CBAM for aluminium producers and exporters

Who it is for. Compliance, ESG and audit teams at producers outside the EU that make or process aluminium goods (CN 7601, 7603-7614, 7616) sold into the EU: primary smelters, secondary smelters (recyclers), extruders, rolling mills, foil and can makers, and fabricators.

What they can do at the end. Tell which of their products are in scope; draw their system boundaries; calculate verified-ready specific embedded emissions; get the right data from metal suppliers; set up PFC and CO2 monitoring; fill the Commission template; and explain to an EU buyer what their numbers mean in CBAM certificates compared with default values.

Legal basis. Definitive period (from 1 January 2026). Built on Regulation (EU) 2023/956 as amended by 2025/2083, the Methodology Act 2025/2547, the Default Values Act 2025/2621 as corrected by 2026/1740, the Verification Principles Act 2025/2546, Delegated Regulation 2025/2551, the Free Allocation Adjustment Act 2025/2620, and Commission Guidance 1-4 and 5e (14.08.2026). Citation keys: ../SOURCE-KEYS.md. Authoring rules: ../CONVENTIONS.md.

Total ≈ 4 h including quizzes. S1 → A1 → A2 → A3 are the minimum for anyone; A4 is essential for plants that buy metal; A5 for the person who will own monitoring; A6 is the capstone.

Suggested shortcuts by role (LatSpace note)

• Extruder / roller / fabricator buying metal: S1, A1, A2 §4-5, A3, A4, S2, A6 §7.
• Primary smelter: full path; A5 §4-6 (PFCs) is the core technical lesson.
• Secondary smelter: full path; skip A5 §4-6; focus on A2 §3 and the scrap parameters in A5 §8.
• Commercial / sales team: S1, A1, A3 §7, S2 §8, A6 §6.

Module summaries

• S1 CBAM basics. What CBAM is, the six sectors, exempt countries, transitional vs definitive period, roles (declarant, operator, verifier, authorities), the annual cycle (declaration and surrender by 30 September, certificate sales from 1 February 2027), the 50 t de minimis rule, operator registration in the registry.
• A1 Covered goods. Aluminium CN codes in scope; 7602 and 7615 out; two aggregated goods categories; simple vs complex; direct emissions only (Annex II); units; grouping rules; the December 2025 proposal to watch.
• A2 Routes and boundaries. Primary smelting (pre-baked/Søderberg), secondary melting, forming; what is inside and outside; plants doing only excluded steps; route-dependent benchmarks (K)/(L).
• A3 Embedded emissions. SEE formulas for simple and complex goods, activity level rules, scrap, rounding; aluminium default values by country with 10/20/30 % mark-ups.
• A4 Precursors. What counts as a precursor; data to collect; the verification condition; mixing actual and default; unknown-origin defaults; weighted averages; primary vs secondary metal.
• S2 Default vs actual. Legal routes, how defaults are built, the Default Values Act and its 2026 correction, look-up steps, decision guide, common mistakes.
• A5 Monitoring. Five source types; standard method for anodes and fuels; PFC slope and overvoltage methods, GWPs, fugitive emissions; monitoring plan; operator's emissions report; the three aluminium parameters.
• S3 Verification, carbon price, free allocation. Accredited verifiers, site visits, 5 % materiality, timing; carbon price deduction and evidence; SEFA formulas, CBAM factor phase-out, benchmarks.
• A6 Worked example. The Commission's two-process example from data to SEE, mapped to the template sheets; what the buyer receives; certificate estimate on actual vs default values.

Sidebar sources (for the app)

Sector: G5e (Guidance 5e, aluminium), CT-AL (template example, aluminium), FS-AL (producer factsheet — transitional period, flag as outdated), DV-XLS, BM-XLS. Shared: REG, MA, DVA-COR, VPA, AVA, FAA, G1-G4, QA, CT, O3CI. Language availability of each source is in cbam/sources/index.csv and SECTORS.md.

Open points and caveats

1. CSCF for 2026-2030 is in Implementing Decision (EU) 2026/1862, which is not in the library; A6 and S3 assume the preliminary 1,0 from Guidance 4. Download the decision and update the examples.
2. Communication template in the library is the 2024 version (transitional era); the aluminium example still shows indirect emissions. A6 and A5 flag this. Check for a definitive-period template version before launch.
3. Carbon price implementing act (Art 9) is not in the library; S3 says so.
4. Record keeping: REG Art 10(5)(c) says 4 years after verification; MA Annex II A.2 says at least 6 years after the reporting period. S1 advises 6 years.
5. Commission Q&A lists the quarterly certificate-holding check dates with "31 October"; the law says end of each quarter. S1 follows the law.
6. COM(2025) 989 (downstream goods, pre-consumer scrap) is a proposal; A1 and A4 present it as "watch", not law.
7. Translations: write after English review; legal terms should follow the official EU language versions of REG and MA (in cbam/sources/).

Template for the other five sectors

Copy this folder structure: 00-outline.md plus six sector modules (covered goods, routes, embedded emissions, precursors, monitoring, worked example/template), reuse S1-S3 unchanged, and follow CONVENTIONS.md. Electricity has no precursors and no template example, so its course has fewer sector modules.