As the EU’s Carbon Border Adjustment Mechanism (CBAM) gradually extends to downstream aluminum processing products, accurate product classification and origin information are becoming increasingly important and directly affect the assessment of potential carbon exposure.
Following the analysis in Part I of CN 76042100 aluminum alloy hollow extrusion and CN 76042990 aluminum alloy solid extrusion, this article further focuses on two products under HS 7604 that are relatively small in scale but show pronounced differences in trade structure:
- CN 76041090—Other non-alloy aluminum extrusion
- CN 76042910—Aluminum alloy bar, rod
In 2025, the combined imports of the above two product categories into the EU-27 from outside the EU totaled approximately 54,800 mt, accounting for about 13% of total HS 7604 imports.
Although their trade scale is significantly smaller than the aluminum alloy extrusion discussed in Part I, these two subcategories reveal another type of CBAM issue.
CN 76041090 recorded strong import growth in 2025, but a considerable portion of the trade volume was classified under the non-country trading partner category **“High seas”**, increasing the difficulty of country-level CBAM analysis.
By contrast, the origin structure of CN 76042910 is clearer, but its imports contracted markedly in both 2025 and H1 2026.
These two products show that, under the CBAM framework, having only the four-digit HS code is gradually not enough to support precise analysis,and the importance of CN8 product classification, origin, and the corresponding production route continues to rise.
There are slight differences in CBAM benchmark values across different CN classifications
According to Commission Implementing Regulation (EU) 2025/2620, the CBAM benchmark values applicable to CN 76041090 and CN 76042910 are not exactly the same.
ForCN 76041090 Other non-alloy aluminum extrusion:
- K-route benchmark value:1.493 mt CO₂e/mt
- L-route benchmark value:0.152 mt CO₂e/mt
ForCN 76042910 Aluminum alloy bar, rod:
- K-route benchmark value:1.485 mt CO₂e/mt
- L-route benchmark value:0.148 mt CO₂e/mt
Although the difference between the two is relatively small, it indicates that the granularity of CBAM exposure calculations has been refined to the CN-code level, rather than being handled uniformly based solely on HS 7604 as a whole.
This article continues to use the same theoretical unit exposure calculation method as in Part I:
Theoretical unit exposure = max[(Base default value × 1.1) − (Benchmark value × 97.5%), 0]
The calculation assumes a Cross-Sectoral Correction Factor (CSCF) of 1 and does not deduct any carbon price already actually paid in the origin country that is eligible.
Therefore, the results presented in this article represent the theoretical CBAM certificate exposure under the default-value methodology and are not equivalent to the importer’s final actual compliance cost.
Combined Imports of the Two Product Categories Were Relatively Stable, but Internal Trends Diverged Markedly
In 2025, the EU-27 imported a combined total of approximately 54,800 mt of the above two product categories from outside the EU, up approximately 1.8% YoY from about 53,900 mt in 2024.
Over the same period, the combined import value increased from approximately EUR 366 million to approximately EUR 385 million.
However, the relative stability of the aggregate figures masks sharply different trends across the two sub-markets.
| Product | 2024 Imports | 2025 Imports | YoY | 2025 Import Value |
|---|---|---|---|---|
| CN 76041090 Other non-alloy aluminum extrusion | 16,117 mt | 21,428 mt | +33.0% | EUR 218.4 million |
| CN 76042910 Aluminum alloy bar, rod | 37,738 mt | 33,414 mt | -11.5% | EUR 166.7 million |
| Total | 53,855 mt | 54,843 mt | +1.8% | EUR 385.2 million |
Among them, CN 76042910 remained the larger category, accounting for approximately 60.9% of the combined imports of the two product categories.
However, the seemingly strong growth of CN 76041090 requires further breakdown.
Over 40% of CN 76041090 imports were recorded as “High seas”
One of the most noteworthy features of CN 76041090 is that a large volume of import trade was not attributed to specific countries, but instead recorded under the **“High seas”** category.
