Guides. Omar Hamdy, on the lender's side, in Cairo. Written in a personal capacity.

Last checked 2 November 2026

CBAM for Egyptian aluminium: unwrought metal and simple products, the defaults, and a mark-up that triples

Aluminium is Egypt's second CBAM line by worth: EUR 615.5m into the EU in 2025 across the covered codes, led by unwrought metal (EUR 339.7m) and plates and sheets (EUR 177.1m). Unlike fertilisers, the mark-up on aluminium defaults rises from 10% to 30%, so the cost of staying on the default grows every year to 2028. This page applies the CBAM hub for Egyptian exporters to unwrought aluminium and the simple products rolled, extruded or drawn from it.

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What counts as aluminium under CBAM

Annex I of Regulation (EU) 2023/956 covers headings 7601, 7603 to 7614 and 7616. This page covers the metal and the simple products made from it; structures (7610), containers (7611 to 7613), stranded wire (7614) and articles (7616) are covered by CBAM too, with their own defaults.

Sources: defaults, Implementing Regulation (EU) 2025/2621, Annex I, Egypt table, as replaced by (EU) 2026/1740, read from the Commission's Excel transcription of 6 August 2026 (the regulation is the binding text). Benchmarks, Implementing Regulation (EU) 2025/2620, Annex, Commission Excel of 6 February 2026, primary route (K) unless stated; Column A for products is the process step only, to which the benchmark of the unwrought aluminium used is added.

How Egypt compares, for the two largest lines:

Source: Implementing Regulation (EU) 2025/2621, Annex I, as replaced by (EU) 2026/1740, country tables.

Two things follow. Egypt's default for the metal matches the UAE's. For sheet, Egypt's default is 36% above the UAE's and close to the figure for countries with no entry at all, so an Egyptian rolling mill on defaults competes for EU buyers at a disadvantage that its data could remove.

EU imports of aluminium from Egypt

In 2025, unwrought aluminium split into unalloyed metal (7601 10, EUR 219.1m, 86,992 tonnes) and alloys (7601 20, EUR 120.6m, 48,441 tonnes, mostly billets and foundry alloys). Egypt supplied 2.1% of the unwrought aluminium and 6.0% of the plates, sheets and strip the EU imported from outside the EU in 2025, by tonnes.

Source: Eurostat Comext, dataset DS-045409, reporter EU, partners Egypt and extra-EU, imports, CN 7601 to 7608 and eight-digit lines, annual, dataset version of 16 October 2026, queried 2 November 2026. Shares are my division of Egypt's tonnes by extra-EU tonnes (6,334,662 for 7601 and 1,083,281 for 7606 in 2025). No imports of 7603 from Egypt are recorded in 2025.

The default and the mark-up, year by year

Sources: mark-ups, Implementing Regulation (EU) 2025/2621, Annex I, opening paragraphs, as replaced by (EU) 2026/1740; CBAM factor, Directive 2003/87/EC, Article 10a(1a); benchmarks as above (1.423 for 7601, 1.485 for 7606). The cross-sectoral correction factor is taken as 1, its maximum. Egypt has no carbon price, so nothing is deducted for carbon paid at home.

For the whole flow, as an illustration. If the 2025 tonnes entered again, all on the Egyptian default, importers would owe about 90,700 certificates for unwrought metal and 164,100 for sheet in 2026; about 155,800 and 218,200 in 2028; and about 329,200 and 304,600 from 2034. Sheet, at less than half the tonnes, needs more certificates than the metal through 2030. This is my arithmetic, not a forecast.

Worked example and calculator

The smelter is fictional and the "actual" figure is an assumption chosen to show the arithmetic, not a benchmark for any real Egyptian plant. P is the certificate price in euros per tonne of CO2e, from the Commission's "Price of CBAM certificates" page.

Inputs (illustrative): 5,000 tonnes of unwrought primary aluminium, CN 7601, produced and imported in 2027. Verified direct emissions 1.600 tCO2e per tonne (assumed).

1. Embedded emissions. Default: 5,000 x 1.870 x 1.20 = 11,220 tCO2e. Actual: 5,000 x 1.600 = 8,000 tCO2e.
2. Deduction. The same on both, because the primary benchmark is 1.423 in both columns: 5,000 x 1.423 x 0.95 = 6,759.25 tCO2e.
3. Certificates. Default: 4,460.75. Actual: 1,240.75.
4. Cost. Default: 4,460.75 x P. Actual: 1,240.75 x P. The gap is 3,220 x P.

