Following the start of the definitive phase of the EU Carbon Border Adjustment Mechanism (CBAM) in 2026, differences in country-specific default values , default production routes and corresponding benchmarks have begun to translate into significantly different theoretical certificate exposures for unwrought aluminium. SMM analysed EU-27 imports of unwrought aluminium under HS/CN 7601 from non-EU origins and matched the trade data with the 2026 default value, default production route and CBAM benchmark assigned to each origin. The theoretical unit certificate exposure in this analysis is calculated as: 2026 theoretical unit certificate exposure = 2026 default value − benchmark × 97.5% × cross-sectoral correction factor The cross-sectoral correction factor, or CSCF, is provisionally assumed to be 1. The calculation does not deduct any qualifying carbon price effectively paid in the country of origin. The results therefore indicate the relative CBAM exposure of different origins under the default-value scenario. They do not represent the final number of certificates that EU importers will be required to surrender or the final monetary cost. EU-27 unwrought aluminium imports rose 7.0% in 2025 According to SMM calculations, EU-27 imports of unwrought aluminium under HS/CN 7601 from non-EU origins reached approximately 7.63 million tonnes in 2025 , up from 7.13 million tonnes in 2024. This represented an increase of about 502,200 tonnes, or 7.0% year on year . Of the 2025 total, approximately 4.56 million tonnes originated from countries subject to CBAM, accounting for 59.7% of total imports. Imports from CBAM-exempt origins, including Norway, Iceland and Switzerland, amounted to approximately 3.05 million tonnes , representing around 40.0% of the total. A further 25,800 tonnes were recorded without a specified origin and were excluded from the country-level exposure ranking. Applying the 2026 default values and benchmarks to the 2025 trade structure produces an estimated theoretical certificate exposure of approximately 4.09 million tCO₂e for imports from CBAM-covered origins. The trade-weighted average unit exposure was approximately 0.898 tCO₂e per tonne of product . As 2025 remained within the CBAM transitional period, these figures are scenario-based estimates using 2025 trade volumes and the 2026 calculation rules. They do not represent actual certificate obligations for 2025. Primary aluminium route accounted for more than 99% of theoretical exposure The primary aluminium route dominated both CBAM-covered import volumes and theoretical certificate exposure. In 2025, imports assigned to the primary aluminium route totalled approximately 4.46 million tonnes , accounting for 97.8% of imports from CBAM-covered origins. Their theoretical certificate exposure reached approximately 4.06 million tCO₂e , representing 99.3% of the total exposure. The trade-weighted average unit exposure for the primary aluminium route was approximately 0.912 tCO₂e per tonne of product . By comparison, imports assigned to the secondary aluminium route amounted to approximately 99,500 tonnes, or 2.2% of CBAM-covered imports. Their theoretical certificate exposure was approximately 30,600 tCO₂e, with an average unit exposure of around 0.307 tCO₂e per tonne . The gap between the two routes reflects differences in both country default values and the applicable benchmarks. For HS/CN 7601, the benchmark used for the primary aluminium route is 1.423 tCO₂e per tonne , compared with 0.091 tCO₂e per tonne for the secondary aluminium route. This means that, under a default-value declaration scenario, the theoretical CBAM exposure of EU-27 unwrought aluminium imports remains highly concentrated in primary aluminium supply. Mozambique recorded the highest unit exposure, with China also ranking near the top The results show a clear divergence in theoretical unit exposure among origin countries. Mozambique recorded the highest unit exposure among major origins with a country-specific default value, at approximately 2.130 tCO₂e per tonne of product . China followed at approximately 1.913 tCO₂e per tonne , placing it among the origins with the highest default-value-based unit exposure. South Africa recorded an estimated unit exposure of approximately 1.207 tCO₂e per tonne , followed by Russia at 0.989 tCO₂e and Canada at 0.769 tCO₂e. Bahrain, the United Arab Emirates, India, the United Kingdom, Egypt and Kazakhstan share similar default values under the primary aluminium route, resulting in unit exposure of approximately 0.670 tCO₂e per tonne . Australia, Brazil, Malaysia, Oman, Qatar, Saudi Arabia and the United States recorded unit exposure of approximately 0.483 tCO₂e per tonne . Origins assigned to the secondary aluminium route generally recorded approximately 0.307 tCO₂e per tonne . A high unit exposure does not necessarily mean that an origin faces the greatest aggregate impact. Total exposure also depends on the volume of trade with the EU-27. China illustrates this distinction. EU-27 imports of HS/CN 7601 products from China reached approximately 12,400 tonnes in 