ALFED has submitted a consolidated sector response to HM Treasury’s Joint Industry Working Group (JIWG) discussion papers on: (1) Free Allocation (FA) adjustment to CBAM rates; and (2) the exemption of UK-produced precursor goods.
The submission draws on the October 2025 meeting of the ALFED CBAM Taskforce, which brings together producers, processors, and downstream manufacturers to coordinate evidence-based input on CBAM design. The Taskforce will meet monthly and acts as the primary forum for member feedback on CBAM policy and implementation.
The aluminium sector is both trade-exposed and emissions-intensive, with significant exports to the EU; CBAM design will directly affect UK competitiveness, investment, and decarbonisation. Our submission responds to the JIWG discussion questions and highlights areas needing urgent policy clarity.
Our key messages to HM Treasury are:
- Align FA baselines, timelines and payment periods with EU CBAM, and publish worked examples so businesses can model impacts with confidence.
- Adopt commodity-level (customs-code linked) CBAM rates and apply robust default values that incentivise verified emissions data and fair competition.
- Support an exemption for UK-produced precursor goods with clear, auditable verification (e.g., trusted-trader style controls), and provide urgent clarity on the treatment of indirect (scope 2) emissions.
Commenting on the submission, Rachel Wiffen, Industry and Skills Development Manager at ALFED, said:
“Members need a CBAM that is predictable, fair, and administratively workable. Our proposals focus on alignment with the EU where it matters, better data and verification, and practical rules for UK precursor goods, so companies can plan, invest, and continue decarbonising without losing ground to international competitors.”
ALFED has also called for a dedicated Treasury CBAM contact for aluminium, regular Treasury participation in Taskforce meetings, publication of aluminium-specific impact assessment, and worked scenarios to inform final design.
