We support the EU’s intention to prevent carbon leakage. Instruments like the CBAM, which intends to encourage decarbonisation globally by adding a carbon price for imported goods comparable to the costs paid by EU producers, represent a highly attractive idea in principle.

Unfortunately, independent analysis requested by European Aluminium has shown why the CBAM cannot yet be considered a suitable alternative to existing EU carbon leakage protection measures. This is mainly because of the electro-intensive nature of primary aluminium production and the unique indirect carbon costs only European producers face in their power price due to the EU ETS (see a short explanation here). These costs will remain significant, even when consuming decarbonised electricity or signing long-term power contracts. Also, including indirect emissions in the CBAM increases the risk of circumvention and will not lead to a reduction in global emissions. Rather the opposite!

We, therefore, support the final agreement on the CBAM, which initially excludes the application of the CBAM on indirect emissions for sectors today eligible for indirect costs compensation under EU state aid rules. The inclusion of indirect emissions in the CBAM should be considered only once the EU electricity grid is close to being completely emission-free (very likely not before 2035) and all circumvention risks and downstream impacts have been assessed across the entire European aluminium value chain. This should include as well a detailed assessment of the consequences of the inclusion of more products upstream or downstream (see our response to the EU Commission study on this here), including precursors such as alumina (see a paper about this topic here).

European aluminium is now closely working with the European Commission and broader stakeholders on the rules for the initial emissions’ reporting period applicable to importers beginning in October 2023. A first review of the mechanism is expected in 2025.

For further information, please find our detailed position paper on the CBAM here .

Our industry is ready to work with national governments and the Commission to phase out Russian fossil fuel imports while ensuring adequate gas and electricity supplies this winter. We see this as an opportunity for boosting renewable energy capacity across the EU, which in turn spurs the demand for our metal because of its critical role in clean energy technologies.

As an electricity-intensive industry that also heavily relies on gas, any measure to reduce energy consumption will greatly impact our industry, particularly as there are few substitution possibilities in the short term. Measures must be carefully tailored and be introduced alongside adequate state aid. Moreover, further development of storage technologies or other forms of dispatchable low-carbon electricity generation (such as PPAs) is needed to address the challenge of intermittent renewable generation.

We must ensure that we do not shift from energy dependency to a broader raw material dependency, making our economy and downstream industries weaker and less resilient than our global competitors.

The European Emission Trading System Reform (Phase IV: 2021-2030), presented in July 2021, is one of the cornerstones of the European climate policy and one of the most cost-effective ways to reduce carbon emissions. Our association monitors and supports the European Commission with technical know-how to ensure the reform comprises essential elements, including adapted benchmarks and support for decarbonisation projects, while ensuring protection against carbon leakage.

The newly adopted CEEAG will be crucial to ensure the necessary national and EU funding to achieve the Green Deal’s decarbonisation objectives, regulated via the “Fit For 55” legislative package while accelerating the transformation of energy-intensive and circular industries like aluminium. State Aid can be a powerful instrument to accelerate the transformation of our industry, especially by supporting key investments and research in decarbonisation technologies that are not yet available at scale on the market today and providing regulatory relief where appropriate.

In particular, the possibility for targeted Renewable Energy Sources (RES) charge reductions under EU State Aid Rules has played a crucial role in limiting carbon leakage for our sector, given that aluminium smelters are particularly sensitive to any increase in the cost of electricity. We are working in close cooperation with the EU and the Member States to ensure they encompass all potential charges caused by the integration of new decarbonisation technologies or policies stemming from the new legislation to be proposed. It is crucial to note that new decarbonisation policies introduced in legislation often have the intended or unintended effect of increasing the electricity price for industrial consumers. These more ambitious renewable policies across Europe must be balanced by ensuring the stability of its financing base.

We are providing policymakers with all the necessary data and evidence to ensure that the CEEAG are adequately implemented and provide European aluminium producers with predictable support for the next decade (2021-2030).

As an energy-intensive industry, the aluminium sector depends on a massive and constant supply of energy. That is why European Aluminium is committed to feeding into the work of the EU institutions on the upcoming Reform of the Energy Market Design.

We will ensure the market is adapted to the long-term realities our industry will face in the years to come. To safeguard the aluminium industry in Europe, it is paramount that any reform or intervention on the market’s functioning accounts for the future predominance of renewable generation in the grid while preventing supply disruption risks.

