Aluminium CBAM: one smelter's
late XML blocks every supplier.
Each non-EU smelter and re-roller must supply schema-valid emissions data, including the indirect electricity load primary aluminium carries.
What the XML must contain
Default-value exposure
What default values mean for an aluminium declaration.
Where a smelter, re-melter or rolling mill cannot evidence actual embedded emissions, the declaration falls back to the default values published for the goods' country of origin. Those defaults carry a statutory mark-up of +10% in 2026, applied to the embedded emissions declared, not charged as a fixed fee.
Certificates are surrendered against the declared emissions after the free-allocation adjustment, which phases in from 2026. What that costs turns on the origin-specific default value for each CN code, the production route behind it (including the origin grid supplying the smelter) and the certificate price published for the quarter, currently €75.28 per tCO₂e for Q2 2026. Collecting actual supplier data removes the mark-up. Default emission values are origin-specific per the Annex to Regulation (EU) 2025/2621; CBAM scope per Annex I to Regulation (EU) 2023/956.
How Carbon Mandate solves it
One dashboard for every aluminium supplier on your declaration.
Frequently asked
Aluminium CBAM, answered.
Why is CBAM harder for aluminium importers than for other goods?
Aluminium is sourced from primary smelters, secondary re-melters, extruders and rolling mills across several origin countries, and each non-EU installation must supply schema-valid embedded-emissions data before the annual declaration can be filed. Primary aluminium carries a heavy indirect (electricity) emissions load that varies by origin grid, so the production route and country matter to every line. A single rejected or late XML from one supplier holds up the whole declaration set. The coordination load — not any one calculation — is the hard part.
What happens if an aluminium supplier cannot provide actual emissions data?
Where actual data is unavailable, the declaration falls back to default values, which carry a phased markup: +10% in 2026. On an illustrative primary-aluminium embedded factor of 6.720 tCO₂e per tonne, that uplift is paid in certificates. Because aluminium's embedded factor is high, the exposure is larger per tonne than for most CBAM goods. Collecting actual supplier data, including the route's electricity emissions, removes the markup.
Does Carbon Mandate file my CBAM declaration with the EU Registry?
No. Carbon Mandate is a preparer, not a filer. We check every incoming supplier XML against the EU CBAM schema, coordinate the supplier pipeline, and hand your filing team an audit-ready evidence pack. You remain the declarant of record and file with the EU Registry yourself.