CBAM ignores the smelter's electricity for aluminium, so a coal-powered and a hydro-powered profile declare the same figure. The product footprint is a different number.
For aluminium goods CBAM counts direct emissions only: the specific embedded emissions of an extrusion are the direct emissions of the extrusion process plus the unwrought aluminium consumed times its own direct specific embedded emissions, divided by the tonnes produced. An illustrative extruder using 31,500 tonnes of billet at 1.85 to make 30,000 tonnes of profiles declares 2.1925 tonnes of CO2e per tonne, and declares exactly the same whether its smelter runs on coal or on hydro power.
Worked in full in The CBAM Compliance Handbook by Julian R. Sterling, with every figure reproduced in a free workbook.See the book on Amazon →
Annex IV of Regulation (EU) 2023/956 defines the specific embedded emissions of a complex good as the attributed emissions of its production process plus the embedded emissions of the relevant precursors consumed, over the activity level. For an aluminium product the relevant precursor is unwrought aluminium. Aluminium is one of the categories, with iron and steel and hydrogen, for which only direct emissions are counted during the definitive period. Direct emissions here include the carbon dioxide from anode consumption and the perfluorocarbons released by the smelting cells, expressed in CO2 equivalent. The electricity that drives electrolysis, the largest source of emissions in primary aluminium, is not in the declared figure.
SEEproduct = (Directprocess + Unwrought consumed × SEEunwrought, direct) / Product output
Excel: =(DirectProcess+BilletUsed*BilletSEE)/Output
A fictional extruder outside the EU buys primary billet from a single smelter and ships part of its output of window and façade profiles to an EU importer. All figures are illustrative orders of magnitude, not published values.
| Input | Value |
|---|---|
| Profiles produced, tonnes | 30,000 |
| Billet consumed, tonnes | 31,500 |
| Smelter's direct SEE of the billet (anodes, PFCs, casthouse), tCO2e per tonne | 1.85 |
| Direct emissions of the extrusion process (gas-fired furnaces), tCO2e | 7,500 |
| Smelter electricity per tonne of billet, MWh (not counted) | 14.5 |
| Extruder electricity, MWh (not counted) | 30,000 |
| Profiles imported into the EU in the year, tonnes | 4,000 |
Step 1, the precursor. The extruder consumed 1.05 tonnes of billet per tonne of profile, a 5 per cent loss to butt ends, saw cuts and scrap. All of it counts: 31,500 × 1.85 = 58,275 tonnes.
Step 2, the process. Add the 7,500 tonnes of direct emissions from the billet heating and ageing furnaces. Nothing for electricity.
Total = 7,500 + 58,275 = 65,775 tCO2e
SEE = 65,775 / 30,000 = 2.1925 tCO2e per tonne
Declared on the import = 2.1925 × 4,000 = 8,770 tCO2e
The billet is 88.6 per cent of the figure; the extruder's own furnaces are 0.25 per tonne. At an illustrative 80 euros a certificate, the full exposure once free allocation has gone is 701,600 euros, 175.40 per tonne of profiles, before the free-allocation adjustment of the early years and any carbon price paid in the country of origin.
Run the same extruder with three different smelter power sources. The CBAM figure does not move. The product's footprint including electricity, the number a customer's sustainability team will ask for, moves by a factor of six. The footprint below adds only electricity to the direct figure; a full cradle-to-gate footprint would also include alumina refining and transport, so it is higher still.
| Smelter power | Factor, t per MWh | CBAM SEE | Footprint incl. electricity | CBAM share | Declared on 4,000 t |
|---|---|---|---|---|---|
| Hydro | 0.02 | 2.1925 | 2.52 | 87.1% | 8,770 |
| Gas | 0.45 | 2.1925 | 9.49 | 23.1% | 8,770 |
| Coal | 0.85 | 2.1925 | 15.98 | 13.7% | 8,770 |
On the coal route the smelter's electricity alone is 12.325 tonnes per tonne of billet, 413,738 tonnes for the extruder's year once its own power is included. CBAM prices none of it. For an importer choosing between suppliers, the CBAM cost points at anode technology and cell performance, not at the power source. Whether indirect emissions should be extended to more goods is a question the regulation leaves to later review, so a supply contract signed now should say which figure each party is providing.
| Billet direct SEE | Product SEE | Declared, tCO2e | Full exposure, EUR |
|---|---|---|---|
| 1.50, modern prebake cells | 1.8250 | 7,300 | 584,000 |
| 1.85, base case | 2.1925 | 8,770 | 701,600 |
| 2.50, older cells, more PFCs | 2.8750 | 11,500 | 920,000 |
| 4.00, illustrative default value | 4.4500 | 17,800 | 1,424,000 |
Each 0.10 on the billet moves the product by 0.105, 420 tonnes on the import, because the yield loss multiplies it. The last row is the one to fear: without the smelter's actual data the declaration falls back on a default value, which the Commission sets by implementing act from average emission intensities with a proportionate mark-up; the 4.00 in the table is illustrative, not the published value, and here it doubles the bill. The supplier data request is worth more than any other line in the file.
The quarterly cash profile, the certificate buffer and a blank model for your own imports are in the free workbook for this book; the same method for steel is worked in how to calculate CBAM embedded emissions for a steel product.
No. For aluminium, as for iron and steel and hydrogen, only direct emissions are counted during the definitive period, including perfluorocarbons from the smelting cells. In the worked case the extrusions declare 2.1925 tonnes per tonne whether the billet came from a coal-powered smelter, with a footprint including electricity of 15.98, or a hydro-powered one, at 2.52.
Not as it stands. A product footprint usually includes electricity and other upstream stages that CBAM does not count for aluminium. Declaring a coal-route footprint of 15.98 instead of the 2.1925 direct figure on a 4,000 tonne import overstates embedded emissions by 55,165 tonnes, 4,413,200 euros at an illustrative 80 euros once free allocation has gone.
Unwrought aluminium, such as the billet the extruder melts and presses. Its specific embedded emissions are carried into the product in proportion to the tonnes consumed, not the tonnes shipped. In the worked case 31,500 tonnes of billet make 30,000 tonnes of profiles, so each 0.10 on the billet SEE moves the product by 0.105.
This article is one calculation from The CBAM Compliance Handbook. The book takes the same case from first principles to the decision, chapter by chapter, and every figure it prints is a live formula in the free companion workbooks.
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