European Aluminium will work together with EU stakeholders to guarantee the new market design leads to efficient and swift decarbonisation of the European energy system, while safeguarding security and affordability of supply, and incentivising investment into and dispatch signal for renewable energy, grid infrastructure, and storage capacity.

Because of the importance of our industry in the green transition and our electro-intensiveness, we are part of the current list of eligible sectors for the indirect carbon cost compensation regime under the ETS Phase IV.

Our association provides EU policy makers with technical know-how to provide adequate protection against carbon leakage for EU producers.

As a circular material with permanent properties, aluminium has been designated as a sustainable economic activity under the EU Taxonomy, which will facilitate investments in our industry for financial undertakings. European Aluminium provides its expertise to EU policy makers to ensure the new framework is smoothly implemented and creates an adequate and efficient framework tailored to our industry. In particular, our association focuses on developing efficient criteria for the designation of sustainable aluminium to ensure that European producers benefit from this new mechanism.

Electricity is aluminium’s lifeblood, and our industry is constantly searching for new ways to use greener energy and produce more efficiently.

To achieve our sustainability objectives, we need more rapid deployment of renewable electricity capacity and access to long-term power purchase agreements (PPAs) to shield it against extreme fluctuations in the energy markets. That’s why we are working with the energy sector and policymakers to set up long-term mechanisms to facilitate decarbonised energy production, accessibility, and consumption at globally competitive prices for energy-intensive consumers.

We actively encourage national financial guarantees that support the uptake of Renewable Energy (RES) PPAs. RES production costs have risen because of the increase in raw material costs and shortages, making it even more challenging to enter into long-term contracts. We also support the development of a future-proof legislative framework for carbon capture technologies, which will be key in fulfilling the EU’s decarbonisation objectives.

The Energy Performance of Buildings Directive (EPBD) promotes improving the energy performance of buildings in the EU. It requires Member States to apply a methodology for calculating the energy performance of buildings and to set minimum performance requirements for new buildings, buildings undergoing major renovations and for building elements. The EPBD was amended in June 2018 and is currently under revision.

We encourage the calculation of life cycle global warming potential (GWP) of buildings to include the environmental benefits from reuse and recycling at end-of-life.

When Member States set minimum performance requirements for transparent building elements like windows, European Aluminium recommends using the ‘energy balance’ methodology that considers both insulation and solar heat gains to assess their thermal performance.

The European Commission’s long-anticipated proposal for the revision of the Waste Shipment Regulation was published in November 2021. The proposal identifies progress in establishing a level playing field for EXTRA-EU shipments and the need to reduce the complexity and administrative burden associated with INTRA-EU waste shipments. This file is a key priority for the aluminium sector because it can help to ensure a continuous supply of scrap in Europe and maximise the sector’s contribution to the EU’s Circular Economy and Green Deal ambitions. We cooperate with policy makers, cross-industry partners, the full recycling value chain, and downstream partners to develop a holistic framework that can strengthen the transition to a circular economy.

The EU’s Waste Framework Directive lays down basic concepts and definitions related to waste management, including definitions of waste, recycling, and recovery. European Aluminium welcomes the Commission’s intention to revise this framework. Modernising waste legislation is a timely and necessary step to establish a resource-based framework fit for the transition to a Circular Economy and well-equipped to meet the objectives of the European Green Deal.

We are working with policy makers in developing the proposal and are providing relevant evidence and information on aluminium collection and recycling as well as the responsible management of industrial waste.

In 2020, the European Commission started working on the review of the End-of-Life Vehicle (ELV) Directive. The Commission’s proposal is expected by the end of 2022. The ELV Directive is pivotal to determining the destiny of ELVs – and the raw materials that can be found therein – in Europe. It will establish modernised rules for the collection, treatment, and data reporting for all car materials and components, including aluminium.

Given the increasing use of aluminium in automotive applications, it has become critical for the European aluminium industry to contribute to the review of legislation concerning the mobility sector’s increased circularity and environmental sustainability.

European Aluminium is working closely with the European Commission on this Directive. We want to ensure that the revised ELV Directive focuses on improving the quality of recycled materials to ensure their reuse in closed loops and high-quality applications and takes action against any illegal shipment or treatment of ELVs.

