CBAM Pulse
Official dataEuropean aluminium · Evidence brief

European Aluminium Under CBAM: Power, Carbon and Import Dependence

Europe’s aluminium position is shaped by concentrated unwrought imports, power-intensive primary production and a scrap stream that does not translate cleanly into available secondary supply.

6.33 Mt
2025 unwrought imports
81.2%
Top-ten origin share
621,048 t
2025 net scrap exports
Direct only
Current CBAM boundary

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.

  1. 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

  2. 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

  3. 03

    Power matters without yielding a plant bill

    Historical smelting ranges and 2025 large-industrial electricity-price context have different periods and populations; multiplying them would manufacture a plant cost.S-028S-029

  4. 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

  5. 05

    Maturity, project status and policy delivery are separate

    A TRL, commissioned test facility, announced pilot, adopted methodology, auction award or legislative proposal each answers a different question.S-002S-030S-034

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 →
QuestionOwnerTreatment here
Which aluminium CN code is covered?Sector page / goods checkerStage summary and link only.
What supplier data and cost inputs are needed?Importer guideEvidence boundary, not checklist duplication.
What did the full Transitional Registry show?CBAM by the NumbersOne aluminium-specific bounded callout.
How do I test threshold or cost?Threshold checker / cost calculatorNo 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.

  1. 01

    Ore / concentrate

    CN 26060000 trade

  2. 02

    Aluminium oxide

    CN 28182000 trade + PRODCOM product

  3. 03

    Primary / unwrought

    CN 7601 trade; unwrought PRODCOM products

  4. 04

    Semi-finished / products

    Separate PRODCOM categories

Separate return laneWaste and scrap (CN 7602) → sorting / remelting → route- and alloy-specific use

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 codeShort source labelActual production, tFlag
24421130Unwrought non-alloy aluminium618,341.697
24421154Unwrought aluminium alloys6,642,252.281
24421200Aluminium oxide2,478,608.349
24422100Aluminium powders and flakes60,993.283
24422230Non-alloy bars, rods and profiles509,368.700
24422250Alloy bars, rods and profiles3,208,122.295
24422330Non-alloy wire93,216.904
24422350Alloy wire172,073.004
24422430Non-alloy plate, sheet and strip >0.2 mm448,632.014
24422450Alloy plate, sheet and strip >0.2 mm5,282,176.101
24422500Aluminium foil ≤0.2 mm1,396,424.419
24422630Non-alloy tubes and pipes13,873.487
24422650Alloy tubes and pipes114,375.883
24422670Tube or pipe fittings17,438.795
38212500Secondary raw materials of aluminium2,221,713.589: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 / technologyMWh/t Al
Electrolysis-specific · point-feed prebaked13.2–15.0
Electrolysis-specific · Søderberg14.5–17.0
Total electrical power · point-feed prebaked13.6–15.7
Total electrical power · Søderberg15.1–17.5

2025 EU27 industrial electricity context

Scroll table →
PeriodEUR/kWhEUR/MWh
January–June 20250.1026102.6
July–December 20250.099899.8

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 codeStage lensGross importsGross exportsImports − exportsDirection
26060000Aluminium ores and concentratesOre/concentrate trade; not contained aluminium or domestic bauxite consumption.10,693,654.66117,868.94810,675,785.713net imports
28182000Aluminium oxide (excluding artificial corundum)Aluminium-oxide trade; not smelter-grade alumina only or refinery output.834,083.1461,773,448.214-939,365.068net exports
7601Unwrought aluminiumBounded unwrought-product lens; not primary route or all aluminium.6,334,671.095350,007.9715,984,663.124net imports
7602Aluminium waste and scrapWaste/scrap trade; no composition, quality, recoverability or secondary-output measure.652,349.6881,273,397.351-621,047.663net 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.

Norway21.2%
Iceland11.7%
Canada9.4%
Mozambique9.1%
Bahrain7.5%
United Arab Emirates7.2%
Russia4.8%
India3.9%
United Kingdom3.5%
South Africa3.1%
Other country or territory rows18.7%
Not specified0.0%
Accessible source tableOpen data
Origin rowRow typeNet mass, tShare
Norwaycountry or territory1,340,664.87421.2%
Icelandcountry or territory741,969.64611.7%
Canadacountry or territory593,055.7819.4%
Mozambiquecountry or territory573,813.7619.1%
Bahraincountry or territory476,112.5907.5%
United Arab Emiratescountry or territory454,313.6327.2%
Russiacountry or territory303,085.2824.8%
Indiacountry or territory247,621.4323.9%
United Kingdomcountry or territory218,727.9233.5%
South Africacountry or territory196,244.2433.1%
Other country or territory rowscountry or territory1,186,495.21618.7%
Not specifiednot specified2,566.7150.0%
EU27 extra-EU aggregate6,334,671.095100.0%

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

  1. 1
    Switzerland24.3%
    158,719 t
  2. 2
    United Kingdom17.4%
    113,738 t
  3. 3
    Norway7.1%
    46,146 t
  4. 4
    Türkiye5.2%
    34,172 t
  5. 5
    Israel5.0%
    32,887 t

