CBAM cost for an aluminium exporter is the number of certificates due, times the certificate price. For goods imported in the third quarter of 2026 that price is EUR 82.32 a tonne of CO2e. Certificates are due for the embedded emissions, either a marked up default or a verified actual figure, minus the free allocation adjustment.
Three numbers behind every CBAM bill
Since 1 January 2026 the CBAM certificate bill has rested on three numbers: embedded emissions per tonne, the free allocation adjustment deducted from them, and the certificate price. Embedded emissions come either from origin-specific default values published in Implementing Regulation (EU) 2025/2621, or from actual installation data verified by an accredited verifier. Aluminium defaults carry a mark-up of 10 percent in 2026, 20 percent in 2027 and 30 percent from 2028; fertiliser defaults carry a flat 1 percent. Aluminium is an Annex II good, so only direct emissions are priced; indirect, electricity related emissions are excluded. In 2026 the certificate price is the average EU ETS auction price for the quarter of import.
The declarant surrenders certificates for the embedded emissions minus the free allocation adjustment, and minus any carbon price deduction, never below zero. The adjustment mirrors the free allocation EU producers of the same good still receive. On default values it is the good’s CBAM benchmark, times the CBAM factor for the year, times the cross-sectoral correction factor, times the mass imported. The deduction shrinks each year. The CBAM factor is 97.5 percent in 2026, 95 percent in 2027, 90 percent in 2028 and 77.5 percent in 2029. It falls to 51.5 percent in 2030, 39 percent in 2031, 26.5 percent in 2032 and 14 percent in 2033. From 2034 nothing is deducted for free allocation. In 2026, 2.5 percent of the benchmark is no longer deducted. That figure is not 2.5 percent of the embedded emissions. The declarant buys the certificates. How the cost is shared with the exporter is a matter for the supply contract.
Example: one tonne of Indian unwrought aluminium (CN 7601) imported in the third quarter of 2026 on default values. The default value of 1.870 tonnes of CO2e, with the 10 percent mark-up, gives 2.057. The free allocation adjustment is 0.975 x 1.00 x 1.423, or 1.387. The declarant surrenders 2.057 minus 1.387, or 0.670 certificates, about EUR 55 at the third-quarter 2026 price of EUR 82.32.
Why the same tonnage costs different amounts
Identical tonnage can produce very different certificate bills. Four things drive the spread:
- Product mix: India defaults climb with each stage of working, from 1.87 tCO2e per tonne for unwrought metal to 4.13 for plates, sheets and foil, so the same tonnage is assessed differently by product.
- Production route: primary aluminium smelted from ore embeds far more carbon than recycled, scrap-based metal.
- Country of origin: default values are set country by country in Implementing Regulation (EU) 2025/2621, so the same product from another origin carries a different base value.
- Year: the mark-up rises and the deduction for free allocation shrinks on fixed schedules, so an unchanged shipment costs more each year.
| Product | CN | Base default (tCO2e/t) | 2026 with mark-up |
|---|---|---|---|
| Unwrought aluminium | 7601 | 1.87 | 2.06 |
| Profiles (incl. hollow) | 7604 (profiles) | 3.44 | 3.79 |
| Plates, sheets, strip | 7606 | 4.13 | 4.54 |
| Foil | 7607 | 4.13 | 4.54 |
Source: Implementing Regulation (EU) 2025/2621, Annex I, India values. Direct emissions only.
How to put a real number on an export line
A credible figure starts from the exporter’s product mix, tonnage, route and origin, never from a generic per tonne quote. The full India default list by CN code sits in the companion answer on Indian aluminium default values. The fastest route to an estimate is the CBAM cost calculator, which models the bill year by year through 2034. Exporters ready to test actual installation data against the defaults can begin with a CBAM discovery and engage GreenSutra’s CBAM consulting service to prepare data for verification by an accredited verifier.
Sources: Regulation (EU) 2023/956 · Implementing Regulation (EU) 2025/2621 · European Commission CBAM portal