To support our recommendations, we commissioned the study Dismantling End-of-Life Vehicles for better aluminium recycling to investigate the recycling process of ELVs and evaluate the feasibility of dismantling aluminium components from ELVs before shredding. The study showed that increasing the dismantling rates of specific car components depends on profitability, access to the right information, and training. It also confirmed that the collection rates of ELVs, especially for premium vehicles, should increase. Avoiding the loss of these vehicles and ensuring their treatment in Europe could significantly increase the amount of aluminium recovered each year.

While cobalt and lithium are probably best known for being used in energy storage, batteries generally use a wide variety of minerals for the cathode, including aluminium. Aluminium is also widely used in battery enclosures.

For this reason, our sector wants to help establish a competitive and sustainable EU battery value chain and supports the EU Batteries Regulation that establishes mandatory requirements for all batteries placed on the EU market, including safety, sustainability, and carbon footprint requirements.

We support the use of life cycle assessment to assess the environmental performance of products, ambitious and realistic collection targets for portable batteries and the introduction of robust methodology and ensure a thorough impact assessment before considering the possibility of introducing the mandatory recycled content targets.

In November 2022, the European Commission published its revision of the Packaging and Packaging Waste regulation (PPWR). One of the primary goals of the proposed revision is to prevent packaging waste and make all packaging recyclable by 2030.

Aluminium is a popular packaging material for food, drinks and pharmaceutical products because it provides a total barrier function, safeguarding the product's integrity and prolonging its shelf life. Aluminium is a top performer among recycling packaging materials, with a 73% recycling rate for aluminium beverage cans in EU27, UK, EFTA, in 2020.

To achieve the EU’s goal of making all packaging reusable or recyclable by 2030, high-quality recycling must be prioritised. This requires a precise definition that includes materials like aluminium, which can be recycled over and over again without property changes and minimal material loss. Moreover, the way packaging is collected directly impacts the quantity and quality of the collected materials that can be recycled. By establishing well-functioning and modern PMD collection systems using the latest separation technologies such as double Eddy Current separators and pyrolysis, we can significantly improve the availability of high-quality recycled materials, consequently reducing our dependence on primary raw materials.

State-financed Chinese dumping undermines Europe’s trade defence and seriously harms its ability to protect jobs, innovative businesses, and entire industrial value chains.
For this reason, we applaud the Commission for imposing definitive anti-dumping rules on Chinese aluminium extrusions and proposing to regulate the import of products with foreign subsidies.
However, we strongly oppose the 9-month suspension of the regulation for Chinese anti-dumping duties on aluminium flat-rolled products. Until dumped imports get regulated, our region will be flooded with underpriced, high-carbon aluminium that jeopardises our Green Deal ambitions.

A 2021 OECD report examined state subsidies to 32 companies representing 70% of the global aluminum market. The study found that Chinese firms received state support ranging from 4% to 7% of annual revenues compared to similar support representing 0.2% of annual revenues of non-Chinese firms. These subsidies unfairly benefit Chinese production at the expense of production in Europe. They also weaken domestic supply chains for many products vital to Europe’s strategic autonomy.
The harmful effects of distortive subsidies must be tackled on a European and global level. European Aluminium welcomes the EU Commission’s initiative to propose a new instrument on foreign subsidies and calls upon the European Commission to effectively address the distortive effects of foreign subsidies in the EU single market and help create a level playing field for the aluminium industry in Europe.
Together with our American, Canadian, and Japanese counterparts, we are also advocating for a global solution to this problem and have released a joint policy brief for G7 leaders.

On 1 January 2022, the United States replaced its Section 232 tariffs on aluminum with tariff-rate quotas. Under the tariff-rate quota system, import volumes are allocated on an EU Member State basis in line with the 2018-19 historical trade volumes. Section 232 aluminium products from the EU that are within the quota will enter free of any Section 232 duty, while products entering above the quota will continue to be subject to a 10 percent duty.

We strongly oppose the tariff-rate quota system. European Aluminium and its US counterpart The Aluminum Association have called for lifting the unjustified Section 232 tariffs on EU imports since their implementation in 2018 and have submitted a concrete proposal on restoring the trading relationship between the two markets. Europe has always been an important ally of the US, and European aluminium exports to the US have never posed a threat to US national security. On the contrary, the US and European aluminium value chains are strongly interlinked, with over 15 multinationals operating in both territories.