2025 , up 24.3% year on year. This corresponded to theoretical certificate exposure of about 23,700 tCO₂e . China therefore ranked near the top on a unit basis, but its comparatively limited shipment volume to the EU-27 kept its aggregate exposure well below that of Mozambique, Canada and several major Gulf suppliers. Mozambique’s total theoretical exposure reached 1.34 million tCO₂e After incorporating 2025 import volumes, Mozambique emerged as the origin with the highest aggregate theoretical certificate exposure. EU-27 imports from Mozambique reached approximately 628,000 tonnes in 2025 , up 17.5% year on year. Based on unit exposure of 2.130 tCO₂e per tonne, its total theoretical exposure was approximately 1.34 million tCO₂e . Mozambique alone accounted for 32.7% of the theoretical exposure associated with CBAM-covered origins. However, the above total exposure is a static estimate based on 2025 trade volumes. Power supply constraints may limit Mozambique’s aluminium smelting capacity and output in 2026–2027, potentially reducing its exports to the EU. As a result, its actual near-term aggregate CBAM exposure may not reach the theoretical level estimated using 2025 trade volumes. Canada supplied approximately 682,800 tonnes to the EU-27 in 2025. Although its unit exposure was considerably lower than Mozambique’s, its larger trade volume lifted its aggregate theoretical exposure to approximately 524,800 tCO₂e , equivalent to 12.8% of the total. Bahrain, the United Arab Emirates, Russia and South Africa recorded theoretical total exposures of approximately 350,900 tCO₂e, 329,300 tCO₂e, 322,200 tCO₂e and 263,600 tCO₂e, respectively. Mozambique, Canada, Bahrain, the United Arab Emirates, Russia and South Africa together accounted for approximately 76.4% of total theoretical certificate exposure. Mozambique’s position was driven by the combination of a high unit default-value exposure and substantial trade volume. Canada’s unit exposure was not among the very highest, but its large and rapidly increasing export volume significantly amplified its aggregate impact. Four-quadrant analysis places China in the “high intensity, low trade volume” category A four-quadrant analysis using 2025 EU-27 import volume on the horizontal axis and 2026 theoretical unit certificate exposure on the vertical axis provides a clearer view of the combined influence of carbon intensity and trade scale. The core high-exposure quadrant includes Mozambique, Canada, Bahrain, the United Arab Emirates, Russia, South Africa, India and the United Kingdom. These origins combine comparatively large trade volumes with relatively high unit exposure and are the main contributors to aggregate CBAM exposure for EU-27 unwrought aluminium imports. China is the most prominent origin in the high intensity, low trade volume quadrant . Its theoretical unit exposure of approximately 1.913 tCO₂e per tonne is second only to Mozambique, but its current export volume to the EU-27 remains comparatively limited. Ukraine and South Korea are among the origins in the trade-volume-driven quadrant . Both are assigned to the secondary aluminium route and have relatively low unit exposure, but their larger trade volumes increase their aggregate exposure compared with other secondary-route origins. Vietnam, Morocco, Serbia, Bolivia and Mexico are among the origins in the low-exposure quadrant , reflecting both lower unit exposure and limited trade volumes. For Vietnam, HS/CN 7601 unwrought aluminium is assigned to the secondary aluminium default route, resulting in theoretical unit certificate exposure of approximately 0.307 tCO₂e per tonne in 2026, significantly below that of most origins assigned to the primary aluminium route. EU-27 imports from Vietnam amounted to approximately 7,100 tonnes in 2025, down around 27.1% year on year, corresponding to theoretical total certificate exposure of about 2,200 tCO₂e. Vietnam’s overall CBAM exposure therefore remains relatively limited at present. However, should its exports to the EU expand in the future, access to and verification of actual emissions data will remain an important factor affecting the relative competitiveness of Vietnamese products. The quadrant thresholds are analytical dividing lines based on the median values of CBAM-covered origins with actual trade. They do not represent regulatory thresholds set by the EU. Theoretical exposure reached approximately 642,400 tCO₂e in Q1 2026 In the first quarter of 2026, EU-27 imports of unwrought aluminium under HS/CN 7601 from non-EU origins reached approximately 1.52 million tonnes , with a total import value of around €4.36 billion . The average import value was approximately €2,873 per tonne . Imports from CBAM-covered origins amounted to approximately 782,800 tonnes , accounting for 51.6% of total imports. Imports from CBAM-exempt origins reached around 733,000 tonnes, or 48.4%. Based on the 2026 default values and benchmarks, imports from CBAM-covered origins generated theoretical certificate exposure of approximately 642,400 tCO₂e during the quarter. Mozambique remained the largest