Is Aluminium Scrap (CN 7602) a CBAM Good?

Last reviewed: 4 August 2026 · Author: Kadim Rammahi, Founder, AllMarketZones

No. Aluminium waste and scrap, classified under CN heading 7602, is not listed in Annex I of Regulation (EU) 2023/956, and CBAM applies only to goods listed in Annex I (Article 2(1), Regulation (EU) 2023/956). Imports of CN 7602 therefore carry no CBAM obligations and do not count towards the 50-tonne de minimis threshold.

The aluminium section of Annex I lists CN headings 7601, 7603, 7604, 7605, 7606, 7607, 7608, 7609 00 00, 7610, 7611 00 00, 7612, 7613 00 00, 7614 and 7616 (Annex I, Regulation (EU) 2023/956). Neither 7602 (waste and scrap) nor 7615 (table, kitchen and household articles) appears in that list. By contrast, ferrous waste and scrap under CN 7204 is expressly listed in the iron and steel section of Annex I — so the treatment of scrap differs by sector, and the aluminium position cannot be inferred from the steel one.

This guide explains what "not listed" means in practice under the definitive regime that began on 1 January 2026 (Article 36(2), point (b), Regulation (EU) 2023/956). AllMarketZones provides a fixed-fee CBAM Scope Assessment; we do not provide emissions verification or binding customs classification advice, and where those are required we coordinate accredited partners.

What "not listed in Annex I" means for scrap importers

Article 2(1) of Regulation (EU) 2023/956 provides that the Regulation "applies to goods listed in Annex I originating in a third country" imported into the EU customs territory. A CN heading that is not listed is simply outside the mechanism: no declarant authorisation, no embedded-emissions reporting, no certificate surrender, and no contribution to the de minimis calculation attach to it.

The 50-tonne threshold in Article 2a(1) is measured against "the net mass of the imported goods" — that is, goods within the scope of the Regulation under Article 2 — "under all CN codes aggregated per importer and per calendar year" (Article 2a(1) and point 1 of Annex VII, as inserted by Regulation (EU) 2025/2083). Because CN 7602 is not an Annex I good, its tonnage is not part of that aggregation.

Why classification still matters

The out-of-scope position depends entirely on the goods being correctly classified under CN 7602 at import. Metal that has been re-melted into unwrought ingot is classified under CN 7601, which is a listed Annex I good whose embedded emissions must be declared (Annex I; Article 6(2), Regulation (EU) 2023/956). The scope decision therefore turns on the CN code declared to customs, not on whether the material is described commercially as "recycled" or "secondary".

An importer handling both scrap and listed aluminium goods should keep the two streams distinct in its records: the net mass of listed goods feeds the Article 2a threshold calculation, while the scrap stream sits outside it. Our guide to the CBAM aluminium CN codes sets out heading by heading which parts of Chapter 76 are listed, and our 50-tonne threshold guide works through the aggregation arithmetic.

Scrap of other CBAM sectors is treated differently

The exclusion of aluminium scrap cannot be generalised to other sectors. Annex I of Regulation (EU) 2023/956 expressly lists CN 7204 — "Ferrous waste and scrap; remelting scrap ingots of iron or steel" — in the iron and steel section, so imported ferrous scrap is a CBAM good and its net mass counts towards the 50-tonne threshold (Annex I; Article 2a(1)). An importer of mixed metal scrap must therefore check each CN heading against Annex I rather than assume a uniform "scrap exemption".

Practical steps for scrap importers

1. Confirm the CN classification of each consignment; the out-of-scope position applies to goods properly classified under CN 7602 (Article 2(1) and Annex I, Regulation (EU) 2023/956).
2. Exclude CN 7602 tonnage from the cumulative net-mass total tested against the 50-tonne threshold, and include any listed goods such as CN 7601 or CN 7604 (Article 2a(1); Annex VII, point 1).
3. Check any ferrous scrap separately — CN 7204 is listed in Annex I and is in scope.
4. Where the total of listed goods exceeds, or is expected to exceed, 50 tonnes, apply for authorised CBAM declarant status (Articles 2a and 5) — see our authorised declarant guide.

The authoritative list of covered goods is Annex I of Regulation (EU) 2023/956, and the mechanism is documented on the European Commission CBAM pages. For the wider mechanism, see our CBAM compliance guide.