Leading export destinations

Last known country of destination for extra-EU exports

  1. 1
    India30.0%
    382,502 t
  2. 2
    Thailand11.7%
    149,163 t
  3. 3
    China9.9%
    126,585 t
  4. 4
    Hong Kong8.4%
    106,705 t
  5. 5
    Pakistan8.2%
    103,822 t
Accessible source tableOpen data
FlowPartner semanticsGross mass, tBoundary
ImportsCountry of origin652,349.688Not a domestic-availability measure
ExportsLast known destination1,273,397.351Not 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 →
InterventionStageJRC maturityNative evidenceBoundary
Inert anodesPrimary smelting / electrolysisTRL 4–5EUR 110–120/t Al estimated competing anode priceNot a retrofit cost, realised market price, measured abatement or deployment result.
Inert-anode retrofit illustrationExisting electrolysis cellsTRL 4–5EUR 1–2m capital cost per cell replacementIllustrative source-wide arithmetic, not a project budget or comparable abatement cost.
Hydrogen co-feeding / calcination heatAlumina refiningGeneral TRL 7–9; aluminium calcination 5–6EUR 3–5/kg renewable hydrogenHydrogen input cost is not an aluminium abatement cost or evidence of availability.
Hydrogen as reducing agentAlternative primary-metal conceptLaboratory tests; no proof of conceptNot reportedLaboratory work does not establish feasibility, cost or operation.
Absorption-based CCUSRefining and primary smeltingAluminium-specific TRL 3–4EUR 50–80/t CO₂ refinery; EUR 180–300/t CO₂ smelterUnlike flue-gas conditions; excludes transport, storage and energy penalties.
Direct electrificationAlumina heat and steamTechnology-specific; no aggregate TRL70% contextual fossil-fuel share used for steamCited context, not an EU observation or measured benefit.
Induction electrificationCasting / remelting heatWell-understood; no TRL reported37% / 50% source comparisons against named gas-furnace baselinesNot an EU fleet average, universal baseline or emissions result.
Waste-heat recoveryPrimary smeltingTRL 7–930–45% of smelting heat reported as waste heatWaste-heat share is not recoverable energy or measured savings.
Fluidised-bed calcinersAlumina calcinationTRL 9Up to 30–35% source-reported energy/cost reductionTechnology potential is not a guaranteed or fleet-average saving.
Electric boilersLow/mid-temperature heatTRL 4–5Not reportedNo aluminium-wide cost, abatement or deployment population.
Mechanical vapour recompressionAlumina digestion steamTRL 7–8Not reportedPilot citation is not European commercial deployment or measured performance.
Lower-temperature electrolysisPrimary smeltingTRL 7–81–1.5 MWh/t theoretical reductionTheoretical 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 →
ProjectDateControlled categoryExact statusDo not infer
Hydro HalZero test facility2026-Q1demonstrated/pilottest facility commissionedNot commercial aluminium production, proven full-process performance or measured abatement.
Hydro HalZero industrial concept pilotPage updated 8 January 2026announcedconstruction aim toward the end of the decadeNot under construction, funded, operating or commercially deployed.
Constellium hydrogen-fired slab castingJuly 2024demonstrated/pilot12-tonne slab demonstrated at C-TECNot 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 →
ActionAnnouncedObservedStatusLegal / operational meaningDo not infer
PA-01Clean Industrial Deal State Aid FrameworkQ2 202525 June 2025Adopted within announced quarterCommission framework enabling qualifying Member-State schemes.No proof that an aluminium project received aid.
PA-02Future-proof network-charge guidanceQ2 20252 July / July 2025Published after announced quarterCommission guidance; national regulators retain tariff-design roles.No aluminium-specific tariff, price reduction or Member-State implementation.
PA-03Low-carbon hydrogen methodologyComing weeks from 19 March8 July 2025Adopted after programme announcementAdopted methodology for low-carbon hydrogen and fuels.No proof of hydrogen availability, price, aluminium uptake or project savings.
PA-04Third European Hydrogen Bank callQ3 20254 Dec 2025–19 Feb 2026Opened later; awards reportedAuction awards reported; grant agreements still expected on the retained page.No aluminium award, production or signed-grant inference.
PA-05Export-carbon-leakage optionsQ2 20252 July 2025Communication after announced quarterCommission considered options and stated an intention for a proposal.No adopted compensation scheme or exporter entitlement.
PA-06Downstream CBAM / anti-circumventionQ4 202517 December 2025; checked 12 Aug 2026Proposal delivered; procedure ongoingLegislative proposal, not current law.No adopted downstream scope, scrap treatment or date.
PA-07Metal-scrap availability measuresBy Q3 2025Bounded audit to 12 Aug 2026No positive follow-up admittedUnresolved 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.

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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.

