for auditability and is not a report finding.
- Prohibited inference
- Do not reproduce the removed crosswalk as positive report content.
- Canonical owner
- /sectors/aluminium
Q-031A historical EU28 material-flow model provides 2013 flow and recycling definitions, not current EU27 observations.
Institutional synthesis
A historical EU28 material-flow model provides 2013 flow and recycling definitions, not current EU27 observations.
- Source / locator
- S-005 · JRC111643 project-calculated EU28 model
- Evidence class
- Historical institutional material-flow model
- Limitation
- The geography and representative year are EU28/2013 and cannot be treated as current.
- Prohibited inference
- Do not carry the historical recycling rates or flows forward as 2025 EU27 facts.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-032CN 7602 trade in 2025 recorded 652,349.688 t gross imports, 1,273,397.351 t gross exports and 621,047.663 t derived net exports.
Official data
CN 7602 trade in 2025 recorded 652,349.688 t gross imports, 1,273,397.351 t gross exports and 621,047.663 t derived net exports.
- Source / locator
- S-006, S-035 · CN 7602 aggregate and partner populations
- Evidence class
- Official statistics plus deterministic arithmetic
- Limitation
- Gross and net flows do not establish composition, recovery, quality, domestic availability or secondary output.
- Prohibited inference
- Do not call net exports a scrap shortage or connect origin and destination rows as shipment paths.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-033JRC distinguishes tighter wrought-alloy scrap constraints from more impurity-tolerant casting-alloy routes.
Institutional synthesis
JRC distinguishes tighter wrought-alloy scrap constraints from more impurity-tolerant casting-alloy routes.
- Source / locator
- S-003, S-004 · JRC125390 Box 1; JRC143128 corroboration
- Evidence class
- Institutional technical synthesis
- Limitation
- Scrap quality, sorting and chemistry constrain substitution by product and alloy family.
- Prohibited inference
- Do not assume mixed scrap is interchangeable with primary metal or suitable for every aluminium product.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-034JRC circular-economy results are model scenarios: BSL50 101, CTC50 98 and ACE50 87 MtCO₂e/year for the entire modelled system.
Institutional synthesis
JRC circular-economy results are model scenarios: BSL50 101, CTC50 98 and ACE50 87 MtCO₂e/year for the entire modelled system.
- Source / locator
- S-003 · Scenario definitions and results, printed pages 20–22 and 53–55
- Evidence class
- Institutional model scenario
- Limitation
- These are modelled scenarios, not forecasts, targets or observed outcomes; the source geography is wider than EU27.
- Prohibited inference
- Do not present one scenario as a prediction or attribute its change to CBAM alone.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-035The JRC technology matrix preserves unlike maturity and native-unit evidence instead of manufacturing one cost or technology ranking.
Institutional synthesis
The JRC technology matrix preserves unlike maturity and native-unit evidence instead of manufacturing one cost or technology ranking.
- Source / locator
- S-002 · Validated 12-row technology matrix
- Evidence class
- Institutional technical synthesis
- Limitation
- Maturity, costs, energy and technical potentials use unlike denominators and evidence bases.
- Prohibited inference
- Do not rank a winner, compare native-unit figures as one cost axis or infer operating deployment.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-036Three direct-source exemplars separate a commissioned test facility, a planned pilot and a demonstrated 12-tonne hydrogen-cast slab.
Direct operator statement
Three direct-source exemplars separate a commissioned test facility, a planned pilot and a demonstrated 12-tonne hydrogen-cast slab.
- Source / locator
- S-030, S-031 · Project status table PJ-01–PJ-03
- Evidence class
- Direct operator communications
- Limitation
- Exact source wording and controlled status remain separate; the examples are not a census.
- Prohibited inference
- Do not relabel announced or demonstrated projects as operating commercial capacity.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-037A seven-row official audit records Action Plan follow-up action by action rather than assigning one implementation verdict.
Institutional synthesis
A seven-row official audit records Action Plan follow-up action by action rather than assigning one implementation verdict.
