EU aluminium import data show exemptions and product scope complicate CBAM shares

Assessing the trade effects of the EU’s Carbon Border Adjustment Mechanism (CBAM) for aluminium is complicated by differences in how imports are treated by origin and product coverage. Some major trading partners benefit from origin-based exemptions, while others supply a range of aluminium products where customs values alone do not indicate embedded emissions. This affects how market-share rankings can be interpreted for potential certificate liabilities.

Eurostat reported that EU imports of aluminium and articles thereof under HS Chapter 76 reached €29.5 billion in 2024, against exports of €18.4 billion. The resulting trade deficit was €11.1 billion. The figures cover a broad range of aluminium products rather than only goods classified under CBAM’s specific product codes, but they show the EU’s reliance on imported metal and fabricated items.

EU import partner shares under HS Chapter 76

On an import-value basis for 2024, Norway was the largest supplier with €4.4 billion, or 15.0% of the total. China followed with €3.9 billion (13.1%), Türkiye with €2.8 billion (9.4%), Iceland with €2.1 billion (7.3%), and Switzerland with €1.7 billion (5.8%). Together, these five countries accounted for about 50.6% of the import value recorded under Chapter 76.

Eurostat’s partner shares are based on trade value rather than physical volumes, and they do not directly measure the market’s CBAM exposure in 2026. The relevance for certificate liabilities depends on whether imported goods meet the conditions for exemption and which product categories fall within CBAM coverage.

Origin-based exemptions and legally established non-preferential status

Goods originating in Norway, Iceland, Liechtenstein and Switzerland are exempt from CBAM under applicable EU rules, reflecting their relevant emissions-trading arrangements. As a result, import shares for Norway, Iceland and Switzerland can carry different implications for potential certificate liabilities than shares for China or Türkiye.

The exemption depends on legally established non-preferential origin rather than routing alone. Simply moving goods through an exempt territory does not automatically confer exempt status under the applicable rules.

CN classification and downstream product coverage

Product classification is also central to analysis beyond aggregate HS Chapter 76 figures. CN 76011010 covers slabs of unwrought non-alloy aluminium, CN 76011090 covers other unwrought non-alloy aluminium, and CN 76012080 covers certain unwrought aluminium alloys.

Downstream products require separate classification and production-route assessments, including sheet, foil, extrusions and other fabricated articles. Certain scrap categories are excluded or treated differently, particularly under proposed reforms.

Import value changes versus physical volume changes

Eurostat compared 2019 and 2024 and found that the value of EU aluminium imports rose by 29.9% while physical weight fell by 6.2%. This divergence indicates that higher customs values cannot be treated as equivalent to higher imported tonnage.

Multiple factors can raise aggregate import values without increasing physical volumes, including global aluminium prices, product composition, exchange rates and trading conditions. Customs unit values expressed in euros per tonne are therefore meaningful only when calculated for sufficiently comparable product categories.

Limits of monthly tracking without matched CN8 data

Eurostat’s general merchandise-trade release dated October 16, 2026 covered August extra-EU imports but did not include the detailed aluminium country-share matrix needed to track the sector’s latest monthly movements. A more robust approach would compare August 2026 with both July 2026 and August 2025 using the same CN8 product selection across periods.

Country-level shares should be calculated separately by physical weight and customs value, while implied customs unit prices should be assessed for differences in grade and product composition. Without matched CN8 data, monthly changes in aluminium import shares cannot be established reliably from aggregate trade figures.

CBAM certificate pricing for covered origins

For imports from covered origins, the published CBAM certificate price for the third quarter of 2026 was €82.32 per tonne of CO₂ equivalent. A supplier’s overall cost position also depends on embedded emissions in the goods and any free-allocation adjustment that applies.

Any qualifying carbon price paid in the country of origin also affects competitiveness relative to invoice pricing. A supplier with lower verified emissions may offer a more competitive overall position even if it charges a higher invoice price, provided comparisons concern equivalent goods and comparable production conditions.

Proposed downstream expansion beyond current scope

The EU’s proposed expansion of CBAM to additional downstream products in 2028 is still under negotiation. The European Parliament has supported lowering the aluminium threshold from 50 tonnes to five tonnes and widening the scope of coverage, while other institutions have advanced their own positions.

The final provisions will determine which fabricated aluminium products become subject to additional compliance obligations. Assessments therefore need to examine relevant CN classifications against both the existing framework and proposed amendments before estimating what share of the market could become newly exposed.

Partner structure shows why headline statistics are insufficient

Eurostat’s 2024 partner structure illustrates how exemption status can differ from headline origin shares: Norway, Iceland and Switzerland together represented 28.1% of HS Chapter 76 import value. This does not establish that 28.1% of CBAM-covered aluminium imports are exempt because Chapter 76 includes products outside precise CBAM scope and legally determined origin may vary between transactions.

The same data limitations apply when comparing periods: higher customs values alongside lower physical weight signal changes in prices or product mix but do not distinguish between global aluminium price movements and shifts toward higher-value fabricated products. A more useful analysis would examine unwrought grades, sheet, extrusions and structures separately using comparable periods and partner-country profiles.

This creates a more differentiated supplier landscape for buyers in Germany, Italy and Austria, as well as exporters in Serbia and the wider Western Balkans. Relevant distinctions include exempt origin status, verified low-carbon production versus higher-emission covered production, and downstream products whose future CBAM status remains uncertain.

The broad-market statistics establish dependence on imported aluminium products but do not show whether CBAM has already redistributed aluminium market shares across partners or product types. Demonstrating such an effect requires product-level trade data combined with verified emissions information and a clear separation between current obligations and proposed future coverage.

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