contributor, with theoretical exposure of around 150,500 tCO₂e. Canada followed with approximately 86,800 tCO₂e, the United Arab Emirates with 82,100 tCO₂e, Bahrain with 63,400 tCO₂e and South Africa with 56,200 tCO₂e. As the analysis does not include Q1 2025 comparison data, no year-on-year conclusion has been drawn for Q1 2026 import volumes or exposure. The quarterly figures are used primarily to illustrate the origin structure during the initial stage of the definitive CBAM period. Access to and verification of actual emissions data could become an important competitiveness factor Country default values are fallback parameters applied when producers are unable to provide actual emissions data that meet EU requirements. They do not necessarily reflect the actual carbon intensity of a specific producer or shipment. For origins with relatively high default-value exposure, including China, Mozambique, South Africa and Russia, producers whose actual embedded emissions are materially lower than the applicable country default value could reduce the certificate exposure faced by EU importers by establishing robust emissions-monitoring systems and providing complete, verified emissions data. Conversely, where suppliers are unable to provide emissions information that is complete, traceable and compliant with EU requirements, importers may have to rely on the relevant country default value. A higher default value could consequently affect supplier selection, purchase negotiations and long-term contract arrangements. The final number of certificates to be surrendered will also depend on actual embedded emissions, production-route classification, data verification and any qualifying carbon price effectively paid in the country of origin. The actual CBAM cost will additionally depend on the CBAM certificate price, which is linked to EU Emissions Trading System allowance prices. The theoretical certificate exposure calculated in this analysis should therefore not be interpreted directly as either the final certificate obligation or the final CBAM cost. Overall, the impact of CBAM on trade in HS/CN 7601 unwrought aluminium will not be determined by country default values alone. Unit certificate exposure, trade scale, actual emissions and the availability of reliable carbon data will jointly shape the competitive position of different origins and producers in the EU market. As the definitive phase progresses, differences in low-carbon production capability, emissions-data management and verification capacity are likely to become increasingly visible in procurement decisions, export competitiveness and trade flows. Data note: The trade scope covers EU-27 imports of unwrought aluminium under HS/CN 7601 from non-EU origins. CBAM-exempt origins, including Norway, Iceland and Switzerland, are included in total import statistics but excluded from theoretical certificate exposure. Origins without a country-specific default value are assigned the applicable value for “Other Countries and Territories.” Unspecified origins are excluded from the country ranking. Theoretical exposure does not deduct qualifying carbon prices paid in third countries. Source: EU-27 import data, EU CBAM default values and benchmarks; compiled by SMM.

Rising compliance costs, a verification bottleneck, and tightening EU import quotas combine to reshape the competitive landscape for Asian stainless steel suppliers in Europe from 2026 onward. The EU CBAM entered its definitive implementation phase on January 1, 2026 — transitioning from a reporting exercise into a mechanism with real trade cost implications.

According to market sources, the EU's Carbon Border Adjustment Mechanism (CBAM) concludes its first definitive quarter today with multiple unresolved administrative hurdles. The EU Commission is set to announce the initial CBAM certificate price on April 7, yet country-specific default values remain flawed, hindering reliable cost calculations. Furthermore, the tender for the central trading platform has faced delays, and a backlog of nearly 10,000 companies awaits registration. The system's viability is further challenged by a severe lack of certified emissions validation bodies and looming changes to the EU Emissions Trading System (ETS) benchmarks, which directly dictate CBAM pricing structures and future allocations.

According to Assofermet, the Italian steel market remained weak in February amid widespread caution along the supply chain and mounting regulatory uncertainties. In the stainless steel segment, selling prices saw a further increase—rising by 10% since November 2025—but this was driven primarily by supply constraints rather than any real recovery in stagnant downstream consumption. The broader market is heavily weighed down by the application of default values for CBAM calculations and new EU safeguard measures, which are structurally increasing the cost of imported steel. Coupled with macroeconomic weakness in Germany and France, and escalating Middle East geopolitical tensions pushing up energy and transport risks, market sentiment remains highly cautious.

