CBAM entered its definitive regime on 1 January 2026, but it is not accurate to say that every EU buyer of every aluminium casting has the same obligation. The first questions are the product's customs classification, whether that CN code is in the current CBAM scope, who acts as the importer, and whether the importer crosses the applicable annual threshold.
The 50-tonne threshold
The EU's 2025 simplification amendment introduced a single mass-based threshold of 50 tonnes of net mass per importer per calendar year for goods in the four covered mass-based sectors, including aluminium. Importers above that threshold need to address authorised CBAM declarant and certificate obligations. Importers below it may qualify for the threshold exemption, subject to the regulation's aggregation and anti-circumvention rules.
The threshold is not a per-shipment allowance and it should not be applied from a product description alone. Use the importer of record, all relevant covered imports and the current regulation when making the calculation.
Official references:
A casting is not automatically in scope
"Aluminium casting" is a manufacturing description, not a customs classification. A finished housing, valve body or machined component may have a different CN code from unwrought aluminium or a basic aluminium article. Confirm the exact code and the current Annex I scope with the importer or customs adviser.
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Send the drawing, target alloy, finishing scope, MOQ, and delivery timing. Bohua will review it like a real sourcing project, not a generic contact request.
Do not copy a supplier's suggested code into the customs declaration without review. Geometry, function, degree of machining and the complete imported assembly can affect classification.
What an in-scope importer may need from the supplier
If the code and threshold checks put the import in scope, define the data request in the RFQ. Useful fields include:
- •installation and production-route identification;
- •reporting period and quantity basis;
- •direct and indirect embedded-emissions data required by the current CBAM method;
- •data source, calculation method and supporting records;
- •alloy and precursor information relevant to the declared route;
- •a named contact for questions, corrections and verification.
Do not assume that a recycled-content statement by itself is a compliant emissions record. Recycled content, primary metal source, energy and process data may all be relevant, but the accepted calculation and evidence must follow the current EU rules.
RFQ checklist for EU-bound aluminium castings
Before award, ask the importer or customs team to confirm:
- •the proposed CN code and the basis for it;
- •whether the code is in current CBAM scope;
- •which legal entity is the importer of record;
- •the entity's aggregated covered net mass for the calendar year;
- •whether authorised-declarant status is required;
- •the supplier data fields, reporting period and verification format;
- •who owns corrections if customs classification or emissions data changes.
For the casting supplier, send the drawing, alloy, process route, annual volume, destination and requested CBAM data template with the RFQ package.
*This article provides procurement guidance, not legal, customs or emissions-verification advice. Confirm the current CN code, threshold calculation and CBAM duties with the European Commission guidance and a qualified customs or CBAM adviser.*
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