CBAM Downstream Aluminium Products: What the 15 September Parliament Vote Changes From 2028

On 15 September 2026 the European Parliament adopted its negotiating position on the revised Carbon Border Adjustment Mechanism. The vote was 464 in favour, 50 against and 159 abstentions. The text extends the mechanism to finished steel and aluminium goods such as fasteners, wire, springs and household articles. For anyone importing profiles, wire or components into the EU, CBAM downstream aluminium products have moved from a Commission proposal to a live negotiating mandate.

The vote does not create an obligation yet. However, it fixes the position the Parliament will defend in the trilogue with the Council and the Commission. The Commission proposed 180 additional products, the Council settled on 200, and the Parliament now backs 457. This note describes the mechanism. It does not recommend any purchase, sale or hedging decision.

What the 15 September vote changes

The Parliament’s press release, reproduced by The European Sting, lists four moves beyond the Commission text. First, the scope widens to finished steel and aluminium products, with fasteners, wire, springs and household articles named explicitly. Second, the threshold for treating a minor modification as circumvention drops. Third, the Commission gains the power to apply default values of the real country of origin when it detects circumvention patterns. Finally, MEPs rejected the safeguard that would have let products leave CBAM during price shocks.

The rapporteur is Mohammed Chahim of the S&D group, from the Netherlands. In short, the Parliament enters the negotiation asking for more coverage and fewer exits.

Three lists for CBAM downstream aluminium products: 180, 200 or 457

The gap between the three institutions is what the trilogue now has to close. The European Parliamentary Research Service sets out the three positions. All of them target downstream goods with a high carbon leakage risk and a high share of steel or aluminium content.

As Mayer Brown summarised the 17 December 2025 proposal, the new goods would enter the mechanism from 1 January 2028. The categories run from fabricated metal articles and machinery to vehicles, medical instruments and metal furniture. The Commission also proposes to treat pre-consumer aluminium and steel scrap as CBAM precursors. In other words, declaring production offcuts as scrap would no longer lower the embedded emissions of the finished good.

For a buyer or exporter, the task is mechanical. Cross your tariff codes against the three lists and work with the wide scenario. The negotiation now runs between the Council’s 200 and the Parliament’s 457.

Two aluminium loopholes the European industry wants closed

The committee vote left two aluminium-specific points open. European Aluminium made both explicit in a statement circulated by AL Circle in July 2026. Paul Voss, the association’s director general, said that “imported aluminium products can benefit from lower carbon costs by declaring post-consumer scrap”. The Commission text only covers pre-consumer scrap. Therefore, the association asks that “a default value should apply to all aluminium scrap used as a precursor, irrespective of whether it is pre- or post-consumer”. Otherwise, it estimates, “around one quarter of global aluminium production could continue to avoid the carbon costs faced by European producers”.

The second point is the threshold. CBAM exempts importers below 50 tonnes a year. AL Circle reports that this leaves around 182,000 importers outside the mechanism. European Aluminium argues the threshold is “ill-suited to aluminium because of the metal’s high value-to-weight ratio”. Its example: the aluminium needed to renew the doors of a 200-room hotel “would amount to only 9.2 tonnes”.

The wider industry pushes in the same direction. Shanghai Metals Market reported on 19 September that Alexander M. Julius, president of Eurometal, called the vote progress but said the scope remains incomplete and the rollout too gradual. In short, the European lobby asks for more scope and less time.

From rule to number: the carbon cost per tonne today

The mechanism becomes concrete when the certificate price meets the default emission values. AL Circle reports a CBAM certificate price of EUR 75.36 per tonne of CO2 in the first quarter of 2026 and EUR 75.28 in the second. Importers who cannot present verified supplier data pay on default values. Moreover, those defaults carry a mark-up of 10 percent in 2026, 20 percent in 2027 and 30 percent from 2028.

The same report gives a default embedded emission figure for unalloyed aluminium under CN code 7601 from Bahrain: 2.057 tonnes of CO2e per tonne of metal. Multiply roughly 2 tonnes of CO2e by a certificate near EUR 75. The carbon cost of an origin without verified data then approaches EUR 150 per tonne, before the default mark-up. This is arithmetic on published figures, not a forecast. From 2028, however, that cost attaches to CBAM downstream aluminium products as well as to the ingot. As a result, supplier emission data turns into a purchasing criterion rather than a compliance formality.

