# For aluminium products, is fuel for annealing, anodising or powder coating inside the European Union (EU) Carbon Border Adjustment Mechanism (CBAM) boundary?

Canonical: https://senseible.earth/answers/cbam-aluminium-annealing-anodising-coating-boundary

The Commission's guide names annealing, and surface preparation and treatment, as steps inside the boundary for aluminium products, and excludes cutting, welding and finishing. It does not name anodising, painting or powder coating, so ask your verifier which side each line falls on. Electricity does not count either way.

## What the guide puts inside

CBAM is the EU's charge on the carbon built into imported goods. For aluminium products the guide counts fuel burnt and gases from flue gas treatment, and it lists these steps inside the boundary for basic aluminium products installations (section 3.1.1 also names annealing among furnaces):

- Raw material preparation, including pre-heating, re-melting and alloying.
- Forming processes, including but not limited to extrusion, casting, hot and cold rolling, forging and drawing.
- Annealing, surface preparation and treatment.
- Emissions control for releases to air, water or ground.

## What the guide leaves out

Cutting, welding and finishing of aluminium products are excluded. Our page on cutting-only units explains what a unit that only does those steps still has to prove.

## Lines the guide does not name

The guide does not use the words anodising, painting, powder coating or ageing oven. Annealing, and surface preparation and treatment, are named as inside. Finishing is named as outside. Where a hot-water boiler for an anodising line or a curing oven for powder coat falls between those two lists, the guide does not say.

Our page on what a verifier checks at an aluminium plant lists billet reheating and ageing among the fuel to record. This guide's step list names annealing instead, and its forming list is open-ended. Treat the Methodology Act text as the final word and agree each line with your verifier.

## What does not matter either way

Electricity for any of these lines is not counted, because aluminium goods are on the list where only direct emissions are taken into account.

## What to do now

- Put a separate fuel meter or tank log on each line so that either answer can be applied afterwards.
- Write down for each line what it does to the metal, in your own words, for the verifier.
- Ask the verifier to confirm in writing which lines sit inside, before the reporting year closes.

## What the choice can do to the figure (example)

- Fuel carbon dioxide (CO2) in a year: billet heating 300 tonnes, ageing oven 80, anodising boiler 120, powder coat curing oven 90
- Output: 2,000 tonnes of profiles
- If only the first two lines are inside: (300 + 80) / 2,000 = 0.190 tonnes per tonne
- If all four are inside: 590 / 2,000 = 0.295 tonnes per tonne
- Gap: 0.105 tonnes per tonne

Fuel and output are example numbers. Which lines are inside is for your verifier to confirm; the example only shows why it matters.

## What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. Telling which line burned which fuel is custom, on request, through sub-meters. Senseible builds the verifier-ready file and checks every figure in-house; an accredited verifier Senseible partners with signs it off, or the client sends it to their own.

- [Build your aluminium CBAM file](https://senseible.earth/cbam-suite)
- [Cutting-only unit and CBAM verification](https://senseible.earth/answers/cutting-only-unit-cbam-verification)
- [Verifier checks at an aluminium plant](https://senseible.earth/answers/what-cbam-verifier-checks-aluminium-plant-india)
- [Does aluminium CBAM count electricity](https://senseible.earth/answers/does-aluminium-cbam-count-electricity)

Sources: [European Commission, CBAM Guidance No. 5e, aluminium (14 August 2026)](https://taxation-customs.ec.europa.eu/document/download/590e983b-c937-41ea-bb9f-810c29e70e1e_en?filename=Guidance%20No.%205e%20-%20Sector-specific%20guidance%20document%20on%20aluminium.pdf)

Last reviewed 2026-11-07. The guide's wording on annealing and finishing is short. Confirm each coating or treatment line against Annex I, point 3.18 of Implementing Regulation (EU) 2025/2547 with your verifier. The guide says it is not legally binding.