As the EU Carbon Border Adjustment Mechanism moves deeper into downstream aluminium products, precise product classification and origin information are becoming increasingly important to understanding potential carbon exposure.
Following SMM's analysis of the two dominant alloy aluminium profile categories, CN 76042100 and CN 76042990, this second article examines two smaller but structurally different product groups within HS 7604: CN 76041090, covering profiles of non-alloy aluminium, n.e.s., and CN 76042910, covering bars and rods of aluminium alloys.
Together, the two categories accounted for approximately 54,800 tonnes of EU-27 extra-EU imports in 2025, representing around 13% of total HS 7604 imports.
Although smaller than the alloy-profile market covered in Part 1, their trade patterns reveal a different set of CBAM issues.
CN 76041090 recorded strong headline import growth in 2025, but a large proportion of the trade was reported under the non-country partner category “High seas”, making country-level CBAM analysis more difficult.
By contrast, CN 76042910 presents a much cleaner country-level supplier structure but recorded a substantial contraction during both 2025 and H1 2026.
The two products therefore illustrate why CBAM analysis increasingly requires not only knowledge of the broad HS heading, but also precise CN8 classification, origin attribution and production-route information.
Different product classifications lead to slightly different CBAM benchmarks
Under Commission Implementing Regulation (EU) 2025/2620, CN 76041090 and CN 76042910 receive slightly different benchmark values.
For CN 76041090 non-alloy profiles, the route K benchmark is 1.493 tCO₂e/t, while the route L benchmark is 0.152 tCO₂e/t.
For CN 76042910 aluminium-alloy bars and rods, the route K benchmark is 1.485 tCO₂e/t, while the route L benchmark is 0.148 tCO₂e/t.
The difference is small, but it demonstrates that CBAM exposure is calculated at a more granular level than the four-digit HS 7604 heading.
For the comparative calculations in this article:
Theoretical unit exposure = max[(base default value × 1.10) − (benchmark × 97.5%), 0]
The calculations assume a cross-sectoral correction factor of 1 and do not deduct qualifying carbon prices paid in the country of origin.
They therefore represent theoretical default-value exposure rather than final importer liability.
Combined imports were broadly stable, but the two product markets diverged sharply
EU-27 imports of the two CN codes combined increased from approximately 53,900 tonnes in 2024 to 54,800 tonnes in 2025, an increase of around 1.8% year on year.
Combined import value increased from approximately €366 million to €385 million.
However, the apparent stability at the combined level masks opposite movements within the two categories.
| Product | 2024 Volume | 2025 Volume | YoY | 2025 Import Value |
|---|---|---|---|---|
| CN 76041090 Non-alloy profiles | 16,117 t | 21,428 t | +33.0% | €218.4m |
| CN 76042910 Alloy bars and rods | 37,738 t | 33,414 t | -11.5% | €166.7m |
| Combined | 53,855 t | 54,843 t | +1.8% |
€385.2m |
CN 76042910 remained the larger product category, representing approximately 60.9% of combined tonnage in 2025.
However, the strong growth reported for CN 76041090 requires closer examination.
More than 40% of CN 76041090 imports were reported under “High seas”
One of the most unusual characteristics of CN 76041090 trade is the large volume recorded under the partner category “High seas” rather than a specific country.
In 2025, approximately 9,037 tonnes of CN 76041090 imports were recorded under this category.
This represented around 42.2% of total EU extra-EU import volume for the code.
The figure was also substantially above the approximately 5,844 tonnes recorded in 2024, an increase of around 54.7% year on year.
The “High seas” category alone therefore accounted for a significant proportion of the total increase in CN 76041090 imports during 2025.
This matters for CBAM analysis because a country-specific default value cannot reliably be assigned to a non-country partner category using trade statistics alone.
As a result, SMM does not assign these volumes to a specific country default-value scenario.
After excluding non-country entries, identifiable country-origin imports represented only around 58% of total reported CN 76041090 volume.
The strong headline increase in the product category should therefore not automatically be interpreted as broad-based expansion among established suppliers.
Albania remained the largest identifiable supplier of non-alloy profiles
Among identifiable country origins, Albania was the largest supplier of CN 76041090 in 2025.
EU imports from Albania reached approximately 2,747 tonnes, down from around 3,179 tonnes in 2024, representing a decline of approximately 13.6% year on year.
The corrected default-value framework assigns Albania approximately 1.160 tCO₂e/t for the product under production route L.
