The European Commission’s latest Q&A addresses how embedded emissions should be calculated when a complex good uses the same precursor from multiple installations. It states that a weighted-average embedded-emissions value is the standard approach. A producer can use data from a single installation or a subset only if it can provide sufficient evidence that the relevant precursors were used in the production process.
Weighted-average embedded emissions and evidence requirements
The guidance means producers need documentation that links precursor inputs to the production process. Where multiple installations supply the same precursor, emissions values are expected to be averaged unless evidence supports a narrower data basis. This approach affects how embedded emissions figures are compiled for goods covered by CBAM calculations.
For aluminium processors, the traceability requirement increases operational relevance. The source materials note that primary aluminium, recycled billet and low-carbon aluminium produced using hydroelectric power may be interchangeable in some applications but can have significantly different emissions profiles. Pooling such inputs without a defensible record of origin and use can dilute any emissions advantage in the CBAM calculation.
Downstream scope proposal targets aluminium-intensive finished goods
The traceability issue is gaining prominence alongside the European Commission’s downstream proposal, file 2025/0419(COD). The proposal seeks to bring selected aluminium-intensive finished goods within the Carbon Border Adjustment Mechanism from 2028. The European Parliament adopted its position in September and broadened parts of the proposed scope.
The final list of products remains subject to negotiations with the Council of the European Union. The expansion is described as a legislative proposal rather than current law. If adopted, fabricators would need to preserve precursor emissions information across multiple stages of production.
Data handling expands beyond smelters into processing stages
The changes described in the proposal would extend CBAM-related data management beyond smelters. The source specifies that additional stages include extrusion, rolling, machining and assembly supply chains. This implies that upstream input records would need to be maintained through downstream manufacturing steps.
For manufacturers in Southeast Europe supplying EU automotive, construction and industrial customers, preparations could start before any changes take effect. The source highlights that enterprise resource planning and warehouse systems would need to link incoming aluminium to specific production batches where supplier-specific emissions data has commercial value. It also notes that EU customers may introduce carbon-data clauses into long-term supply contracts ahead of the proposed start date.
Supplier-specific emissions documentation affects commercial positioning
The commercial value of low-emission aluminium is described as depending on both the metal’s emissions intensity and whether its origin and use can be demonstrated through relevant production stages. As downstream CBAM negotiations progress, preserving reliable precursor data could become a differentiator for aluminium fabricators supplying the EU market.