What the extension means for Latin American aluminium exporters

Latin American producers currently watch CBAM through the ingot. Fastmarkets reported in July that Brazilian exports of aluminium ingot to Europe fell to 51,935 tonnes between January and June 2026. The same period of 2025 had recorded 98,565 tonnes, so the drop is 47.3 percent. Ingot shipments from March to June, however, reached 40,564 tonnes against 25,048 a year earlier, up 61.9 percent, after the Middle East conflict pushed European buyers back toward Brazilian supply.

Rafael Della Barba of WayCarbon summarised the exporter view: “CBAM just makes things more difficult. It’s highly bureaucratic and difficult to calculate.” The downstream extension moves that difficulty one step along the chain. A manufacturer in Brazil, Mexico or Argentina that ships aluminium components or assembled goods to the EU has no CBAM obligation today. From 2028, if its codes sit in the final list, it will have to document the embedded emissions of the aluminium inside those goods and prove the origin of any declared scrap. Meanwhile, light reworking in a third country will not take the goods off the list. For the US equivalent, see our note on the Section 232 aluminium derivative products list.

Market backdrop and what to do with this

The extension arrives on top of a tight physical market. Trading Economics quoted LME aluminium at USD 3,261.40 per tonne on 22 September 2026, up 1.34 percent on the month and 23.44 percent on the year. It notes that GCC production fell 44 percent year-on-year in July, that “LME inventories remained close to a 36-year low” and that Chinese exports were “climbing 17.2% year-on-year in August”. The European buyer therefore pays for scarce metal and sees more Chinese origin entering the market. Origin traceability becomes a purchasing criterion, not a paperwork step.

None of this tells anyone when to buy or at what price. It does define a checklist worth working through now:

• Map the codes. Cross every aluminium tariff line you move into or out of the EU against the three lists of CBAM downstream aluminium products. Plan with the widest one.
• Ask for real emission data. Verified supplier figures replace default values, and the default mark-up rises to 30 percent from 2028.
• Document scrap origin. Pre-consumer scrap is already a precursor in the Commission text, and post-consumer scrap is the gap European Aluminium wants closed.
• Check the 50-tonne threshold against value, not weight. Small aluminium volumes carry large invoices.
• Follow the trilogue. The text is not final, and 1 January 2028 is the Commission’s date, not yet the law’s.

Allinx trades aluminium and other metallurgical materials into Europe and Latin America, backed by the logistics and customs capacity of BiiSmart Group and its own operation in Shenzhen. On a specific enquiry we can provide a delivered-cost quotation at destination, an analysis of origin and applicable duty, and sourcing with our own logistics. We do not quote future prices, and nothing above is a recommendation. For a code-by-code check of your product list, contact the team. See also our note on secondary aluminium sourcing under CBAM.

FAQ: CBAM Downstream Aluminium Products

What did the European Parliament vote on 15 September 2026?

It adopted its negotiating position on the revised Carbon Border Adjustment Mechanism, by 464 votes in favour, 50 against and 159 abstentions. The text extends the mechanism to finished steel and aluminium goods such as fasteners, wire, springs and household articles. The vote does not create an obligation yet.

How many downstream products could CBAM cover?

The Commission proposed 180 additional goods, the Council settled on 200 and the Parliament now backs 457. The trilogue has to close that gap. Under the Commission proposal of 17 December 2025, the new goods would enter the mechanism from 1 January 2028, which is not yet the law’s date.

What will Latin American exporters of aluminium components need from 2028?

A manufacturer in Brazil, Mexico or Argentina that ships aluminium components or assembled goods to the EU has no CBAM obligation today. From 2028, if its codes sit in the final list, it will have to document the embedded emissions of the aluminium inside those goods and prove the origin of any declared scrap.

What does CBAM cost per tonne of aluminium without verified data?

AL Circle reports a certificate price near EUR 75 per tonne of CO2 and a default value of 2.057 tonnes of CO2e per tonne for unalloyed aluminium from Bahrain. Without verified supplier data, the carbon cost approaches EUR 150 per tonne, before a default mark-up of 10 percent in 2026, 20 percent in 2027 and 30 percent from 2028.