CBAM for Aluminium Windows and Doors (7610)

CN code 7610 covers aluminium structures and parts of structures — specifically doors, windows, door frames, window frames, thresholds for doors, and similar architectural products made from aluminium. If you import aluminium window frames, curtain walling sections, door frames, or shopfront profiles from outside the UK, your imports fall under 7610 and are subject to UK CBAM.

The code also covers aluminium thresholds, transoms, mullions, and other structural elements used in building envelopes. These are classified as aluminium products and carry the full CBAM obligation for that sector, including both direct and precursor emissions reporting.

Importers of fabricated aluminium building products are often surprised to discover they are caught by CBAM. Many did not expect fabricated, value-added products to be in scope. However, CBAM covers all goods under the relevant commodity code headings regardless of the degree of fabrication. A raw aluminium ingot and a finished window frame are both covered if they fall within the aluminium sector scope.

Aluminium window and door fabricators typically import extruded aluminium profiles from overseas mills or extruders, cut and machine them, and assemble them into finished windows and doors. Even though you are adding value in the UK, the imported aluminium profiles are CBAM-covered goods because they are classified under the aluminium heading (76) of the UK Trade Tariff.

The key distinction: if you import the raw extrusion stock (profiles) and fabricate in the UK, the import is caught. If you buy the profiles from a UK-based stockholder who originally imported them, you are not the importer of record and do not have the CBAM obligation — the stockholder does. You need to understand your position in the supply chain to know whether CBAM applies to you.

For fabricators who import directly, the emissions data you need includes the extrusion emissions (Scope 1 and 2 of the extruder) plus the smelter-level precursor emissions for the aluminium billet used to produce the profiles. Your data request to the extruder must ask for both components separately.

When requesting CBAM data from your aluminium extruder, ask for: total embedded emissions per tonne of extruded profiles (kg CO2e per tonne), broken down into smelter precursor emissions and extrusion process emissions separately. Request confirmation of the smelter source and production route (hydro vs coal-fired power), the scrap content of the billet, and whether any carbon price has been paid in the country of production.

Aluminium emissions vary dramatically by production route. Hydro-powered smelters can produce aluminium with emissions as low as 2-4 tonnes CO2e per tonne, while coal-fired smelters can exceed 20 tonnes CO2e per tonne. This 5-10x range means your CBAM liability depends heavily on knowing your specific supply chain emissions rather than using defaults.

Oremly's aluminium importer module handles the precursor calculation for 7610 products. It identifies aluminium structure imports, maps them to the correct subheading, requests precursor data from your extruder, and calculates the combined smelter-plus-extrusion emissions using the correct methodology for aluminium products.