Using the secondary-route benchmark of 0.152 tCO₂e/t:
1.160 × 1.10 − 0.152 × 97.5% ≈ 1.13 tCO₂e/t
This is materially lower than the default-based exposure calculated for several primary-route suppliers.
Albania therefore illustrates the effect of production-route treatment: a lower secondary-route default value can produce substantially lower unit exposure, even though the associated free-allocation benchmark is also much smaller.
Mozambique emerged temporarily as a major 2025 supplier
Mozambique represented another notable feature of the 2025 CN 76041090 data.
EU imports reached approximately 2,432 tonnes, making Mozambique the second-largest identifiable country supplier during the year.
Comparable trade in 2024 was negligible.
However, this increase does not appear to have been sustained.
During H1 2026, imports from Mozambique declined to approximately 223 tonnes, down around 89% from H1 2025.
The 2025 surge should therefore be interpreted cautiously rather than immediately treated as a structural change in the supplier landscape.
Nevertheless, the episode illustrates how relatively small downstream aluminium markets can experience significant shifts in CBAM exposure when new origins enter with meaningful volumes.
Chinese non-alloy profile shipments continued to decline
China remained another relevant supplier of CN 76041090, but its shipments fell substantially.
EU imports declined from approximately 3,012 tonnes in 2024 to 2,253 tonnes in 2025, a decrease of around 25.2%.
The decline continued into H1 2026, when imports fell by approximately 41% year on year to around 744 tonnes.
China's corrected base default value for the relevant HS 7604 products is approximately 4.881 tCO₂e/t under production route K.
Using the 1.493 tCO₂e/t profile benchmark:
4.881 × 1.10 − 1.493 × 97.5% ≈ 3.91 tCO₂e/t
This is considerably higher than the theoretical exposure calculated for Albania.
The trade data alone do not demonstrate that CBAM caused the decline in Chinese shipments. Market demand, pricing, trade measures and supplier strategy may all have contributed.
However, where EU buyers must rely on fallback default values, relatively high theoretical carbon exposure could become an additional commercial disadvantage.
Türkiye's role is much smaller than in alloy profiles
Türkiye supplied approximately 1,790 tonnes of CN 76041090 in 2025, up around 6.7% year on year.
Its share of total reported imports was approximately 8.4%.
This is far below Türkiye's dominant position in the alloy hollow- and solid-profile markets examined in Part 1.
The contrast suggests that Türkiye's strong EU extrusion position is concentrated primarily in alloy profiles rather than evenly distributed across all HS 7604 categories.
Türkiye's theoretical unit exposure for CN 76041090 is approximately:
3.741 × 1.10 − 1.493 × 97.5% ≈ 2.66 tCO₂e/t
This remains below China's approximately 3.91 tCO₂e/t but above Albania's secondary-route exposure.
CN 76042910 has a much clearer country-level supplier structure
The market for aluminium-alloy bars and rods under CN 76042910 differs substantially from CN 76041090.
Almost all 2025 trade can be attributed to identifiable partner countries.
Approximately 83% of total imports came from identifiable CBAM-covered origins, while around 16% came from exempt suppliers, principally Norway and Switzerland.
Only a very small proportion was recorded under non-country categories.
This makes CN 76042910 considerably more suitable for direct country-level default-value comparison.
Türkiye remained the largest supplier despite lower shipments
Türkiye was the largest supplier of CN 76042910 in 2025, exporting approximately 7,823 tonnes to the EU.
Shipments nevertheless declined by around 10.5% year on year from approximately 8,743 tonnes in 2024.
Türkiye accounted for approximately 23.4% of total imports.
Norway ranked second at around 3,404 tonnes, although Norwegian-origin material is outside the scope of CBAM.
China supplied approximately 2,594 tonnes, followed by Serbia at around 2,304 tonnes.
The UAE, India and the United States also supplied meaningful volumes.
The market is therefore much more diversified than the alloy-profile market, where Türkiye alone accounted for more than half of imports.
China again carries materially higher theoretical unit exposure
Chinese imports of CN 76042910 declined from approximately 3,543 tonnes in 2024 to 2,594 tonnes in 2025, down around 26.8% year on year.
During H1 2026, the decline accelerated further, with EU imports falling approximately 51.5% year on year to around 817 tonnes.
For CN 76042910, the primary-route benchmark is slightly lower than for profile products, at 1.485 tCO₂e/t.
Using China's 4.881 tCO₂e/t default value:
4.881 × 1.10 − 1.485 × 97.5% ≈ 3.92 tCO₂e/t
This is only marginally above the approximately 3.91 tCO₂e/t calculated for CN 76041090.