The champagne corks in Brussels may have popped too soon. On January 14, 2026, the European Commission released a soaring press statement celebrating the official entry of the Carbon Border Adjustment Mechanism (CBAM) into its "Definitive Regime." In the official narrative, this was a triumph of digitalization: over 10,000 customs declarations verified in real-time, with the system running as smooth as silk. However, if we shift the lens from the desks of Brussels to the customs brokers in Hamburg, the steel traders in Rotterdam, and the customs officials currently drowning in paperwork across the continent, a starkly different picture emerges. What we are witnessing is a carefully whitewashed administrative "cardiac arrest." Forensic-level investigation into the first seven weeks of 2026 reveals that the landing of CBAM is far from the glitz claimed by officials. On the contrary, plagued by suspected low-level data errors, catastrophic approval backlogs, and teetering temporary patches, the mechanism is currently mired in a dual crisis of legality and operations. I. The Absurd "Default Values": When Taiwan’s Stainless Steel "Became" Indonesian Coal If one were to find a single representative footnote for this chaos, the "Default Value Controversy" would be the undisputed choice. For importers unable to obtain precise carbon emission data from upstream factories, the EU’s official "default values" are a lifeline. This was supposed to be a baseline derived from rigorous scientific calculation. Yet, in the 2,400-page document released on December 31, 2025, mere hours before the new rules took effect, industry experts witnessed a jaw-dropping scene. This is not merely a margin of error; it looks more like a metallurgical farce. Industry bodies have pointed out that when the Directorate-General for Taxation and Customs Union (DG TAXUD) established the carbon emission default values for stainless steel from the Taiwan region, the data tables contained suspected structural errors, bearing traces of a "copy-paste" job from Indonesian data structures. The consequence? In the physical world, processing a steel slab into a precision tube requires significant electricity, meaning the finished product should logically have higher emissions than the semi-finished one. Yet, in the table published by the EU, industry players have flagged phenomena where "Taiwanese semi-finished stainless steel allegedly emits more than the finished product," vehemently questioning its rationality. In metallurgy, this is impossible; in a bureaucratic Excel sheet, it became legal reference. More fatally, Taiwan’s stainless steel industry relies primarily on Electric Arc Furnaces (EAF) and scrap recycling, resulting in a relatively low carbon footprint. In contrast, the Indonesian stainless steel industry is highly dependent on Nickel Pig Iron (NPI) and coal-fired power, yielding extremely high emissions. This suspected "slip of the hand" by the EU is akin to forcefully assigning the calorie count of a rich braised pork belly to a light garden salad. This has directly resulted in European buyers of Taiwanese stainless steel facing artificially inflated financial costs. II. A 27% Pass Rate: The 15,000-Strong Army Blocked at the Gate If data controversies are "soft tissue damage," the backlog in administrative approval is a fatal "compound fracture." The core rule of the CBAM definitive stage is simple: without "authorized declarant" status, you cannot import. This means every company wishing to ship a screw or an aluminum sheet into Europe must first secure an "entry ticket." The reality is brutal. According to the Commission’s official press release, by January 7, over 12,000 operators across the EU had submitted applications, with just over 4,100 approved (a pass rate of roughly 34%). However, industry estimates suggest that by late February, applications swelled to approximately 15,000, causing the pass rate to slide to around 27%. Where did the massive remainder go? They are stuck in the overwhelmed approval systems of National Competent Authorities (NCAs). In Germany, due to the deluge of applications, logistics giant DSV issued a public notice stating it could not support clients with CBAM authorization and registration, bluntly forcing thousands of SMEs to crash into the complex reporting system like headless flies. In France, the labyrinthine digital authentication process has turned the application into a maze only a hacker could navigate. To prevent European ports from paralysis, the EU was forced to administer a "painkiller": Customs Code Y238. This is a temporary "hall pass" allowing companies that applied before March 31 but have not yet been approved to keep goods moving for now. But make no mistake, this merely lengthens the fuse on the bomb. III. The Strategy of Silence and the Risk of "Retroactive Reckoning" Faced with industry skepticism, Brussels seems to have chosen the oldest PR strategy: silence. Although industry giants like the Gerber Group issued detailed technical warnings as early as January 9, pointing out the absurdity of the Taiwan/Indonesia data, the industry notes that as of late February, no official "Corrigendum" has been issued to legally revise the default values. The updated Excel version released on February 13 merely added a disclaimer: "information only." This rigid attitude transfers all risk to the enterprises. For companies currently relying on the Y238 temporary arrangement, the real danger is not "whether goods are released," but "whether they will be retroactively penalized." Competent authorities have publicly warned that if an authorization application is ultimately rejected, member states can, under Article 26 (2)/(2a) of the CBAM Regulation, retroactively penalize goods imported during the waiting period. Such fines can, in certain cases, reach 3 to 5 times the standard penalty. In other words, this is not a procedural flaw; it is a compliance risk that could land directly on cash flows and balance sheets. Conclusion: Who Pays the Price for Hubris? CBAM was supposed to be the crown jewel of the EU’s climate ambition, a lighthouse for global green trade. But the opening scene of 2026 makes it look more like an unfinished Tower of Babel. From the "data ghosts" haunting the industry to the severely backlogged approval channels, this "hard landing" exposes a chasm between regulatory ambition and administrative capability. For European importers, every day now is an exercise in navigating through fog. They are forced to calculate not just carbon emissions, but the cost of policy uncertainty. And for the European Commission, if it cannot step out of this arrogant "silence" and clarify these glaring operational controversies, what CBAM loses will be more than just data accuracy; it will be the trust of its global trading partners.

The beginning of 2026 did not bring the calm usually expected in the global stainless steel industry chain ahead of the traditional Lunar New Year offseason. Instead, under the double pincer attack of surging raw material costs and escalating trade protectionism, the market is undergoing a violent restructuring.