Gulf aluminium is in CBAM scope. The UAE and Bahrain rank fourth and sixth among in-scope suppliers by 2024 import value, once Norway, Iceland and Switzerland are set aside as exempt under Annex III. The published default for unwrought aluminium is 1.870 tonnes of CO2e per tonne for the UAE and Bahrain and 1.700 for Saudi Arabia, Oman and Qatar, before the mark-up. Verified installation data therefore decides the declared figure.
Where Gulf aluminium sits once exempt origins are removed
The EU imported about EUR 29.6 billion of aluminium in 2024. Norway, China, Türkiye, Iceland and Switzerland lead the partner list, yet Norway, Iceland and Switzerland fall outside CBAM under Annex III of Regulation (EU) 2023/956, through the EEA or a linked emissions-trading system, whatever their emissions. In-scope repricing therefore concentrates on the suppliers that follow, led by China, Türkiye and the United Kingdom, then the UAE. Gulf smelters rise up the ranking of covered origins for that reason, not because their metal is unusually carbon-heavy.
Published defaults for Gulf aluminium
Default direct emissions for unwrought aluminium (CN 7601) by origin, in tonnes of CO2e per tonne, before the mark-up:
| Origin | Default direct emissions |
|---|---|
| United Arab Emirates | 1.870 |
| Bahrain | 1.870 |
| Saudi Arabia | 1.700 |
| Oman | 1.700 |
| Qatar | 1.700 |
| China (for comparison) | 3.000 |
These are the values in Annex I to Implementing Regulation (EU) 2025/2621, as corrected by Implementing Regulation (EU) 2026/1740. Aluminium is an Annex II good, so several features of the regime decide the real number:
- Only direct embedded emissions count, and grid electricity is excluded from the certificate obligation.
- Smelting is power-intensive, but electricity is an indirect emission and does not count, so the figure comes from direct sources such as fuels and perfluorocarbons, whatever the smelter’s power source.
- Primary metal smelted from ore carries far more embedded carbon than recycled, scrap-based metal, so feed mix matters too.
From estimate to declared figure
A producer lacking verified data falls back to its country default, marked up by 10 percent in 2026, 20 percent in 2027 and 30 percent from 2028. Verified installation data usually replaces that conservative default with a lower real figure. A workable sequence:
1. Confirm the CN code, since aluminium spans unwrought metal through bars, profiles, wire, sheet and finished articles. 2. Measure direct emissions at the smelter on a calculation-based or measurement-based approach. 3. Have that data verified by an accredited verifier before it reaches the EU importer.
The de-minimis of 50 tonnes per importer each year sits below most commercial consignments, so the bulk of Gulf aluminium trade is covered. CBAM advisory covers declarant status, embedded-emissions calculation and certificate exposure across covered origins, and the CBAM guide sets out the evidence an EU importer expects.
Sources: Regulation (EU) 2023/956 · Eurostat · European Commission CBAM