The European Commission has issued guidance clarifying that aluminium produced in 2025 but released for free circulation in the European Union during 2026 falls under the Carbon Border Adjustment Mechanism (CBAM). The guidance links the applicable treatment to the customs release timing rather than production alone.
For imports in 2026, the legally applicable reporting period is 2026. It also states that production data from earlier periods cannot be automatically used as CBAM-verified actual emissions because accredited CBAM verification was not available for those historical production periods.
Reporting period and customs release under CBAM
The Commission’s clarification explains why late-2025 inventories could remain outside the definitive regime depending on when goods were released for free circulation. Producing, selling or shipping metal before the end of 2025 was not sufficient if release occurred in 2026.
The guidance therefore frames the decisive factor as the customs event date. It indicates that customs clearance timing determined whether aluminium inventories aligned with the definitive CBAM regime for imports in 2026.
Front-loaded trade flows before the definitive regime
The guidance also provides context for exceptional aluminium and hot-rolled coil trade flows ahead of the definitive CBAM application. Fastmarkets estimated that front-loading cleared around EUR 820 million in potential CBAM liabilities before 1 January 2026.
According to the same assessment, shipments rose sharply in late 2025 and then reversed in early 2026. The effectiveness of these inventory approaches depended on whether the relevant customs event occurred before the new regime became applicable.
Bonded inventories and suspensive customs procedures
For market participants, customs status is described as a factor affecting carbon-cost exposure under CBAM. Aluminium held in a bonded warehouse, placed under a suspensive customs procedure, or awaiting release for free circulation may receive different CBAM treatment than stock that has already cleared EU customs.
The distinction is also relevant for later inventory strategies. As the adjustment for free allocation declines towards 2034, the effective CBAM burden is described as increasing, which could affect incentives to manage import timing around future increases in exposure.
The Commission’s guidance notes that practical scope for such strategies is constrained by customs requirements, anti-circumvention rules, financing costs and available storage capacity.
Bank financing and working-capital models
The customs-date rule also affects banks financing metal inventories. Stock financed before customs clearance may involve an uncertain future carbon liability, while inventories already released for free circulation have an established regulatory status under applicable rules.
Working-capital models are therefore expected to distinguish inventories based on their legal customs position rather than relying only on physical location or production date. This reflects how CBAM exposure can vary according to whether goods have been released for free circulation.