The advancement of the EU Carbon Border Adjustment Mechanism (CBAM, commonly known as "carbon tariff") has established a new green trade benchmark for global aluminum products exported to the EU.
As a key EU policy to balance carbon costs of domestic and foreign products and prevent "carbon leakage", CBAM has gradually become a crucial factor affecting the international trade of aluminum products since the launch of its transition period.
The revised proposal issued by the EU in 2025 has provided enterprises with more flexibility in compliance through adjustments including "exemption + simplification + extension".
For Chinese aluminum product exporters, grasping the core requirements and response directions of CBAM is an important prerequisite for successfully entering the EU market.
I. Core Simplified Points of the New CBAM Rules
The 2025 revised CBAM proposal focuses on reducing enterprises' compliance burden, with core adjustments guided by "convenience and simplification", mainly covering three aspects:
1. Exemption Policy for Small and Medium-Sized Trade Entities
The new rules establish an exemption mechanism for trade scenarios with low annual import volumes. Eligible EU importers and corresponding exporters can be exempted from some CBAM compliance processes, without the need to conduct additional complex operations such as authorization applications and carbon emission declarations, effectively reducing the compliance pressure on micro, small and medium-sized enterprises.
2. Optimization of Compliance Timelines and Pricing
To allow enterprises sufficient preparation time, relevant CBAM compliance timelines have been postponed, reducing the risk of hasty responses by enterprises.
At the same time, the certificate pricing method has been adjusted to a more stable periodic average price calculation, reducing the impact of short-term price fluctuations on enterprise budget planning and improving the predictability of compliance costs.
3. More Flexible Carbon Emission Accounting
Enterprises can independently choose actual emission data or reference standards provided by the EU for carbon emission accounting, without being restricted to a single accounting method.
For products such as aluminum products, emissions from some downstream processing links are not included in the accounting scope, and emissions from precursor materials produced in compliance within the EU can be deducted in accordance with relevant rules, further simplifying the accounting process.
II. Main Impacts of CBAM on Aluminum Products Export
The core of CBAM is to incorporate carbon emission costs into trade considerations, and its impacts on aluminum products export focus on two aspects: carbon costs and compliance requirements:
1. Carbon Costs Become a New Export Consideration
Direct emissions and indirect emissions exist in the electrolytic aluminum production process, among which electricity-related indirect emissions account for a relatively high proportion.
Although CBAM does not fully cover all emission types at present, with policy advancement, carbon emission costs will gradually become an important cost component of aluminum products exported to the EU, and aluminum products produced with green electricity will have greater market advantages.
2. Compliance Requirements Run Through the Entire Trade Process
Enterprises need to pay attention to carbon data management throughout the entire export process, from emission recording in the production link to information submission in export declaration, all of which must comply with relevant EU requirements.
In the future, as free quotas are gradually reduced and carbon prices show an overall upward trend, enterprises' compliance costs and management pressure may gradually increase.
III. Main Trends of CBAM's Future Development
CBAM is an important part of the EU green trade system, and its policy direction will continue to be optimized and improved, mainly showing three trends:
1. Applicable Scope May Gradually Expand
The EU is considering extending the control scope of CBAM to downstream derivatives of basic products such as aluminum products, which means more related industries relying on aluminum raw materials may need to meet CBAM compliance requirements in the future.
2. Supervision Intensity Continues to Strengthen
To prevent compliance evasion, the EU will further clarify declaration information requirements, and may require enterprises to provide more basic information related to product production to ensure the authenticity and effectiveness of compliance.
3. Long-Term Compliance Standards Tend to Be Stricter
With the advancement of global low-carbon transformation, the proportion of CBAM free quotas will gradually decrease, and the proportion of carbon cost sharing will continue to increase, putting forward higher requirements for enterprises' carbon emission control capabilities.
IV. Basic Response Directions for Aluminum Product Enterprises' CBAM Compliance
Faced with CBAM policy requirements, enterprises can build compliance capabilities at the basic level, focusing on three aspects:
1. Standardize Carbon Data Management
Establish a basic carbon data recording system, accurately count information related to exported products, and confirm whether cooperating EU importers meet exemption conditions.
Prioritize the use of officially recognized data standards and accounting methods to avoid compliance risks caused by non-standard data.
2. Explore Low-Carbon Transformation Paths
Gradually promote low-carbon optimization in the production link, such as rational layout of green electricity use and increasing the application ratio of recycled aluminum, to reduce product carbon emission intensity from the source and enhance market competitiveness.
3. Strengthen Supply Chain Collaboration
Establish communication and collaboration mechanisms with upstream raw material and electricity suppliers, clarify relevant requirements for carbon data provision, ensure that carbon information in all links of the supply chain is traceable and verifiable, and provide basic support for compliance declaration.
Helping Enterprises Efficiently Respond to CBAM Compliance
Faced with CBAM's policy requirements and compliance challenges, based on its understanding of EU green trade rules, SKYCO2 provides targeted compliance support for aluminum product exporters: assisting in building basic carbon data management systems, interpreting core policy requirements, guiding compliance declaration processes, and linking supply chains to optimize carbon information transmission, helping enterprises smoothly access the EU market.
If your enterprise is involved in aluminum product exports to the EU and is struggling with CBAM compliance planning, please feel free to contact SKYCO2. We will tailor a concise and efficient compliance plan to help you seize EU green trade opportunities.