Aluminium Delegated Act Tracker: ESPR Aluminium DPP Status

Aluminium ESPR Delegated Act: Primary vs Secondary Aluminium

The carbon footprint of aluminium varies dramatically depending on whether it is produced from primary (virgin) or secondary (recycled) sources. Primary aluminium production — smelting alumina from bauxite ore using electrolysis — is extremely energy-intensive, with a carbon footprint of 8–17 tonnes of CO₂ per tonne of aluminium depending on the carbon intensity of the electricity used. Secondary aluminium production — melting recycled aluminium scrap — uses only 5% of the energy of primary production, with a carbon footprint of 0.5–1.5 tonnes of CO₂ per tonne of aluminium. The ESPR delegated act for aluminium will require manufacturers to declare the recycled content percentage and the carbon footprint per tonne of aluminium, creating a strong incentive to increase the use of recycled aluminium.

Aluminium in the EU Green Economy

Aluminium is a critical material for the EU's green transition — it is used extensively in solar panels (frames and mounting systems), wind turbines (nacelle components), electric vehicles (body panels, battery housings), and building facades (curtain wall systems). The EU's demand for aluminium is expected to increase significantly as the green transition accelerates. The ESPR delegated act for aluminium will need to balance the environmental objective of reducing the carbon footprint of aluminium production with the industrial policy objective of ensuring sufficient supply of aluminium for the EU's green economy. The EU Commission's Critical Raw Materials Act (EU 2024/1252) identifies aluminium as a strategic raw material, reflecting its importance for the green transition.

CBAM and the Aluminium ESPR DPP

The EU Carbon Border Adjustment Mechanism (CBAM, EU 2023/956) applies to aluminium imports from 2026. CBAM requires importers to purchase CBAM certificates corresponding to the carbon price that would have been paid under the EU ETS if the aluminium had been produced in the EU. The CBAM charge is calculated based on the embedded carbon emissions of the imported product — the carbon footprint per tonne of aluminium. The ESPR aluminium DPP will provide the carbon footprint data that CBAM authorities need to calculate the correct CBAM charge. Aluminium importers should ensure that their suppliers can provide carbon footprint data in a format compatible with both the ESPR DPP requirements and the CBAM reporting requirements.

Aluminium and ESPR: The Regulatory Context

Aluminium is one of the most widely used metals in the EU economy — it is used in automotive components, aerospace structures, construction cladding, packaging, electrical cables, and consumer electronics. The EU produces approximately 3.5 million tonnes of primary aluminium annually, and imports a further 3 million tonnes from Russia, Norway, and other countries. The EU Commission has identified aluminium as a priority material for ESPR because of its high energy intensity (primary aluminium production consumes approximately 14 MWh of electricity per tonne) and its high recyclability (aluminium can be recycled indefinitely without loss of quality, and recycled aluminium requires only 5% of the energy needed for primary production). The ESPR aluminium delegated act is expected to include requirements for recycled aluminium content disclosure, carbon footprint per tonne of aluminium, and end-of-life recycling instructions for aluminium-containing products.

Aluminium Stewardship Initiative and ESPR Readiness

The Aluminium Stewardship Initiative (ASI) is a global multi-stakeholder initiative that has developed a certification standard for responsible aluminium production, processing, and use. ASI certification requires aluminium producers and processors to meet performance standards covering governance, environment, social responsibility, and supply chain due diligence. ASI-certified aluminium producers collect and verify data on greenhouse gas emissions, energy consumption, water use, and waste generation — data that overlaps significantly with the data required for ESPR DPP compliance. EU aluminium producers that are already ASI-certified will have a significant head start on ESPR DPP compliance. The ASI is working with the EU Commission to align ASI certification requirements with ESPR DPP data requirements.

ESPR Aluminium Delegated Act: Expected Timeline

The ESPR aluminium delegated act is currently at the scoping study stage. The EU Commission's Joint Research Centre (JRC) is conducting a preparatory study that will assess the environmental impact of aluminium products across their lifecycle and identify the most effective ecodesign requirements. The preparatory study is expected to be completed in 2026, with the delegated act published in 2027–2028. Aluminium manufacturers and their customers (automotive OEMs, construction companies, packaging manufacturers) should monitor the preparatory study and participate in stakeholder consultations to ensure their sector's specific concerns are addressed in the delegated act.

Aluminium in the EU Battery Regulation: A Preview of ESPR Requirements

The EU Battery Regulation (EU 2023/1542) includes requirements for aluminium components in battery packs — specifically, requirements for recycled aluminium content and carbon footprint disclosure. These requirements provide a preview of what the ESPR aluminium delegated act is likely to require. Battery manufacturers that are already implementing the EU Battery Regulation's aluminium requirements will have a head start on ESPR aluminium DPP compliance. The EU Battery Regulation requires that battery manufacturers disclose the recycled aluminium content in their battery packs from 2027, and that they meet minimum recycled aluminium content requirements from 2030. The ESPR aluminium delegated act is expected to apply similar requirements to all aluminium-containing products, not just batteries.

Aluminium Recycling and ESPR: The Circular Economy Case

Aluminium is one of the most recyclable materials in the world — recycled aluminium requires approximately 95% less energy to produce than primary aluminium from bauxite ore. The EU already has a high aluminium recycling rate (approximately 75% for post-consumer aluminium scrap), but the ESPR aluminium delegated act is expected to push this rate higher by requiring minimum recycled aluminium content in aluminium products. The expected minimum recycled content requirements are: 30% recycled aluminium content for building and construction products, 20% for automotive components, 15% for packaging, and 10% for other product categories. These requirements will create strong demand for post-consumer aluminium scrap and will incentivise investment in aluminium recycling infrastructure. Aluminium manufacturers should assess the recycled content levels achievable in their product portfolio and engage with their scrap suppliers to understand the availability of high-quality post-consumer aluminium scrap.

The CBAM (Carbon Border Adjustment Mechanism, EU 2023/956) applies to aluminium imports into the EU and requires importers to purchase CBAM certificates corresponding to the carbon price that would have been paid under the EU ETS if the aluminium had been produced in the EU. The CBAM creates a financial incentive for non-EU aluminium producers to reduce their carbon intensity — producers with lower carbon intensity pay lower CBAM costs. The ESPR aluminium DPP's carbon footprint disclosure requirement will complement the CBAM by providing transparent, verifiable carbon footprint data for aluminium products. Aluminium importers should ensure that their ESPR DPP carbon footprint data is consistent with their CBAM declarations — inconsistencies between the two datasets could attract scrutiny from customs authorities.

Aluminium manufacturers should register for updates from the EU Commission's ESPR stakeholder forum for the metals sector. The stakeholder forum meets quarterly and provides updates on delegated act development, preparatory study findings, and technical standard development. Participation in the stakeholder forum is free and open to all interested parties — manufacturers, trade associations, NGOs, and research institutions. Registration is available through the EU Commission's Futurium platform.