European aluminium importers can face two carbon-related cost sources within a single shipment: the Carbon Border Adjustment Mechanism (CBAM) liability tied to embedded emissions and carbon costs linked to maritime transport under the EU Emissions Trading System (EU ETS). The obligations cover different activities, but both can influence how movements in the European carbon market affect the delivered cost of imported metal.
EU ETS coverage for maritime voyages
The EU ETS has covered maritime transport since 2024. For ships within the system’s scope, shipping companies account for 50% of emissions from voyages between an EU port and a non-EU port. For voyages between EU ports, 100% of emissions occurring within EU ports are covered.
Starting in 2026, the maritime ETS framework will include methane and nitrous oxide in addition to carbon dioxide. This expands the set of greenhouse gases addressed under the maritime component of the system.
Two cost channels linked to EUA prices
For aluminium buyers, maritime ETS requirements create a freight-related carbon exposure alongside CBAM costs associated with the metal’s embedded emissions. Although CBAM and maritime ETS impose separate legal obligations, their commercial outcomes can be connected through changes in the price of EU allowances (EUAs).
When EUA prices rise, an importer may see higher expected CBAM certificate costs while shipping companies may seek to recover increased maritime compliance expenses through freight charges. This can create a correlated exposure across two parts of an import transaction.
A company that hedges only the embedded emissions component of its aluminium but does not include the carbon element of ocean freight may underestimate its sensitivity to the EU carbon market. During periods of sharp EUA price increases, both border-related liability and shipping surcharges can move upward together, affecting the landed price of aluminium.
Freight contract terms and internal cost calculations
Importers are directed to review how maritime ETS costs are handled in freight agreements. Commercial arrangements can include whether any carbon charge is fixed, variable, passed through transparently, or incorporated into a bunker adjustment mechanism.
Companies should also check whether freight indices or all-in shipping rates already include an ETS-related surcharge. Without distinguishing these elements, carbon costs may be counted twice in internal landed-cost calculations.
Quantifying combined EUA sensitivity for aluminium imports
For large aluminium import programmes, a consolidated EUA sensitivity analysis can be used to quantify combined exposure across CBAM and maritime ETS-linked freight charges. The analysis can assess how a €10/tCO2 increase in allowance price affects both estimated CBAM liability and expected carbon-related freight surcharge.
The CBAM and maritime ETS remain separate regulatory mechanisms. Their interaction means shipping-related carbon costs can become a more significant factor in aluminium procurement, freight contracting, and treasury risk management.