In 2025, imports under this category were approximately 9,037 mt, accounting for about 42.2% of the EU’s total imports of CN 76041090 from outside the EU.
This figure was significantly higher than approximately 5,844 mt in 2024, up approximately 54.7% YoY.
In other words, the “High seas” category itself contributed a substantial share of CN 76041090’s import growth in 2025.
This is particularly important for CBAM analysis.
Because “High seas” is not a specific country of origin, trade statistics alone cannot reliably match this portion of trade to the corresponding CBAM default values for a given country.
Therefore, in the country-level CBAM estimation in this article, SMM does not forcibly allocate national default values to this portion of trade volume.
After removing trading partner records that are non-national in nature, in 2025 the imports of CN 76041090 for which a specific country of origin can be clearly identified accounted for only about 58% of total declared volume.
Therefore, the 33% import growth for this category in 2025 cannot be simply interpreted as a broad expansion of exports to the EU by traditional supplier countries.
Albania Remained the Largest Identifiable Supplier Country
Within trade where the country of origin can be clearly identified, Albania was the largest supplier country of CN 76041090 in 2025.
EU imports from Albania were about 2,747 mt, below about 3,179 mt in 2024, down about 13.6% YoY.
Under the revised CBAM default value system, the base default value for this product from Albania was about 1.16 mt CO₂e/mt, corresponding to the L route, i.e., the secondary aluminum route.
Calculated using the L-route benchmark value of 0.152 mt CO₂e/mt:
1.16 × 1.1 − 0.152 × 97.5% ≈ 1.13 mt CO₂e/mt
This theoretical unit exposure level was clearly lower than that of some major supplier countries that partially use the primary aluminum route.
Albania therefore reflected the impact of differences in production routes on CBAM results: a lower default value under the secondary aluminum route can significantly reduce theoretical unit exposure, but at the same time, the corresponding benchmark value deduction is also far smaller than under the primary aluminum route.
Mozambique Temporarily Became a Major Supplier Country in 2025, but the Growth Did Not Continue into 2026
Mozambique was another notable change in the 2025 CN 76041090 trade data.
In 2025, the EU imported about 2,432 mt of this product from Mozambique, making it the second-largest identifiable country source.
Comparable trade volume in the same period of 2024 was relatively low.
However, this growth did not continue into 2026.
In H1 2026, EU imports from Mozambique fell to about 223 mt, down about 89% from H1 2025.
Therefore, the import surge in 2025 is currently better viewed as a phased change rather than a stable new supply landscape having formed.
However, this case also shows that in downstream aluminum product markets where trade scale is relatively small, as long as a new supply source sees relatively large growth in the short term, it may significantly change the overall country-level CBAM exposure structure of the entire market.
China’s exports of non-alloy aluminum extrusions continued to decline
China remained one of the key supply sources for CN 76041090, but its supply to Europe has continued to fall in recent years.
EU imports from China decreased from about 3,012 mt in 2024 to about 2,253 mt in 2025, down about 25.2% YoY.
This trend further continued in H1 2026, with imports down about 41% YoY to about 744 mt.
The revised basic default value for China’s relevant HS 7604 products was about 4.881 tCO₂e/mt, corresponding to the K route.
Calculated using the 1.493 tCO₂e/mt benchmark value for CN 76041090:
4.881 × 1.10 − 1.493 × 97.5% ≈ 3.91 tCO₂e/mt
Under this default-value methodology, the theoretical unit exposure level was significantly higher than Albania’s.
It should be noted that trade data alone cannot prove that the decline in China’s exports was directly caused by the Carbon Border Adjustment Mechanism (CBAM). Factors such as European demand, product prices, traditional trade measures, and suppliers’ business strategies may all have an impact.
However, when EU importers need to rely on default values for accounting, higher carbon exposure levels may become an additional commercial competitive disadvantage in the future.
Türkiye’s position in the non-alloy aluminum extrusion market was significantly weaker than in alloy extrusions
In 2025, the EU imported about 1,790 mt of CN 76041090 from Türkiye, up about 6.7% YoY.
