Power traders supplying aluminium producers are increasingly expected to provide more than electricity. Industrial customers may seek one commercial arrangement covering physical power, renewable energy attributes, and evidence used for specific regulatory or customer claims. Each component is expected to keep a clearly defined purpose and value within the overall deal.
Contract structures for electricity, GoOs and verification services
Bundled supply arrangements can lower procurement complexity for aluminium smelters and fabricators. Contracts are still expected to separate the price paid for electricity from the cost of Guarantees of Origin (GoOs). They also need to distinguish any services related to metering, data management, or verification support.
This separation is intended to ensure that one contractual instrument is not used to substantiate a claim it cannot independently prove. Renewable attribute contracts should also prevent the same environmental claim from being sold more than once, including where a single generating project serves multiple industrial buyers. Power and GoO records can be reconciled to show allocation of electricity and its associated attributes.
Reconciliation can demonstrate how electricity and attributes are allocated, but ownership of a renewable attribute alone does not establish compliance with a specific CBAM electricity route. The allocation evidence therefore needs to be handled in line with the relevant CBAM methodology rather than treated as automatically equivalent.
Renewable electricity procurement and current CBAM liability
For iron-and-steel and aluminium goods listed in Annex II, the existing CBAM calculation takes account of direct emissions. Renewable electricity procurement can still provide operating, customer, financing, and decarbonisation value without automatically reducing current CBAM certificate liability through purchased-electricity emissions.
For an aluminium smelter or fabricator, an electricity contract can support operating-cost competitiveness and decarbonisation. The product’s CBAM calculation follows its applicable methodology, including when a trader supplies multiple production sites or separate legal entities within the same corporate group.
The same legislative file includes a proposed downstream expansion from 2028 for selected steel- and aluminium-intensive goods. The Council of the EU and the European Parliament both support extending coverage, but their proposed product lists differ and remain under negotiation. Until final legislation is adopted, the existing scope remains the operating baseline.
Evidence services, liability controls and low-carbon aluminium claims
Traders that provide repeatable evidence services may secure margins beyond commodity electricity pricing. Their offerings can combine energy procurement, attribute allocation, and organised data supporting customer or regulatory requirements.
Lenders and investors are expected to require clear liability caps and controls against double allocation. Contractual responsibilities should specify which party supplies underlying data, maintains allocation records, and supports each agreed claim.
Customer contracts for low-carbon aluminium are expected to define the precise commitment being purchased. A product-carbon-footprint claim, a renewable-electricity sourcing commitment, a maximum emissions threshold, and a disclosure requirement each require different supporting evidence. Different evidence packages may also justify different commercial premiums.
COM(2025) 989: proposed changes to electricity treatment under CBAM
A separate reform proposal, COM(2025) 989, would materially change electricity treatment under CBAM. The proposal includes changes to the methodology for electricity default values and aspects of conditions for using actual values.
The reform would also broaden physical power purchase agreements involving intermediaries. It would change the congestion and nomination framework used in relation to those arrangements.
The Council adopted its negotiating position on 12 June 2026, while the European Parliament adopted its position on 15 September 2026. The proposal remains under interinstitutional negotiation and should not be treated as enacted law.
In this context, suppliers to power-intensive aluminium producers are likely to combine energy-market services with environmental-attribute management and structured data support. Buyers are expected to separate electricity-cost competitiveness from process-carbon compliance when assessing transition measures based on demonstrable benefit.