The European Commission’s latest guidance says aluminium produced in 2025 but released for free circulation in the European Union during 2026 falls under the Carbon Border Adjustment Mechanism (CBAM). The guidance links the applicable treatment to the customs release timing rather than production alone.
For imports in 2026, the legally applicable reporting period is 2026. It also states that production data from earlier periods cannot be automatically used as CBAM-verified actual emissions, because accredited CBAM verification was not available for those historical production periods.
Reporting period and customs release under CBAM
The Commission’s guidance explains that late-2025 inventories could fall outside the definitive regime only if the goods were released for free circulation before the new applicability. Producing, selling or shipping metal before the end of 2025 was not sufficient when release occurred in 2026.
This distinction is tied to how customs events align with CBAM reporting requirements. It also clarifies why the relevant customs timing could determine whether inventories were treated within the definitive framework.
Front-loaded shipments before 1 January 2026
The clarification provides context for exceptional aluminium and hot-rolled coil trade flows ahead of the definitive CBAM regime. Fastmarkets estimated that front-loading cleared about EUR 820 million in potential CBAM liabilities before 1 January 2026.
Trade data showed shipments rising sharply in late 2025, followed by a pronounced reversal in early 2026. The guidance indicates that the impact of these inventory strategies depended on whether the relevant customs event occurred before the regime became applicable.
Bonded inventories and suspensive customs procedures
Customs status is presented as a factor for traders managing carbon costs. Aluminium held in a bonded warehouse, placed under a suspensive customs procedure, or awaiting release for free circulation may receive different CBAM treatment than stock that has already cleared EU customs.
The same customs distinction can affect inventory planning beyond 2026. As the adjustment for free allocation declines towards 2034, the effective CBAM burden increases, which may influence how import timing is managed around future increases in exposure.
The guidance notes that strategies are limited by customs requirements, anti-circumvention rules, financing costs and available storage capacity. These constraints apply to how firms can time imports and manage inventory positions.
Working capital considerations for bank-financed inventories
The customs-date rule also affects banks financing metal inventories. Stock financed before customs clearance may involve an uncertain future carbon liability, while inventories already released for free circulation have an established regulatory status under applicable rules.
Working-capital models are therefore expected to distinguish inventories based on their legal customs position. The guidance says this approach should not rely solely on physical location or production date when assessing carbon-cost exposure.