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Aluminium

Aluminium is a priority intermediate product under the ESPR Working Plan, closely aligned with CBAM. The delegated act will focus on recycled content, embodied carbon and traceability to the smelter.

DraftApplies from Expected 2028ESPR (Regulation (EU) 2024/1781) — delegated act in scoping

Key dates

  1. 1 October 2023

    CBAM transitional phase begins for aluminium imports.

  2. 18 July 2024

    ESPR enters into force.

  3. 1 January 2026

    CBAM definitive regime begins.

  4. Expected 2027

    Public consultation on the aluminium delegated act.

  5. Expected 2028

    Delegated act adopted; DPP obligations phase in.

Required data points

  • Unique product identifier
  • Alloy grade and specification
  • Recycled content (post-consumer and pre-consumer)
  • Embodied carbon per tonne
  • Primary vs secondary production route
  • Smelter origin and electricity mix
  • Substances of concern
  • Conformity documentation

Accepted data carriers

QR code on product or packagingMill certificate resolverGS1 Digital Link or sector-specific APIs

Thresholds & exemptions

  • Close alignment with CBAM reporting — same embodied-emissions data reused.
  • Packaging-grade aluminium may be covered by the Packaging and Packaging Waste Regulation instead.

Open questions

  • Interaction with the Aluminium Stewardship Initiative certification.
  • Scope of cast vs wrought products.
  • Flow-through into downstream DPPs (vehicles, construction, packaging).