CBAM for Copper Exporters: Embedded Emissions Guide 2025

Copper exporters supplying EU customers are entering the most consequential phase of CBAM. The transitional reporting period (October 2023 to December 2025) required EU importers to report embedded emissions quarterly but made no financial demand. From 1 January 2026, the definitive period begins: EU importers must purchase CBAM certificates for every tonne of CO₂e embedded in your goods at the current EU ETS price.

At EU ETS prices of €50–80/tonne CO₂e, the difference between a well-documented actual emission value and the punitive CBAM default value can represent thousands of euros per tonne of copper exported. Getting your emissions calculation right is not just a compliance exercise — it directly determines whether your products remain price-competitive in the EU.

1. Is copper in CBAM scope?

Yes. Copper and copper alloy products were included in CBAM from the beginning — Annex I of CBAM Regulation (EU) 2023/956 lists copper products alongside steel, iron, aluminium, fertilisers, cement, hydrogen, and electricity.

The CBAM transitional period required EU importers to file quarterly embedded emissions reports from October 2023, using actual values where available or defaults where not. Many importers used defaults during the transitional period because the reporting carried no financial penalty. From 2026, defaults carry full financial cost, creating strong incentive for exporters to provide actual emission data.

2. Which copper CN codes are covered?

CBAM covers a selection of copper products under HS Chapter 74 (copper and articles thereof). The key in-scope CN codes include:

• 7401: copper mattes, cement copper (precipitated copper)
• 7402: unrefined copper; copper anodes for electrolytic refining
• 7403: refined copper and copper alloys, unwrought
• 7404: copper waste and scrap
• 7405: master alloys of copper
• 7407: copper bars, rods and profiles
• 7408: copper wire
• 7409: copper plates, sheets and strip of thickness greater than 0.15 mm
• 7410: copper foil
• 7411: copper tubes and pipes
• 7413: stranded wire, cables, plaited bands and the like, of copper

Check Annex I of Regulation (EU) 2023/956 for the exact CN code entries — not all sub-headings within each heading are necessarily in scope, and the annexes are occasionally amended. Copper household goods, electrical apparatus, and many fabricated articles (Chapter 85, 86, 90 etc.) are outside CBAM scope even if they contain significant copper content.

3. How embedded emissions are calculated for copper

CBAM embedded emissions for copper products are calculated under CBAM Implementing Regulation (EU) 2023/1687. The calculation covers:

Direct embedded emissions

Emissions from processes at your installation that physically produce the copper goods. For primary copper, this includes:

• Fuel combustion in smelting and converting furnaces (flash smelting, reverberatory, electric)
• Fuel combustion in anode furnace and fire refining
• Process emissions from sulphide concentrate roasting and converting (SO₂ is a co-product, not a GHG, but CO₂ from fuel used in the process counts)
• On-site power generation emissions (if applicable)

For secondary copper (scrap-based), direct emissions are substantially lower because the concentrate smelting and matte converting steps are absent or reduced.

Indirect embedded emissions

Indirect emissions from purchased electricity consumed at the installation. Calculated as: kWh of electricity consumed × country-specific or regional grid emission factor (tCO₂/MWh).

For copper, indirect emissions from electricity are often the largest single component — copper electrolytic refining and electrowinning are highly electricity-intensive. The grid emission factor used must be the country-level default from CBAM Implementing Regulation Annex IX, or a more specific electricity supply agreement emission factor if the installation can demonstrate a direct power supply from a specific low-carbon source.

The boundary: specific vs. aggregate calculation

CBAM requires the embedded emissions to be calculated per tonne of goods at the specific production installation level, not at country average or industry average level. This means you need installation-level energy and fuel consumption data, production volumes, and the ability to attribute emissions to the specific products being exported to the EU.

4. Primary vs. secondary copper: emissions difference

The embedded emissions intensity of copper varies enormously between primary (mined) and secondary (recycled) production. Indicative ranges from industry data:

The table shows why even a mid-efficiency primary copper smelter is likely below the CBAM default value — and why submitting actual emission data is financially critical.

5. Why you must avoid CBAM default values

CBAM default values for embedded emissions are set at the 90th percentile of emissions intensity in the global production landscape for each product category. For copper, this means the default represents a very high-emitting facility — not a modern, well-managed operation.

At an EU ETS price of €65/tonne CO₂e, the difference between a default value of 5 t CO₂e/t copper and an actual value of 2.5 t CO₂e/t copper represents €162.50 per tonne of copper in additional CBAM certificate cost for your EU importer. On a 500-tonne shipment, that is €81,250 in unnecessary cost that your importer will either absorb or pass back to you through lower purchase prices.

Providing actual verified emission values is not just in your interest — your EU importer is legally required to use your actual values when they are available and verified. If you provide them, the importer must use them.

6. What documents your EU importer needs

To declare actual embedded emissions in their CBAM declaration, your EU importer needs the following from you:

• CBAM embedded emissions data file — actual direct and indirect embedded emissions per tonne of goods, in the format required by CBAM Implementing Regulation (EU) 2023/1687
• Installation details — name, address, country, CBAM installation identifier (where your country issues one)
• Methodology reference — confirmation that the calculation follows CBAM Implementing Regulation Annex III methodology
• Third-party verification report — from 2026 definitive period, actual values used in the declaration must be verified by an accredited verifier (requirements aligned with ISO 14065 and EU ETS verification rules)
• Carbon price evidence — if your country operates a carbon price scheme and you have paid for the embedded emissions, evidence to support the deduction

7. Claiming a carbon price deduction

If your production country operates a carbon price — an emissions trading system (ETS) or carbon tax — that covers the direct emissions in your copper production, your EU importer can deduct the effective carbon price paid from their CBAM certificate obligation. This is the CBAM deduction mechanism, designed to prevent double-counting of carbon pricing.

To claim the deduction, you need: evidence of the carbon permit purchase or carbon tax payment, the number of tonnes CO₂e covered, the price paid per tonne (in EUR or converted at the official reference rate), and evidence that the carbon price applies specifically to the direct emissions embedded in the goods exported.

Countries with relevant carbon price schemes for copper exporters include: Chile (carbon tax), Kazakhstan (ETS), China (national ETS for power sector — check whether it applies to your smelter's electricity emissions), and a growing number of others. The deduction is calculated separately for direct emissions (where the carbon price was paid at the installation) and for indirect emissions (where the carbon price was passed through in the electricity price).

8. CBAM definitive period timeline for copper

FAQs