# Our aluminium tanks and drums ship lined or insulated. Do we cut the tonnes we report for the European Union (EU) Carbon Border Adjustment Mechanism (CBAM)?

Canonical: https://senseible.earth/answers/cbam-aluminium-goods-with-lining-or-insulation-tonnes

The Commission's aluminium guide says to report the quantity in tonnes under the right Combined Nomenclature (CN) code, without a standalone mass-threshold adjustment for non-aluminium parts such as lining or insulation. It does not say in so many words whether the weight includes the lining, so settle that with your verifier.

## What the guide says

CBAM is the EU's charge on the carbon built into imported goods, a bit like a toll on the smoke behind a product. For aluminium goods, the Commission's guide says the quantity of aluminium products shall be reported in accordance with the applicable CN code and the functional unit (tonnes), without applying a standalone mass-threshold adjustment for non-aluminium components, for example lining or insulation.

Our reading, in plain words: there is no special rule that lets you strip out, or must make you strip out, the weight of a lining by a cut-off.

## Which goods this touches

- CN 7611: reservoirs, tanks, vats and similar containers over 300 litres, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment.
- CN 7612: casks, drums, cans, boxes and similar containers up to 300 litres, with the same wording on lined or heat-insulated goods.
- The guide's Table 2-1 puts both codes inside aluminium products.

## A different rule, so do not mix them up

The guide has a separate rule about alloying elements. Any alloying elements in unwrought aluminium that are not CBAM precursor goods are left out of the mass and the embedded emissions of the aluminium good. The reporting table also asks for the total share of elements other than aluminium where that share exceeds 1%.

Our reading, not the guide's words: the alloy rule is about metals mixed into the aluminium, and the lining sentence is about parts attached to the finished good. The guide does not connect the two.

## What to settle before you file

1. Which weight your customs entry uses for each tank or drum code. Our reading is that your per-tonne figure and the tonnes your EU buyer declares should rest on the same weight, but the guide does not say so.
2. Whether the lining or insulation is a separate good under another CN code on your invoice.
3. What your verifier wants to see: weighing records, drawings of the lining, and a note on how you classified the product.

## Why the weight basis has to match (example)

- 500 insulated tanks: aluminium shells 20 tonnes, insulation 3 tonnes, so 23 tonnes in all
- Process direct emissions for the year: 22 tonnes of carbon dioxide equivalent (CO2e)
- Per tonne of aluminium shell: 22 / 20 = 1.10. Per tonne of whole tank: 22 / 23 = 0.957
- If the figure is 1.10 but the buyer declares 23 tonnes: 1.10 x 23 = 25.3 tonnes, which is 3.3 more than the 22 you emitted

Example numbers. They show why one weight basis must be used on both sides; the guide does not say which basis to use.

## What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. Weighing your goods or classifying them under a CN code is custom, on request. 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)
- [Verifier checks at an aluminium plant](https://senseible.earth/answers/what-cbam-verifier-checks-aluminium-plant-india)
- [Alloy grades and one figure per CN code](https://senseible.earth/answers/cbam-alloy-grades-one-figure-per-cn-code)
- [Aluminium foil and containers covered](https://senseible.earth/answers/are-aluminium-foil-and-containers-covered-by-cbam)

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 sentence on lining and insulation is short. Confirm with your verifier and your customs broker which weight your entries use. The guide says it is not legally binding.