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Manufacturing · EU Taxonomy Activity Guide

Manufacture of aluminium under the EU Taxonomy

Aluminium’s Taxonomy treatment mirrors its two production worlds. Secondary (recycled) aluminium qualifies directly, reflecting its small fraction of primary’s energy demand. Primary aluminium must clear a combined test: a greenhouse gas intensity ceiling, an electricity intensity ceiling, and a low-carbon electricity sourcing condition, which in practice makes smelter power sourcing the decisive question.

Activity ID
CCM 3.8
NACE code
C24.42 / C24.53
Objective
Climate change mitigation
Sector
Manufacturing
01

Why this activity matters

Aluminium is both emissions-intensive to make and central to the transition, in vehicles, buildings, packaging and grids, which is why the Taxonomy takes a transitional approach: it rewards recycled production outright and defines what best-in-class primary production looks like, dominated by the carbon content of smelter electricity.

For producers, alignment supports financing of smelter modernisation and recycling capacity, and feeds CSRD KPIs. For buyers and investors, the aligned/not-aligned distinction increasingly tracks the premium low-carbon aluminium market. Assessments split cleanly: recycled routes are quick, evidence-light cases; primary routes turn almost entirely on documented electricity sourcing and measured process emissions.

02

What alignment requires

One route qualifies by nature, the other by thresholds. In summary:

AreaWhat is required (summarised)
Secondary (recycled)Manufacture of aluminium from scrap qualifies directly, with no emissions threshold, reflecting the roughly 95% energy saving over primary production.
Primary: GHG intensityDirect process emissions must sit within the Taxonomy ceiling per tonne of aluminium (a level only efficient smelters approach), evidenced by verified emissions data.
Primary: electricityElectricity consumption per tonne must sit within the intensity ceiling, AND the electricity must meet a low average carbon intensity, which is why hydro- and nuclear-powered smelters dominate aligned primary production.

Summarised for orientation; the assessment itself applies the full criteria text of the Delegated Acts as amended.

03

Where DNSH scrutiny falls

Pollution prevention

BAT conformity for smelting: fluorides, PFC emissions from anode effects, and dust are the characteristic pollutants.

Circular economy

Scrap sourcing and dross/by-product handling; for primary, spent pot lining management is the recurring hazardous-waste item.

Water

Cooling and process water for casthouses; discharge quality documentation.

Climate adaptation

CRVA including energy supply resilience, material for electricity-dependent smelters.

04

Documentation that typically supports the assessment

05

How Censatim assesses it

The first fork in our questioning is primary versus secondary, because the criteria differ completely. Secondary assessments close quickly on scrap evidence; primary assessments concentrate on the three-part test, with electricity sourcing documentation carrying the most weight. Mixed operations are assessed per route, matching how production and reporting are actually organised.

Censatim is an expert-built EU Taxonomy assessment tool: describe the asset or activity in plain language, upload supporting documents, and answer a short set of targeted questions. The result is a criterion-by-criterion view with an In-line / Partial / Not aligned / Undetermined rating and a confidence level for each dimension. See the full methodology.

06

Frequently asked questions

Does recycled aluminium automatically qualify under the EU Taxonomy?

Secondary aluminium production from scrap qualifies for substantial contribution without an emissions threshold, reflecting its dramatically lower energy demand. DNSH criteria and Minimum Safeguards still apply, but recycled routes are among the most straightforward manufacturing assessments.

What thresholds does primary aluminium face under the Taxonomy?

A combined test: direct GHG emissions per tonne within the Taxonomy ceiling, electricity consumption per tonne within an intensity ceiling, and low-carbon electricity sourcing. The electricity conditions are usually decisive, favouring smelters on hydro or other low-carbon power.

Why does smelter electricity sourcing matter so much?

Because electricity dominates primary aluminium’s footprint. The criteria address it directly through the intensity ceiling and the carbon-intensity condition on the power consumed, so PPAs, grid factors and generation mix documentation are the heart of a primary assessment.

What is spent pot lining and why does it come up in DNSH?

Spent pot lining is the hazardous waste from relining smelter cells. Its management is a characteristic circular-economy and pollution item for primary aluminium, and documented handling arrangements are routinely requested in assessments.

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