ALFED has formally submitted its response to HMRC’s technical consultation on the draft regulations for the UK Carbon Border Adjustment Mechanism (CBAM), representing the collective voice of the UK aluminium value chain.
The full submission can be accessed here.
Thank You to Members
We would like to extend our sincere thanks to all ALFED members who contributed feedback, insights and real-world examples to support this response.
The strength of this submission is a direct result of member engagement across recycling, remelting, extrusion, finishing, distribution and downstream manufacturing. Your input has ensured that the practical realities of operating within complex, global aluminium supply chains are clearly reflected in our position.
Key Themes from the ALFED Response
The response focuses on ensuring that CBAM delivers on its intended objectives, preventing carbon leakage and creating a level playing field, without unintentionally undermining UK competitiveness.
A central theme is the urgent need for clarity and early guidance. As highlighted in the submission, several critical elements of the framework, including Monitoring, Reporting and Verification (MRV), emissions methodologies and verification processes, are not expected to be finalised until late 2026.
This presents a significant challenge for businesses, who will need to build internal systems, engage supply chains and factor CBAM costs into commercial decisions well ahead of implementation in January 2027.
The response also highlights the risk of unintended consequences for UK manufacturers, particularly where the current design could create asymmetry between domestic production and imported finished goods. Ensuring CBAM supports, rather than disadvantages, UK manufacturing is a key priority.
Given the integration of UK and EU supply chains, ALFED has also stressed the importance of alignment with the EU CBAM framework, to avoid duplication, increased administrative burden and potential trade distortion.
In addition, members raised practical concerns around:
- The complexity of emissions data collection across global supply chains
- The proportionality of verification requirements
- The need for workable default emissions values
- Administrative challenges within the proposed registration process
Looking Ahead
CBAM represents a significant structural change for the aluminium sector, with implications across the entire value chain.
ALFED will continue to engage closely with HMRC, HM Treasury and wider Government to:
- Seek early publication of key frameworks and methodologies
- Ensure alignment with international systems
- Advocate for a practical, proportionate approach to compliance
- Position the UK aluminium sector as competitive, resilient and central to the low-carbon transition
We will also continue to work with members through the Trade Committee and CBAM working groups to support preparedness and share further guidance as it becomes available.
If you have any further questions or would like to contribute to ongoing CBAM discussions, please do get in touch: alfed@alfed.org.uk