The break-even moves with the mark-up. For unwrought primary aluminium the deduction is the same on both bases, so actual data is cheaper whenever the verified direct figure is below the default with its mark-up: 2.057 in 2026, 2.244 in 2027 and 2.431 from 2028. A smelter above those lines is cheaper on Egypt's default. The gap per tonne in the example grows from 0.457 in 2026 to 0.831 from 2028: the mark-up alone raises it by 82%.

For sheet, foil, profiles and wire the calculator shows the default only. On actual data the benchmark is the process figure plus the benchmark of the unwrought aluminium consumed, and the embedded emissions include that metal's own figure, so the result depends on precursor data this page does not model. The direction is clear: Egypt's 3.624 default for sheet sits far above the 1.870 for the metal it is rolled from, and a rolling mill that can document its ingot and its own process emissions has more to gain from actual data than any other aluminium line.

Work it out: certificates and cost

CN line7601: Unwrought aluminium, primary route7604 10 10: Bars and rods (also 7604 29 10)7604 10 90: Profiles (also 7604 21 00, 7604 29 90)7605: Aluminium wire7606: Plates, sheets and strip over 0.2 mm7607: Foil, 0.2 mm or less7608: Tubes and pipes

Import year202620272028202920302031203220332034

Tonnes imported into the EU

Certificate price P, EUR per tonne of CO2eType the current figure from the Commission's page. This site states no price.

Your verified emissions, tCO2e per tonne (optional)Direct plus indirect where they count. Leave empty to see the default only.

Illustrative arithmetic on public figures, not advice for a shipment. Cross-sectoral correction factor taken as 1, its maximum; a lower factor shrinks the deduction. No carbon price paid in Egypt is deducted.

Defaults: Implementing Regulation (EU) 2025/2621 as replaced by 2026/1740. Benchmarks: 2025/2620. CBAM factor: Directive 2003/87/EC, Article 10a(1a).

The calculator runs in your browser and sends nothing. Certificates equal embedded emissions minus the benchmark times the CBAM factor, never below zero.

What your EU importer and the verifier will ask for

• The CN line at eight digits, shipment by shipment, matched to the customs declaration. The default for 7606 is almost double that for 7601.
• Installation identity: operator, address, coordinates and main activity, the fields used to register an installation in the EU CBAM registry (Article 10 of Regulation (EU) 2023/956).
• Production route: primary (electrolysis) or secondary (remelting scrap). The route sets the benchmark: 1.423 for primary, 0.091 for secondary metal.
• Direct emissions per tonne, for the reporting period, calculated under Implementing Regulation (EU) 2025/2547: anode consumption, perfluorocarbons from anode effects, and fuel for casting and holding furnaces at a smelter; fuel for reheating and annealing at a rolling or extrusion plant.
• Precursors for products: tonnes of unwrought aluminium per tonne of product, where it was made and its embedded emissions. If the country of the metal cannot be identified, Annex IV of 2025/2621 (as replaced) applies 3.198 tCO2e per tonne.
• A verification report from an accredited verifier, if the importer is to declare on actual data (Article 8 and Annex VI).
• A named contact and a date for next year's update.

Electricity data is still worth keeping. It does not count towards aluminium certificates under the current rules, but buyers ask for full footprints for their own reporting.

The lender's view

The mark-up makes data a dated asset. For aluminium the cost of staying on the default rises by 20 points in 2027 and another 10 in 2028. A rolling mill or extruder that gets verified data in place before 2028 avoids the steepest part of that rise; one that waits pays for it.

What a lender wants to see before counting a CBAM benefit in a decarbonisation loan:

• The right lever. Because only direct emissions count, a solar plant or a renewable supply contract cuts a smelter's power bill and its reported footprint but not its CBAM certificates. Projects that move the CBAM figure are those that cut direct emissions: anode and process control that reduces perfluorocarbons, furnace efficiency, fuel switching in casting and reheating, and more scrap where the product allows it.
• A verified baseline per CN line, with the route stated. A cut in emissions at a plant that stays on defaults changes nothing on the bill.
• For rolling mills and extruders, the precursor file. Where the metal comes from, with its figure, is often the largest single number in a product's embedded emissions.
• Who captures the saving. The importer buys the certificates. A pricing clause or a buyer's letter that passes part of the saving back is worth more to the credit file than an estimate.
• The result at several certificate prices and for 2026 to 2028. The calculator gives the certificate count for each year; multiply by your own price range.