For Türkiye, the corresponding exposure is approximately 2.67 tCO₂e/t, compared with about 2.66 tCO₂e/t for the profile category.
The differences are relatively small, but they demonstrate an important principle: even when the country default value is identical, precise CN classification can slightly change CBAM exposure because the applicable benchmark differs.
UAE shipments increased sharply in 2025
One of the strongest supplier shifts within CN 76042910 came from the United Arab Emirates.
EU imports increased from approximately 337 tonnes in 2024 to 2,270 tonnes in 2025, an increase of more than 570% year on year.
The UAE consequently captured approximately 6.8% of the market.
By contrast, a number of established suppliers recorded lower volumes during the year.
Türkiye, China, India, the United States, Switzerland, Japan and South Korea all saw declines, while Norway increased shipments by around one-third.
The result was a substantial reshuffling of supplier shares even as the total market contracted.
These movements should not be attributed directly to CBAM, particularly because 2025 remained within the transitional phase.
However, the definitive regime adds a new cost and compliance variable to an already changing competitive landscape.
H1 2026 contraction accelerated for alloy bars and rods
The weakness in CN 76042910 continued into 2026.
EU imports reached approximately 13,400 tonnes in H1 2026, down around 22.9% year on year.
Türkiye remained the largest supplier at approximately 3,276 tonnes, but shipments fell around 23.1%.
China declined by approximately 51.5%, while Serbia and the UAE also recorded substantial decreases.
India moved in the opposite direction, increasing shipments modestly, while Egypt also recorded stronger volumes.
The supplier structure therefore continued to shift rapidly even as the overall market contracted.
Again, the trade statistics alone do not establish a causal relationship with CBAM.
Nevertheless, from 2026 onward the interaction between trade patterns and carbon exposure becomes increasingly relevant because the definitive CBAM framework is now applicable.
The two products illustrate different CBAM data risks
Taken together, CN 76041090 and CN 76042910 demonstrate two different challenges for downstream aluminium CBAM analysis.
For CN 76041090, the central issue is origin attribution.
With more than 40% of 2025 volume reported under “High seas”, a large part of the statistical trade flow cannot be assigned reliably to a country-specific default value.
For CN 76042910, origin attribution is much cleaner, but the supplier base is highly diversified.
EU buyers may therefore face materially different default-value exposures depending on where the product is sourced.
The two categories highlight why CBAM analysis increasingly requires:
CN8 classification + origin + assigned production route + precursor emissions + verified actual emissions where available.
The broad HS heading alone is no longer sufficient.
Verified actual emissions may become increasingly valuable
Country default values remain fallback parameters rather than measurements of individual plants.
This distinction may be particularly important in diversified downstream aluminium markets.
Two producers supplying the same CN code from the same country may use very different combinations of primary aluminium, recycled metal, electricity sources and upstream billet.
Where verified actual embedded emissions are materially below the applicable fallback default value, suppliers may be able to reduce the certificate exposure faced by their EU customers.
Conversely, suppliers unable to provide sufficiently complete and traceable emissions information may remain reliant on country defaults.
This could increasingly affect landed-cost comparisons between otherwise similar suppliers.
For CN 76041090, robust origin and emissions documentation may be particularly important because the trade statistics themselves show that a substantial part of the market cannot be clearly attributed to individual countries.
Product-level analysis becomes increasingly important under CBAM
The detailed trade data show why HS 7604 should not be treated as one homogeneous market.
The dominant alloy-profile categories examined in Part 1 are characterised by strong Turkish concentration and a clear trade-scale-versus-carbon-intensity relationship.
The two smaller categories examined here show a different picture.
CN 76041090 recorded strong headline growth in 2025, but much of the increase was associated with “High seas” reporting and temporary changes in specific country flows rather than broad supplier expansion.
CN 76042910 contracted during both 2025 and H1 2026 while supplier shares shifted significantly across Türkiye, China, the UAE, India and other origins.
At the same time, slightly different benchmark values mean that even products within the same HS 7604 heading can carry different theoretical CBAM exposure.
As CBAM develops, downstream aluminium competitiveness will therefore increasingly depend on the interaction between:
product classification, country of origin, production route, actual embedded emissions, carbon-data quality and conventional commercial competitiveness.
For EU importers and aluminium suppliers alike, the growing granularity of the CBAM framework means that detailed product- and shipment-level data are likely to become increasingly important in procurement, contract negotiations and supplier selection.