This accounted for about 8.4% of the total declared imports in this category.
This share was far below Türkiye’s dominant position in the aluminum alloy hollow extrusions and solid extrusions markets analyzed in Part I.
This difference indicates that Türkiye’s advantages in the EU extrusion market are mainly concentrated in aluminum alloy extrusions, and have not extended evenly to all sub-segments under HS 7604.
Türkiye’s theoretical unit exposure for CN 76041090 was about:
3.741 × 1.10 − 1.493 × 97.5% ≈ 2.66 tCO₂e/mt
This level was still significantly lower than China’s approximately 3.91 tCO₂e/mt, but higher than the corresponding secondary aluminum route level for Albania.
The supplier-country structure for CN 76042910 was clearer
Compared with CN 76041090,the trade data for CN 76042910 aluminum alloy bars and rods were clearer in terms of country attribution.
In 2025, almost all imports could be matched to specific trading partner countries.
Of these, about 83% of imports came from clearly identifiable CBAM-covered countries, and about 16% came from CBAM-exempt sources, mainly including Norway and Switzerland.
The share of non-country trade records was extremely low.
Therefore, CN 76042910 is more suitable for directly comparing trade scale with country-level CBAM default values.
Turkey Remained the Largest Supplier, but Exports Declined YoY in 2025
In 2025, Turkey remained the largest supplier of EU imports of CN 76042910, with exports to the EU of about 7,823 mt.
However, this figure fell by about 10.5% YoY from about 8,743 mt in 2024.
Turkey accounted for about 23.4% of total EU imports in this category.
Norway ranked second with about 3,404 mt, but products sourced from Norway are not within the scope of CBAM.
China’s supply was about 2,594 mt, and Serbia’s about 2,304 mt.
The UAE, India, and the US also maintained supply at a certain scale.
Compared with the aluminum alloy extrusion discussed in Part I, the supply sources for CN 76042910 were clearly more diversified. Although Turkey still ranked first, its market share was far below the level of over 50% seen in hollow and solid aluminum alloy extrusion.
China’s Theoretical Unit Exposure Level Remained Significantly High
In 2025, the EU imported about 2,594 mt of CN 76042910 from China, lower than about 3,543 mt in 2024, down by about 26.8% YoY.
In H1 2026, the decline further widened, with imports down by about 51.5% YoY to about 817 mt.
The K-route benchmark value corresponding to CN 76042910 is 1.485 tCO₂e/mt, slightly lower than 1.493 tCO₂e/mt for extrusion products.
Calculated using China’s default value of 4.881 tCO₂e/mt:
4.881 × 1.1 − 1.485 × 97.5% ≈ 3.92 tCO₂e/mt
This result is only slightly higher than about 3.91 tCO₂e/mt for CN 76041090.
For Turkey, the same product classification difference makes its theoretical unit exposure for CN 76042910 about 2.67 tCO₂e/mt, while CN 76041090 is about 2.66 tCO₂e/mt.
Although the numerical differences are limited, they reflect an important principle:
even if the exact same default values apply to the same country, different CN products may still differ in their final theoretical CBAM exposure due to different benchmark values.
Therefore, accurate product classification remains a necessary condition in CBAM calculations.
UAE Supply to Europe Surged in 2025
In the supply landscape for CN 76042910, one of the most notable changes in 2025 came from the UAE.
EU imports from the UAE increased from about 337 mt in 2024 to about 2,270 mt in 2025, up over 570% YoY .
The UAE thus captured a market share of about **6.8%**.
Meanwhile, trade volumes from most traditional supplier countries declined.
In 2025, exports to the EU from Turkey, China, India, the US, Switzerland, Japan, and South Korea all decreased, while supply from Norway increased by about one-third.
Therefore, even as total market imports declined, market shares among supplier countries were still significantly reallocated.
These changes likewise should not be directly attributed to CBAM, especially as 2025 was still in the mechanism’s transition period.
However, once the formal implementation phase begins, CBAM will serve as a new cost and compliance variable, together with existing market competition factors, to shape the supply landscape.