European Aluminium welcomes the EU-US decision to develop a Global Arrangement on Sustainable Steel and Aluminium. We believe the GASA if designed correctly, can be an excellent platform for deeper cooperation between Europe, the US and other like-minded regions towards reducing global emissions and non-market behaviours by establishing a common approach based on coherence and a level playing field. The GASA can also play an important role in driving decarbonisation efforts while ensuring the competitiveness of industry players.

According to the announcement statement from 31 October, the EU and US seek to conclude their negotiations on the Arrangement by 31 October 2023. We consider the permanent removal of the Section 232 tariffs and quota system for European companies to be pivotal for starting negotiations on the implementation of such an Arrangement.

The existing World Trade Organisation (WTO) rules are inadequate to remedy the scale and scope of state intervention in the global aluminium market. Most WTO rules date back to 1995, when the organisation was established, and before China was the dominant player it is now. The rules should be redesigned to address global market distortions resulting from subsidies. The WTO should also provide tools to assess the impact of government support throughout the whole value chain and better account for the influence of state actors, given the dual role of some State-Owned Enterprises as both recipients and providers of support.

Trade is not just about business. European Union trade policy has had a significant impact on other policies such as climate change, social rights, safety, and standards. This policy linkage is critical for our industry to lead on sustainability and promote environmental, health, and safety (EHS) standards globally. For this reason, we welcome new free trade agreements with trade partners that comply with the Paris Agreement, high labour standards, and equal standards in terms of consumer/employee health and safety.

The European Commission’s Industrial Emissions Directive (IED) is a critical piece of legislation to achieve a high level of protection for the health of humans and the environment. The Directive is currently being revised and is expected to be implemented in 2023.

European Aluminium is a member of the Industrial Emissions Alliance group and actively cooperates with the European Parliament and Council to revise the IED. Thanks to our expertise in industrial emissions, European Aluminium is an active stakeholder in all matters pertaining to the IED, its implementation at the Member State level, and the drafting of Best Practices Reference Documents (BREFs) for the industry through the Sevilla process.

The aluminium value chain in Europe complies with the highest health and environmental protection standards. We are working with policy makers to ensure that the Best Practice Reference Documents (BREFs) provide a viable approach to determining the Best Available Techniques (BATs) for minimising industrial emissions. We want to ensure that the Best Available Techniques Emission Limit Values (BAT-AELs) in these documents are aligned with what our industry can realistically achieve while remaining a pioneer in environmental compliance.

REACH is the EU Regulation on Registration, Evaluation, Authorisation and Restriction of Chemical substances, aiming to improve the protection of human health and the environment by thoroughly assessing the properties of chemical substances produced in Europe or imported and regulating their safe use accordingly. The REACH Regulation is currently under revision after ten years of operation. The legislative proposal is expected by the last quarter of 2022.

Together with the non-ferrous metals association Eurometaux, we have identified five key areas of improvement that will make the revised REACH regulation more effective:

1. Evaluate each substance’s actual exposure and risks
2. Recognise the Risk Management Option assessment tool
3.  Make authorisation specific for each substance use
4. Boost the use of REACH registration datasets
5. Prevent duplication of risk management requirements

The most relevant substances for our industry in this context are produced substances such as aluminium metal, aluminium oxide and aluminium hydroxide, but also several other substances used in the production process such as, among others, the coal tar pitch in the production of anodes for primary aluminium smelting.

In 2005, we formed The Aluminium REACH Consortium with the International Aluminium Institute to help the aluminium industry comply with REACH legislation by providing the necessary information on REACH classifications and risk assessment.

Alongside REACH, the revised CLP Regulation, which aligns the EU system of classification, labelling and packaging of chemical substances and mixtures to the Globally Harmonised System, will be critical to successfully implementing the EU’s Chemicals Strategy for Sustainability. A legislative proposal and the accompanying impact assessment are expected by the last quarter of 2022.

The European Commission will soon introduce a new harmonised environmental classification for lead metal. The last proposal by the ECHA Risk Assessment Committee (RAC) deviated substantially from ECHA’s metal’s current classification guidance (and was not in line with the harmonised classification of other metals). The result is a significant challenge for the metals industry. In light of the Commission’s ambition to establish a risk-based chemicals framework, we advocate maintaining a workable approach to metal classification and ensuring that the implementation of this environmental classification is viable for the aluminium industry.