  1. 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.
  2. Atomise: every retained claim carries source IDs, locator, evidence class, limitation, prohibited inference and canonical owner.
  3. Separate: stage, route, capacity, output, direct/power/lifecycle emissions, gross/net trade, proposal/law and announcement/operation never collapse into one field.
  4. Fail closed: unsupported or commercially blocked values remain Held — not claimed; removed canonical duplication remains visible in the audit trail.
  5. 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-001

Current Annex I lists aluminium under CN 7601, 7603–7614 and 7616; exact goods discovery remains with the sector page and goods checker.

Adopted law
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-002

Current 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
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-003

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.

Adopted law
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-004

Current ETS law and the CBAM free-allocation adjustment apply the operative CBAM-factor path through 2034, with actual/default evidence handled separately.

Adopted law
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-005

COM(2025)989 proposes downstream aluminium scope and pre-consumer-scrap treatment from 2028; procedure 2025/0419(COD) was ongoing at cutoff.

Proposal — not law
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-006

COM(2026)616 proposes a different CBAM-factor path and conditional additional free allocation; procedure 2026/0212(COD) was ongoing at cutoff.

Proposal — not law
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-007

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.

Official data
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-008

The 24% displayed aluminium emissions share reconciles at source precision: 81 / 343 = 23.615%, rounded to 24%.

Institutional synthesis
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-009

PRODCOM reports 2025 EU27 output of 618,341.697 t unwrought non-alloy aluminium and 6,642,252.281 t unwrought aluminium alloys.

Official data
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-010

No compatible admitted source establishes current EU27 primary-aluminium output.

Held — not claimed
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-011

No compatible admitted source establishes current European recycled or secondary aluminium-metal output.

Held — not claimed
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-012

The Commission described roughly half of EU primary-production capacity as inactive since 2021 in March 2025.

Institutional synthesis
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-013

No defensible same-route output-and-capacity time series is available from the admitted records.

Held — not claimed
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-014

The 2025 PRODCOM packet provides 15 exact aluminium product-output categories with official labels, units and flags.

Official data
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-015

Member-State unwrought rows do not fully allocate the EU aggregate where confidentiality, unavailable values, estimates and rounding intervene.

Official data
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-016

Four direct-operator records support a bounded event history for Slovalco, Rheinwerk and San Ciprián using controlled status categories.

Direct operator statement
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-017

No publishable quantitative power/process/thermal emissions split is admitted.

Held — not claimed
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-018

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.

Institutional synthesis
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-019

No publishable quantitative split separates refinery fuel, smelting electricity and anode/PFC emissions across a compatible population.

Held — not claimed
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-020

No method-complete European primary-aluminium intensity is admitted for publication.

Held — not claimed
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-021

No compatible European/global intensity pair is admitted for a ranking or ratio.

Held — not claimed
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-022

JRC technical synthesis states that the secondary route uses about 5% of the energy required for primary aluminium.

Institutional synthesis
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-023

JRC distinguishes inert-anode, refinery-CCUS and smelting-power emissions boundaries rather than treating them as one intervention.

Institutional synthesis
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-024

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.

Official data
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-025

EU27 extra-EU CN 7601 trade in 2025 recorded 6,334,671.095 t gross imports and 350,007.971 t gross exports.

Official data
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-026

The ten largest country-of-origin rows represented 81.2293% of 2025 CN 7601 extra-EU import mass.

Official data
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-027

Import reliance requires net imports divided by compatible apparent consumption; the 2025 packet lacks the matching production denominator.

Institutional synthesis
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-028

For CN 7601, 2025 gross imports minus gross exports equal 5,984,663.124 t derived net imports.

Official data
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-029

Separate 2025 trade slices show net imports of bauxite/ore, net exports of aluminium oxide and net exports of aluminium waste/scrap.

Official data
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-030

A wider Chapter 76 scope crosswalk was removed because exact scope and code checking have canonical owners elsewhere.

Removed
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-031

A historical EU28 material-flow model provides 2013 flow and recycling definitions, not current EU27 observations.

Institutional synthesis
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-032

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.

Official data
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-033

JRC distinguishes tighter wrought-alloy scrap constraints from more impurity-tolerant casting-alloy routes.

Institutional synthesis
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-034

JRC circular-economy results are model scenarios: BSL50 101, CTC50 98 and ACE50 87 MtCO₂e/year for the entire modelled system.

Institutional synthesis
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-035

The JRC technology matrix preserves unlike maturity and native-unit evidence instead of manufacturing one cost or technology ranking.

Institutional synthesis
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-036

Three direct-source exemplars separate a commissioned test facility, a planned pilot and a demonstrated 12-tonne hydrogen-cast slab.

Direct operator statement
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-037

A seven-row official audit records Action Plan follow-up action by action rather than assigning one implementation verdict.

Institutional synthesis
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-038

Seven bounded operator decisions classify numbers, refuse incompatible comparisons, separate aggregates from installations and route execution to canonical tools.

Institutional synthesis
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-007

Eurostat PRODCOM database

Accessed 2026-08-12 · Official statistics

Boundary: Transformed Eurostat data; attribution, change notice and non-responsibility disclaimer apply.

S-032

Alcoa Q2 2026 results

Accessed 2026-08-12 · Direct operator / investor communication

Boundary: Dated completion statement; no site-output inference.

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.