Aluminium

Your business imports aluminium as ingot for a foundry, billet for an extruder, extrusions for a window system, sheet for a fabricator, foil for a packer, or finished castings and fittings under the residual heading. The covered goods are 7601, unwrought aluminium; 7603, powders and flakes; 7604, bars, rods and profiles; 7605, wire; 7606, plates, sheets and strip over 0.2 mm; 7607, foil not over 0.2 mm; 7608, tubes and pipes; 7609, tube or pipe fittings; 7610, structures and parts of structures; 7611, containers over 300 litres; 7612, containers not over 300 litres; 7613, containers for compressed or liquefied gas; 7614, stranded wire and cables; and 7616, other articles of aluminium.

Two headings deserve a second look because the businesses that import under them do not think of themselves as aluminium importers. Heading 7610 covers structures and parts of structures, which the Schedule illustrates with bridges, towers, roofs, doors and windows and their frames, balustrades, pillars and columns, and heading 7616 is the residual heading for finished aluminium items with no more specific heading. A business that imports window systems, ladders, cast components or fasteners of aluminium should check the eight-digit code on its customs entries before concluding that it is outside the tax.

What is outside, and why scrap matters

HMRC's policy summary, which is guidance and not law, states that imported scrap products in the aluminium and iron and steel sectors will not be within scope from 1 January 2027, and the absence of 7602 from the Table is where that is given effect for aluminium. An importer of aluminium scrap for remelting therefore pays nothing on the scrap; an importer of the ingot that a remelter abroad makes from scrap pays on the ingot, at the remelter's verified intensity or the default value.

The system boundary

Table 1a of the System Boundaries Document maps heading 7601 to the category unwrought aluminium and every other covered heading to the category aluminium products. For both, the relevant gases are carbon dioxide and the perfluorocarbons tetrafluoromethane and hexafluoroethane, which regulation 8 of SI 2026/995 converts at 6,630 and 11,100 tonnes of carbon dioxide equivalent per tonne. A smelter's perfluorocarbon emissions arise in small mass from anode effects and can be a large part of its intensity, so an importer should make sure that the supplier's figure includes them.

Point 3.2 sets the boundary for unwrought aluminium by two routes. For primary electrolytic smelting, monitoring covers carbon dioxide from electrodes and electrode pastes, from fuels, and from flue gas treatment, together with the perfluorocarbons from anode effects; it has no precursors. For secondary melting from scrap, monitoring covers carbon dioxide from fuels used for drying and pre-heating, in melting furnaces, in the pre-treatment of scrap, for casting and in associated activities, and from flue gas treatment; unwrought aluminium from other sources is a precursor where it is added. Point 3.3 sets the boundary for aluminium products: carbon dioxide from fuels and from flue gas treatment across all processes linked to production, excluding cutting, welding and finishing, with unwrought aluminium and aluminium products as the precursors where used, and with primary and secondary aluminium treated separately where the data is known.

The document maps direct emissions only. The electricity that powers a primary smelter is outside the boundary, and no instrument read for this site brings emissions from purchased electricity into the tax. HM Treasury's factsheet, which is guidance, states that the inclusion of indirect emissions within scope will be delayed until 2029 at the earliest.

Where the figure comes from

The functional unit is tonnes of product under the same commodity code, and the source of the unwrought metal matters more than anything the product plant itself does. An extruder's own furnaces, presses and flue gas treatment are a small part of the intensity of a tonne of profile; the billet it bought carries the smelter's or the remelter's intensity into the product under step 5 of regulation 5 of SI 2026/995, and a primary billet will generally carry far more than a secondary one. An importer who wants to reduce the tax should look first at where the supplier's billet comes from, and a supplier who cannot say has left the precursor to the default value.

Regulation 4 of SI 2026/802 fixes the weight as net of packing at the time of import. Carbon price relief applies where the smelter or the product plant sits in a jurisdiction with a qualifying scheme and form CarbonVP1 can be obtained; where the unwrought aluminium came from a different jurisdiction, regulation 12(3) of SI 2026/809 requires a separate effective carbon price for the precursor.

Questions for an aluminium supplier

For a smelter: does the intensity include perfluorocarbons from anode effects and carbon dioxide from electrodes and electrode pastes. For a remelter: is unwrought aluminium from other sources added to the scrap charge, and is it counted as a precursor. For a product plant: is the billet or slab primary or secondary, is the unwrought precursor accounted for separately by source, and are cutting, welding and finishing excluded from the plant's own emissions. For any supplier: which commodity code does each product fall under, since 7604, 7606, 7608 and 7616 are separate types of good and each carries its own intensity. For every supplier in a jurisdiction with a carbon price: can form CarbonVP1 be completed for the installation and, where the unwrought aluminium came from elsewhere, for the smelter as well.

The check to run

Take the twelve months of customs declarations for chapter 76 goods, sort them by four-digit heading, and set against each heading whether it is one of the fourteen in the Table, which category Table 1a maps it to, and which installation made the goods. A line under 7602 or 7615 is outside. A line under 7601 needs a smelter's or remelter's figure with perfluorocarbons in it. A line under any other covered heading needs a product plant's figure with the unwrought precursor inside it. Chapter 24 of UK CBAM for Importers sets out the sector in full, with a worked illustration of the two routes.