The CRM Act provides an opportunity to deliver a European industrial agenda supporting sustainable growth and our bloc’s strategic autonomy while ensuring raw materials production and transformation at the highest environmental and social standards. Creating greater complementarity between the different policy areas will further help to ensure the success of the twin transition and deliver the objectives of the EU Green Deal.

However, the classification of European raw materials must be improved, and raw materials that aren’t deemed ‘scarce’ or ‘rare’ should not be left behind. Policy makers should introduce measures for all raw materials industries to help increase their supply security, obtain greater investments, and scale up recycling capacity to recover valuable secondary raw materials.

European Aluminium stands ready to collaborate with the co-legislators to ensure that the Act includes aluminium and delivers on its promise to create a supportive regulatory environment for raw material supply chains and the net-zero industries they serve.

The NZI Act aims at maintaining competitiveness and reducing strategic import dependencies in key net-zero technology products and their supply chains, to make the European Union more investment and innovation friendly.

The Act recognises that for hard-to-abate sectors, including energy-intensive industries, the number of commercially available and scalable net zero technologies is currently limited. For those net zero technologies already in use or in the early stages of development, major reductions in cost and improvements in performance will be needed. Therefore, investments in research and innovation both at Union and national level continue to be important.

Nevertheless, the Act's wording could be improved. European Aluminium believes that there should be a stronger wording about carbon leakage, and especially investment leakage for trade and electro-intensive industries.

In March 2022, the European Commission presented its proposal for an Ecodesign for Sustainable Products Regulation (ESPR) as part of its wider Circular Economy Action Plan. This initiative, which will build on the Ecodesign Directive and propose additional legislative measures as appropriate, aims to make products placed on the EU market more sustainable.

A well-balanced approach adapted to our value chain will allow for a smooth and accelerated transition to a resource-efficient, low-carbon, and circular economy, which can help realise the EU’s Green Deal’s sustainability objectives. It also can help ensure coherency and complementarity between all policy areas relevant to our sector. To fulfil the ESPR principles and harness their full potential, each covered product category must be scrutinised in detail and carefully assessed.

European Aluminium will work towards ensuring ESPR market instruments are tailored to support the uptake of sustainable products, and its implementation comes with continued work on standards and coherence with existing legislation as well as proportional and adapted Digital Product Passport (DPP) requirements.

The Construction Products Regulation (CPR) lays down harmonised rules for the marketing of construction products in the European internal market and provides a common technical language to assess construction products’ performance. Declaration of Performance (DoP) and CE marking are key parts of it.

European Aluminium introduced simplified procedures that allow affordable compliance for manufacturers. Guidance documents for CE marking and declaring performance (DoP) under the Construction Products Regulation (No 305/2011) can be found in the resource centre.

The CPR is currently under revision.

Safety in the workplace is a core concern of the European aluminium industry. Our members fully embrace a workplace safety culture and continuously look for improved ways to reduce their employees’ exposure to risk.

The European aluminium industry listens to external experts and leverages advances in information and communication technology to reduce this further. Our members have already reduced the total recordable incident rate for the industry – a measure of the total number of fatalities, lost time accidents, restricted work cases, and medical treatment cases per million hours worked – by 80% since the 1990s.

As part of our continuous commitment to improving safety, European Aluminium organises a Safety Workshop every two years. This workshop allows our members to gather and share best practices and showcase any innovations in safety. We recognise and celebrate initiatives with our ‘Safety Solutions’ competition as part of this biennial event. Our member companies present their best safety solutions at the individual plant level. This encourages all staff to take an interest in improving safety.

The aluminium industry wants to create long-term and tangible socio-economic value for the local communities in which it operates. We are working with our members to ensure that each aluminium production facility has a programme to share value with the local community.

Aluminium is one of the most common elements on earth. It is the most abundant metal found in the earth’s crust. It is used in a wide range of applications.

Some of these applications are familiar and visible. Think about aluminium pans, beverage cans, or household foil, for example. But aluminium is also in things we don’t see. It occurs naturally in the air we breathe, the water we drink and the food we eat. It plays an important role in medicines, vaccines and cosmetics.

Given aluminium’s widespread occurrence in both the environment and commercial applications, its safety has been thoroughly investigated. There is no evidence that aluminium poses a health risk. Despite this, a number of myths persist. Together with International Aluminium, we are committed to dispelling myths and providing accurate scientific data on occupational and consumer health related issues.