- Source / locator
- S-012, S-020, S-021, S-034 · Policy action table PA-01–PA-07
- Evidence class
- Official policy / operations records
- Limitation
- Publication, adoption, guidance, auction award, proposal and unresolved follow-up have distinct meanings.
- Prohibited inference
- Do not infer Member-State implementation, project operation, signed grants or non-delivery from these records.
- Canonical owner
- /guides/european-aluminium-under-cbam
Q-038Seven bounded operator decisions classify numbers, refuse incompatible comparisons, separate aggregates from installations and route execution to canonical tools.
Institutional synthesis
Seven bounded operator decisions classify numbers, refuse incompatible comparisons, separate aggregates from installations and route execution to canonical tools.
- Source / locator
- S-002, S-004, S-006, S-007, S-008 · Operator decision matrix D-01–D-07
- Evidence class
- Derived decision contract
- Limitation
- The decisions organise evidence; they do not determine a reader's legal obligations or investment action.
- Prohibited inference
- Do not use this report as customs, tax, legal, compliance, certification or investment advice.
- Canonical owner
- /guides/european-aluminium-under-cbam
Source register
27 admitted source records
S-001
JRC144120 — Mapping the transition of the EU aluminium industry to carbon neutrality
Accessed 2026-08-12 · Institutional analysis / scenario
Boundary: Internal evidence and attributed quotation; no publisher chart reuse.
S-002
JRC136525 — Decarbonisation Options for the Aluminium Industry
Accessed 2026-08-12 · Institutional technical analysis
Boundary: CC BY 4.0; credit and change notice required; third-party cover excluded.
S-003
JRC143128 — Environmental and Socio-Economic Impacts of the Circular Economy Transition
Accessed 2026-08-12 · Institutional model scenario
Boundary: CC BY 4.0; scenario labels and assumptions retained.
S-004
JRC125390 — Sustainability aspects of Bauxite and Aluminium
Accessed 2026-08-12 · Institutional analysis
Boundary: CC BY 4.0; named third-party figures excluded.
S-005
JRC111643 — Material flow analysis of aluminium, copper and iron in the EU-28
Accessed 2026-08-12 · Historical institutional material-flow analysis
Boundary: Source acknowledgement required; EU28/2013 boundary retained.
S-006
Eurostat international trade in goods / Comext
Accessed 2026-08-12 · Official statistics
Boundary: Transformed Eurostat data; attribution, change notice and non-responsibility disclaimer apply.
S-007
Eurostat PRODCOM database
Accessed 2026-08-12 · Official statistics
Boundary: Transformed Eurostat data; attribution, change notice and non-responsibility disclaimer apply.
S-008
Regulation (EU) 2023/956 consolidated to 20 October 2025
Accessed 2026-08-12 · Adopted EU law
Boundary: Official legal text; current consolidation rechecked at cutoff.
S-010
Commission Implementing Regulation (EU) 2025/2547
Accessed 2026-08-12 · Adopted EU law
Boundary: Official legal text.
S-012
COM(2025)125 — European Steel and Metals Action Plan
Accessed 2026-08-12 · Official EU policy programme
Boundary: Programme commitments are not law or proof of delivery.
S-013
COM(2025)783 — report on the application of CBAM and Annex IV
Accessed 2026-08-12 · Official administrative data / estimate
Boundary: Default-based transitional estimates remain labelled unverified.
S-017
International Aluminium Institute terms of use
Accessed 2026-08-12 · First-party licensing record
Boundary: Quantitative IAI copying, transformation and republication are blocked without permission.
S-020
COM(2025)989 — downstream-CBAM proposal
Accessed 2026-08-12 · Official EU proposal — not law
Boundary: Proposal wording kept separate from current obligations.
S-021
EUR-Lex procedure 2025/0419(COD)
Accessed 2026-08-12 · Official procedure record
Boundary: Volatile status; ongoing at the research cutoff.