H1 2026 Imports of Aluminum Alloy Bars and Rods Contracted Further
The weakness in the CN 76042910 market continued into 2026.
In H1 2026, EU imports were about 13,400 10kt, down about 22.9% YoY .
Turkey remained the largest supplier, with imports of about 3,276 mt , but down about 23.1% YoY .
China’s imports fell by about 51.5% YoY, and supplies to the EU from Serbia and the UAE also saw a marked decline.
On the other hand, India’s imports edged up, and Egypt’s supply also increased.
Therefore, even as the overall market continued to contract, its internal supplier structure was still adjusting rapidly.
It should also be emphasized that trade data alone cannot establish a direct causal relationship between the above changes and CBAM.
However, since the start of the formal implementation phase in 2026, the link between trade flows and carbon exposure will become increasingly worthy of attention from market participants.
The two products reflect different types of CBAM data risks.
Overall, CN 76041090 and CN 76042910 respectively illustrate two different issues in CBAM analysis of downstream aluminum products.
ForCN 76041090, the most critical issue isorigin identification.
Because more than 40% of imports in 2025 were recorded as “High seas,” trade databases alone cannot accurately map a considerable share of trade to specific countries’ default values.
ForCN 76042910, the origin identification issue is relatively small, but supply sources are highly fragmented.
This means that even when EU buyers purchase products with the same CN code, they may face significantly different levels of exposure to default values due to differences in the supplying countries.
Therefore, these two products further show that CBAM analysis is increasingly dependent on the following information:
CN8 product classification + origin + corresponding production route + precursor material emissions + verified actual emissions data.
Using only the four-digit HS code is increasingly unable to accurately reflect the true CBAM exposure situation.
The importance of verified actual emissions data may further increase.
National default values are always fallback parameters, rather than measurements of the actual emissions levels of specific producer.
This is particularly important in downstream aluminum markets where supply sources are highly diversified.
Even if two enterprises are located in the same country and export products under the same CN code, there may be clear differences in the primary aluminum, secondary aluminum, electricity sources, and upstream aluminum billet they use, and therefore the actual embedded emissions levels may also differ significantly.
If an enterprise can provide verified actual emissions data and demonstrate that its emissions level is clearly lower than the national default value, it may be possible to reduce the corresponding CBAM certificate exposure for its EU client.
Conversely, suppliers that cannot provide complete and traceable emissions information may continue to rely on national default values.
In the future, this difference may increasingly be reflected in comparisons of the total landed cost among different suppliers.
For CN 76041090, reliable origin and emissions documentation may be particularly important, because existing trade statistics already show that the market contains a considerable share of records that cannot be clearly attributed to specific countries.
The importance of product-level analysis under CBAM continues to rise.
More granular trade data indicate that HS 7604 is not a homogeneous market.
The main aluminum alloy extrusion products analyzed in Part I show a high degree of market concentration in Turkey and exhibit a clear relationship between trade volume and unit carbon exposure.
By contrast, the two relatively small products discussed in this paper present a completely different structure.
CN 76041090 recorded strong headline import growth in 2025, but a considerable share of the growth came from “High seas” statistics and temporary trade surges from certain countries, rather than broad-based expansion by the main traditional suppliers.
CN 76042910 continued to contract in 2025 and H1 2026, while market shares among Turkey, China, the UAE, India, and other supplying countries kept adjusting.
Meanwhile, because there are slight differences in the benchmark values applicable to different CN codes, even within HS 7604, the theoretical Carbon Border Adjustment Mechanism (CBAM) exposure levels of different products are not entirely identical.
As CBAM is further implemented, the competitiveness of downstream aluminum products will increasingly depend on:
the combined effects of product classification, country of origin, production route, actual embedded emissions, carbon data quality, and traditional commercial competitiveness.
For EU importers and global suppliers of aluminum products, the increasing granularity of CBAM rules means that, in procurement, contract negotiations, and supplier selection processes,detailed product-level and shipment-level data will become increasingly important.