Next steps

1. Confirm the eight-digit CN line and the route of every product you ship to the EU.
2. Run the calculator for 2026, 2027 and 2028 at three prices from the Commission's page.
3. For unwrought metal, compare your best estimate of direct emissions with 2.057, 2.244 and 2.431. For products, start the precursor file now.
4. Ask each EU buyer which basis they will declare on and when they need your data.
5. Read the CBAM hub for Egyptian exporters for the rules common to every product, including the proposed extension to more downstream aluminium goods (a proposal, not law).

Frequently asked questions

What is Egypt's CBAM default for aluminium?

1.870 tCO2e per tonne for unwrought aluminium (7601) and 3.624 for plates, sheets, strip (7606) and foil (7607), before the mark-up. Bars, rods and wire are 2.997; profiles and tubes 3.025.

What mark-up applies to aluminium defaults?

10% in 2026, 20% in 2027 and 30% from 2028 onwards. Fertilisers stay at 1%; aluminium does not.

Does solar power reduce CBAM costs for an aluminium smelter?

Not under the current rules. Only direct emissions count for aluminium, so electricity, however clean, does not change the certificate count.

How many CBAM certificates does a tonne of Egyptian unwrought aluminium need?

On the default, about 0.67 in 2026, 0.89 in 2027, 1.15 in 2028 and 2.43 from 2034, taking the correction factor at 1. Multiply by the certificate price from the Commission's page.

Is Egypt's aluminium default higher than the Gulf's?

For unwrought metal it equals the UAE's and Bahrain's (1.870) and is above Saudi Arabia's, Oman's and Qatar's (1.700). For sheet it is 3.624 against 2.660 for the UAE and 2.490 for Saudi Arabia.

Send me what you received

If your EU buyer, a verifier or your lender has sent you a CBAM request about aluminium, send it to me in five short lines: what you received, from whom, the deadline, your sector, and what you want to know. I'll reply by email.

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Guides, checks, toolkit and newsletter are free. Advisory is paid work in a personal capacity: scope agreed in writing, fee quoted after a free first call.

I don't arrange finance, introduce lenders or work on files for my employer's credit decisions. Every enquiry gets a conflicts check before any work.

Sources

Legal texts (Official Journal of the European Union)

1. Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism, Articles 6, 8, 10, 20, 21, 22 and Annexes I, II and VI eur-lex.europa.eu
2. Regulation (EU) 2025/2083 amending Regulation (EU) 2023/956 eur-lex.europa.eu
3. Commission Implementing Regulation (EU) 2025/2621 on CBAM defaults, Annexes I and IV eur-lex.europa.eu
4. Commission Implementing Regulation (EU) 2026/1740 of 20 July 2026 correcting Annexes I and IV of 2025/2621 eur-lex.europa.eu
5. Commission Implementing Regulation (EU) 2025/2620 on the free allocation adjustment and CBAM benchmarks eur-lex.europa.eu
6. Commission Implementing Regulation (EU) 2025/2547 on the methods for calculating embedded emissions eur-lex.europa.eu
7. Directive (EU) 2023/959 amending Directive 2003/87/EC, Article 10a(1a), CBAM factor eur-lex.europa.eu

European Commission

8. CBAM legislation and guidance, with the Commission's Excel files of default figures (version of 6 August 2026) and benchmarks (6 February 2026) for the definitive period taxation-customs.ec.europa.eu
9. Price of CBAM certificates taxation-customs.ec.europa.eu

Trade data

10. Eurostat Comext, DS-045409, reporter EU, partners Egypt and extra-EU, imports, CN 7601 to 7608, 2023 to 2025 (dataset updated 16 October 2026, queried 2 November 2026) ec.europa.eu

Reported, not law

11. EnterpriseAM, "It looks like we might get a break on the EU's carbon tax", 12 January 2026 enterpriseam.com

All views are my own, written in a personal capacity. They do not represent my employer or any other institution. This page explains public rules; it is not legal or tax advice for a specific shipment.

Cite this guide

Other CBAM pages

• CBAM for Egyptian exporters
• CBAM for Egyptian urea
• CBAM for Egyptian ammonia
• CBAM for Egyptian cement and clinker