If you make aluminium products and export to the EU, your customers are already asking for embedded emissions data. From January 2026, EU CBAM (Carbon Border Adjustment Mechanism) entered its definitive phase, which means the carbon content of your products is now a direct cost for whoever imports them. Get the number wrong or leave it blank, and they pay more. Get it right, and you protect the relationship.
This guide explains exactly what embedded emissions are, how to calculate them, and what UK aluminium manufacturers need to do to stay on the right side of their EU customers.
What are embedded emissions under CBAM?
Embedded emissions are the greenhouse gases released during the production of a good, up to the point it leaves your factory gate. For aluminium, this covers:
Direct emissions (Scope 1): the carbon released from your own production processes, such as combustion in furnaces, use of fossil fuels for heating, process emissions from smelting or casting, and the use of chemical reagents in production.
Indirect emissions (Scope 2): the emissions from the electricity you consume in manufacturing. For aluminium, this is significant because electrolytic smelting is energy-intensive, and the carbon intensity of that electricity depends on when and where it was generated. Note that electrolytic smelting is only relevant if you are producing primary aluminium from base ore. Most downstream aluminium manufacturers working with ingot or billet will not have this process in scope.
Precursor emissions: if your aluminium product uses aluminium ingot, billet, or other semi-finished materials as inputs, the embedded emissions from those upstream materials must also be included. These are often the largest share of the total.
The boundary for CBAM is modules A1 to A3 under EN 15804, which maps to cradle-to-gate. You are not required to include transport to the customer or end-of-life, but you do need everything up to the factory gate.
Why the EU methodology is different from a standard LCA
This is where many manufacturers get tripped up. A Life Cycle Assessment (LCA) gives you a comprehensive picture of your product’s environmental impact across multiple categories. An Environmental Product Declaration (EPD) communicates that data in a standardised format.
But CBAM does not simply accept an LCA or EPD as proof of embedded emissions. The EU’s Monitoring and Reporting Regulation (MRR) requires installation-specific, meter-based data. That means:
- Emissions must be traced to your specific production installation, not an industry average
- Electricity must be attributed using a time-weighted carbon intensity factor for the grid you actually use
- Any precursor materials must have their own verified emissions data, not generic database values
If you cannot provide verified actual emissions, your EU customer must use region-specific default values. These are calculated as the average of the 10% worst-emitting production sites in that region, not a single EU-wide figure. For most UK manufacturers, those default values will be higher than your actual emissions, which means your customer overpays on certificates and you look like a high-carbon supplier.
Step-by-step: calculating embedded emissions for aluminium
Identify which products are in scope and trace each one back to its production installation. For a UK aluminium extruder, this means the extrusion facility itself, but also the source of the aluminium billet you use as feedstock.
Gather actual metered data from your installation for the reporting period, typically a calendar year. This includes fuel consumption by type, electricity consumption, and production volumes. The data needs to be traceable, ideally from your energy invoices and production records.
Apply the EU-approved emission factors for each fuel type to your fuel consumption data. These are set by the EU MRR and are not the same as DEFRA emission factors, so you need to use the right source.
Multiply your electricity consumption by the carbon intensity of your national grid, using the country-specific electricity emission factor published by the EU for the relevant year. For UK installations, there is a specific factor available.
If you use primary aluminium as an input, you need verified embedded emissions data for that aluminium from the smelter or supplier. This is where the process gets complicated. If your supplier cannot provide verified data, region-specific default values apply for that portion.
Divide total direct and indirect emissions by the quantity of product produced in tonnes. This gives you the embedded emissions intensity figure your EU customer needs.
Embedded emissions intensity formula
This is the figure your EU importer needs for their CBAM declaration.
This is the document you provide to your EU importer. It must follow the format specified by the European Commission and include your installation details, the calculation methodology, the emissions intensity figure, and any carbon price already paid in the UK.
What role does an LCA or EPD play?
Even though an EPD alone does not satisfy CBAM, it significantly reduces the work involved. A well-constructed EPD for an aluminium product contains most of the primary data and calculation logic CBAM requires. The system boundary overlaps almost entirely, and the verification process for an EPD gives you an audit trail that CBAM verifiers will recognise.
If you already have an EPD or are planning to get one, the marginal effort to produce CBAM-ready embedded emissions data is much lower. The datasets, the allocation methodology, and the verification evidence are largely the same.
This matters because CBAM verification is mandatory from 2026. Your embedded emissions data must be independently verified by an accredited third party, including an on-site audit in the first year. Starting with a rigorous LCA and EPD foundation makes that verification faster and less painful.
UK CBAM: what comes next
EU CBAM applies to goods imported into the EU now. UK CBAM is expected to follow a similar structure and is currently scheduled to take effect from January 2027, covering aluminium, cement, fertiliser, hydrogen, and iron and steel.
If you manufacture aluminium products sold in the UK market, the same embedded emissions calculation methodology will apply domestically within the next 12 months. Building the data infrastructure now means you will be ready for both regimes without duplicating the work.
FAQ
No. An LCA provides valuable primary data, but CBAM requires installation-specific metered data calculated using the EU MRR methodology. An LCA is a strong starting point, not a direct substitute.
If you cannot obtain verified data from your supplier, region-specific default values apply for that precursor. These are based on the average of the 10% worst-emitting production sites in the relevant region. This will likely overstate your actual embedded emissions and increase your customer’s CBAM certificate cost.
From 2026, yes. Supplier-specific emissions data used in CBAM declarations must be verified by an accredited third-party verifier. The first verification includes an on-site audit.
It is the document UK exporters provide to their EU importers summarising embedded emissions per tonne of product, the calculation methodology, and any carbon price already paid. It follows the format set by the European Commission.
UK CBAM is expected to follow a similar structure, with full implementation from January 2027. It will cover the same broad product categories. UK manufacturers exporting to the EU face EU CBAM obligations now; those selling domestically will face UK CBAM obligations from 2027.
Yes. Below280 provides embedded emissions calculations for CBAM compliance, including primary data collection, EU MRR-aligned methodology, and support through the verification process. We also produce EPDs that create a reusable data foundation for ongoing CBAM reporting.
Working through your first CBAM submission?
If your EU customer has started asking for a Communication Summary Sheet, we can help. We calculate your embedded emissions, prepare the documentation, and support you through verification.
Global commercial consultancy • Horizon Europe, UKRI & Innovate UK research partner. Specialists in openLCA, and UK openLCA partner for GreenDelta.