S-022
Directive 2003/87/EC consolidated to 1 March 2024
Accessed 2026-08-12 · Adopted EU law
Boundary: Official legal text; operative schedule kept separate from proposals.
S-023
Commission Implementing Regulation (EU) 2025/2620
Accessed 2026-08-12 · Adopted EU law
Boundary: Official legal text.
S-024
COM(2026)616 — ETS revision proposal
Accessed 2026-08-12 · Official EU proposal — not law
Boundary: Proposed schedule is not merged into current law.
S-025
EUR-Lex procedure 2026/0212(COD)
Accessed 2026-08-12 · Official procedure record
Boundary: Volatile status; ongoing at the research cutoff.
S-027
Commission Implementing Regulation (EU) 2026/1740
Accessed 2026-08-12 · Adopted EU law
Boundary: Correcting act applies from 1 January 2026.
S-028
2017 Non-Ferrous Metals BAT Reference Document
Accessed 2026-08-12 · Historical Commission/JRC technical synthesis
Boundary: Reproduction authorised with source acknowledgement; 2008 input boundary retained.
S-029
Eurostat nrg_pc_205 — EU27 industrial electricity prices, band IG, 2025
Accessed 2026-08-12 · Official statistics
Boundary: Transformed Eurostat data; attribution, change notice and non-responsibility disclaimer apply.
S-030
Hydro direct records — HalZero and Slovalco
Accessed 2026-08-12 · Direct operator communications
Boundary: Dated company statements; not independent performance verification or a European census.
S-031
Constellium 2024 sustainability-report announcement
Accessed 2026-08-12 · Direct operator communication
Boundary: Company-reported demonstration event only.
S-032
Alcoa Q2 2026 results
Accessed 2026-08-12 · Direct operator / investor communication
Boundary: Dated completion statement; no site-output inference.
S-033
Speira Rheinwerk transformation records
Accessed 2026-08-12 · Direct operator communications
Boundary: Smelting status is separate from the continuing site.
S-034
European Commission Action Plan follow-up packet
Accessed 2026-08-12 · Official policy / operations records
Boundary: Action-by-action status; no global implementation verdict.
S-035
Eurostat copyright notice and free re-use of data
Accessed 2026-08-12 · Official reuse notice
Boundary: Commercial reuse permitted with attribution, change disclosure, Eurostat non-responsibility disclaimer, and listed exclusions.
Decision FAQs
What can I safely conclude from this report?
Does current aluminium CBAM include indirect electricity emissions?
For the listed aluminium goods in current Annex II, Article 7 requires direct emissions only to be calculated and taken into account. Keep that legal field separate from physical power exposure and lifecycle analysis.
How much primary aluminium does the EU currently produce?
This reviewed packet does not support one current EU27 primary-output total. PRODCOM product rows do not identify primary route, and the retained candidate values are not compatible enough to promote.
Can I use the electricity figures to estimate a smelter bill?
No. The historical technology ranges and the 2025 all-industry band-IG prices have different periods and populations. The price is not a smelter tariff or PPA.
Does 5% of mass and 24% of estimated emissions mean aluminium pays 24% of CBAM cost?
No. The 24% is a source-rounded share of unverified transitional default-based estimates over Q4 2023–Q2 2025. It is not certificate demand, liability or verified intensity.
Do net unwrought imports prove import dependence?
No. Dependence requires a compatible production/apparent-consumption denominator. Net flow alone does not close that denominator.
Do net scrap exports prove Europe has a scrap shortage?
No. Gross/net trade does not establish collection, composition, recovery, alloy suitability, domestic availability or secondary output.
Is a high TRL or test facility proof of commercial operation?
No. Maturity, commissioning, demonstration, construction, operation, capacity and realised output are separate status fields.
Did the Steel and Metals Action Plan deliver lower smelter power prices?
The packet records publication of network-charge guidance, not Member-State implementation or aluminium-specific price outcomes.
Where should an importer start?
Use the aluminium sector page for scope, then the dedicated importer guide for supplier data, threshold and cost preparation. This flagship is context, not a company determination.