The European Commission has issued sector-specific guidance for aluminium that addresses how emissions are calculated under the Carbon Border Adjustment Mechanism for goods sold into the European Union. The guidance states that electricity consumption is not included in the embedded emissions of covered aluminium goods, with only direct emissions counted. The approach applies to electricity use despite its role in aluminium production and Serbia’s reliance on lignite-fired generation.
The Commission’s guidance shifts carbon exposure away from the Serbian power system and toward the aluminium entering production. For rolling, extrusion and other downstream manufacturing, the relevant inputs include slabs, billets and unwrought metal used to make products for the EU market. Under this framework, producers’ ability to document feedstock origin, production route and verified carbon intensity becomes central to CBAM calculations.
The Guidance Document 5E, published on 14 August 2026, covers unwrought aluminium and a range of downstream goods. The listed categories include powders, bars, profiles, wire, plates, sheets, strip, foil, tubes, structures, containers and other aluminium articles. Aluminium scrap under CN 7602 and household articles under CN 7615 are stated as remaining outside the listed scope.
The document is described as explanatory rather than legally binding, while providing an operational interpretation of how aluminium emissions should be calculated during the definitive CBAM period. For Serbia’s exporters, the trade exposure is significant: Serbia exported about $853.7 million of aluminium and aluminium articles in 2025. The EU accounted for about $505.7 million, or 59.2%, of that total.
Within the EU purchases of Serbian aluminium products, the Czech Republic, Germany and France together bought roughly $346.2 million, equivalent to more than two-thirds of Serbia’s EU-bound exports in 2025. Plates, sheets and strip were identified as the largest product group in the export mix. Other categories included aluminium containers, other articles, structures, bars and profiles.
Accounting rules differ across smelting and downstream processing
Serbia is not described as a large primary aluminium producer, with industrial strengths focused on rolling, extrusion, recycling, alloy preparation, fabrication and surface treatment. This matters because different accounting approaches apply to primary production, secondary melting and downstream manufacturing under the Commission framework. The guidance distinguishes emissions reporting requirements by production stage.
A primary smelter is required to report carbon dioxide from anodes and paste, fuel combustion, flue-gas treatment and perfluorocarbons including CF4 and C2F6. Secondary aluminium production reports direct fuel emissions and treats scrap as having zero embedded emissions. For rolling or extrusion plants, production is treated as a “complex good” where processing emissions are combined with embedded emissions from unwrought aluminium used as a precursor.
For Serbian rolling and extrusion companies, precursor inputs can therefore dominate CBAM outcomes even where plant operations are efficient. A producer may run furnaces with modern burners and maintain energy management but still face higher CBAM values if it buys carbon-intensive primary aluminium without verified installation data. Conversely, producers using substantial recycled content or documented low-carbon billets may report lower embedded-emissions values even when electricity consumption remains considerable.
Impol Seval: reported direct emissions contrasted with excluded electricity
Impol Seval is based in Sevojno and is described as one of Serbia’s key aluminium processing assets. The company is 70% owned by Slovenia’s Impol Group and includes casting and recycling operations alongside hot and cold rolling. This setup enables production of rolled products rather than trading only unwrought metal.
In 2025, Impol Seval produced 47,577.9 tonnes, down from 52,632 tonnes in 2024. The company consumed about 15.08 million cubic metres of natural gas and 39.50 GWh of electricity during 2025. Reported direct Scope 1 emissions were 28,267 tonnes of CO2 equivalent, corresponding to 0.594 tonnes per tonne of production.
Location-based Scope 2 emissions were higher at 43,415 tonnes, reflecting a disclosed Serbian grid factor of 1.099 kilograms of CO2 per kWh. The source material states that electricity represented approximately 61% of the combined reported Scope 1 emissions intensity plus location-based Scope 2 in 2025. Under Guidance 5E as described here, those indirect electricity-related emissions are excluded from the embedded CBAM calculation for covered aluminium goods.
The comparison also highlights that disclosed corporate inventories do not necessarily match CBAM production-process boundaries used for embedded-emissions calculations. CBAM calculations must add embedded emissions from the aluminium precursor adjusted for input quantity needed to produce one tonne of finished product. Material losses and cutting yields affect precursor mass entering production even where cutting or finishing emissions fall outside the system boundary.
Sensitivity scenarios based on certificate prices
The source provides sensitivity figures tied to hypothetical certificate prices for carbon allowances under CBAM conditions discussed in the article context. At a certificate price of €75 per tonne of CO2, an intensity of 0.594 tonnes per tonne corresponds to about €44.55 per tonne of product value equivalent. Applied across Impol Seval’s entire 2025 output, this would equal approximately €2.12 million.
The same scenario framework gives comparable amounts at certificate prices of €50 and €100. Those values are stated as approximately €1.41 million and €2.83 million, respectively. The figures are presented as exposure scenarios rather than estimates of an actual CBAM bill because they assume all production is covered and exported to the EU while excluding phase-in effects and other regulatory adjustments.
The source further states that precursor embedded-emissions differences can outweigh direct-emissions sensitivity in practice under Guidance 5E logic described there. At a certificate price of €75 per tonne of CO2, a difference between feedstock embedded-emissions values of 1.5 tonnes versus 6 tonnes is estimated at about €337.50 per tonne of aluminium input. It also notes that failure to substantiate supplier data could result in commercial penalties larger than those associated with a plant’s own furnaces.
Financial context reported for Impol Seval in 2025
The article links compliance readiness needs to operating conditions at Impol Seval during 2025. It states that Impol Seval recorded a net loss of €4.69 million in 2025 compared with marginal profit in 2024. Year-end capital declined to €67.23 million.
The source attributes the weaker result to difficult European market conditions, reduced capacity utilisation and margin pressure combined with a machine breakdown at Sevojno late in the year. It also describes CBAM compliance as involving margin protection and working-capital considerations rather than only environmental reporting tasks for companies facing soft demand and high fixed-cost absorption.
The company is described as having set an emissions-reduction target to cut emissions per tonne by 58% by 2030 compared with 2021. Its rolling division targets at least 35% secondary aluminium in the average charge. In addition, Impol obtained Aluminium Stewardship Initiative Performance Standard and Chain of Custody certification in 2025.
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