The European Commission’s latest guidance states 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 CBAM treatment to the customs release event rather than production timing alone.
For imports in 2026, the legally applicable reporting period is 2026. It also says 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 verification limits for earlier production
The Commission’s clarification explains why late-2025 inventories could fall outside the definitive regime depending on when goods were released. Producing, selling, or shipping metal before the end of 2025 was not sufficient if release for free circulation occurred in 2026.
This distinction centers on customs clearance timing. It indicates that whether inventories entered the definitive CBAM framework depended on the relevant customs event taking place before the regime became applicable.
Front-loaded clearance ahead of the definitive CBAM regime
The guidance provides context for exceptional aluminium and hot-rolled coil trade flows observed ahead of the definitive CBAM regime. Fastmarkets estimated that front-loading cleared about 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 strategies depended on whether the customs event occurred before the new regime applied.
Bonded stocks and suspensive procedures under CBAM
The Commission’s guidance also highlights that customs status can affect carbon-cost exposure for traders. Aluminium held in a bonded warehouse, placed under a suspensive customs procedure, or awaiting release for free circulation may receive different CBAM treatment from stock that has already cleared EU customs.
This customs-based distinction can also matter for inventory approaches in later years. As the adjustment for free allocation declines towards 2034, the effective CBAM burden is described as increasing, which may affect incentives to manage import timing around future exposure increases.
The ability to adjust timing is described as limited by customs requirements, anti-circumvention rules, financing costs, and available storage capacity.
Financing considerations tied to customs clearance dates
The customs-date rule is also relevant for 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 described as needing to distinguish inventories by their legal customs position. The guidance indicates this should be done rather than relying only on physical location or production date.
The Commission’s latest guidance further links changing trade flows to how customs law shapes resulting carbon-cost exposure. It describes this as an important factor alongside other elements affecting CBAM compliance outcomes.