FACE Survey
IMPACT OF CBAM, TARIFFS AND SUPPLY RISKS ON THE ALUMINIUM VALUE CHAIN
RESULTS
Summary of FACE Survey Results
The survey highlights a clear overall picture: companies demonstrate a high level of awareness of CBAM, but their level of practical preparedness and their assessment of its potential impact remain uneven. At the same time, costs, competitiveness and supply security emerge as the most widespread concerns.
Executive Summary
The survey highlights 4 key messages:
- CBAM is well understood, but implementation is not yet uniform.
All respondents state that they have a very good understanding of CBAM, while a large majority have already received in-depth information or training. Operational preparedness is more uneven: the majority report being prepared in a structured way, while some companies are only partially prepared or have not yet started a structured preparation process. The main challenges identified are reporting and compliance, emissions calculation, regulatory complexity and managing relationships with non-EU suppliers. - There is broad support for extending CBAM to downstream products, but the expected impact is highly polarised.
A clear majority of respondents support an extension. However, views on its effects differ significantly: some companies see it as a tool to ensure a level playing field and protect European industry, while others are concerned about higher costs, additional bureaucracy and higher final prices. - Cost pressures are perceived as structural.
The vast majority of respondents believe that current tariffs and trade measures are significantly increasing value-chain costs. The main sources of additional costs include logistics, energy, import tariffs, regulatory compliance and certifications, alongside geopolitical instability. - The aluminium supply chain is considered fragile.
The large majority of respondents describe the current situation as unstable, with some companies considering it highly critical. Over the next 12–24 months, the main concerns are rising raw material prices, material shortages, a reduction in the number of available suppliers and geopolitical risks.
- CBAM: High Awareness, but Uneven Preparedness
The most evident finding is that all respondents report a very good understanding of CBAM. The majority have also received in-depth information or training.
However, knowledge does not automatically translate into operational preparedness.
The majority of companies report being structurally prepared, while a smaller share is only partially prepared or has not yet started a structured preparation process.
The main challenges identified are:
- reporting and compliance;
- calculation of embedded emissions;
- regulatory complexity;
- relationships with non-EU suppliers;
- risk of errors and penalties.
This suggests that the main need is no longer simply awareness of CBAM, but rather the transition from theoretical knowledge to the practical and standardised management of compliance obligations.
A particularly relevant issue: data quality
One response proposes the creation of a public and certified EU registry containing carbon values associated with installations and HS codes.
This is significant because it addresses one of the most relevant practical challenges: avoiding repeated requests for and verification of the same emissions data by individual importers across the supply chain.
Another respondent highlights the risk that non-EU suppliers may absorb or offset the cost of CBAM through price reductions, calling for a more effective mechanism to protect European producers.
Overall message: companies appear to be calling for a CBAM that is simpler, more transparent, verifiable and genuinely effective in creating a level playing field.
- Extension of CBAM to Downstream Products: Broad Support, but Significant Cost Concerns
A clear majority of respondents support extending CBAM to downstream products.
However, expectations and motivations differ.
Positive perspective
Some companies see the extension as an opportunity to achieve:
- greater competitive fairness;
- protection of European industry;
- greater supply-chain transparency;
- stronger incentives for decarbonisation.
Negative perspective
Others highlight concerns regarding:
- higher costs;
- increased complexity;
- additional bureaucracy;
- higher prices;
- potential loss of competitiveness.
The result is therefore apparently contradictory, but highly relevant: companies broadly share the objective of preventing carbon leakage and ensuring a level playing field, but they are not necessarily convinced that the current regulatory approach represents the least costly way of achieving this objective.
- Tariffs and Competitiveness: Costs Are at the Centre of the Debate
The survey shows strong concern about the overall cost of operating within the European aluminium value chain.
The vast majority of respondents believe that current tariffs and trade measures are significantly increasing value-chain costs.
The sources of additional costs identified are diverse:
- logistics costs;
- energy costs;
- import tariffs;
- regulatory compliance;
- certifications and sustainability requirements;
- geopolitical instability.
The impact on competitiveness ranges from limited to significant, with a meaningful share of respondents considering the impact significant.
Views on tariffs are not uniform
An important distinction also emerges here:
- some companies call for stronger trade protection;
- others call for removing or reducing tariffs on strategic raw materials.
This is not necessarily contradictory. It appears to reflect a demand for more targeted trade policies that protect European producers without excessively penalising European users that depend on imported raw materials.
One of the open responses captures the dilemma particularly well: tariffs can protect European industry, but they can also be inflationary.
- Supply Chain: The Most Immediate Risk
This is probably the strongest finding of the entire survey.
The large majority of respondents perceive the aluminium supply chain as unstable, while part of the sample considers it highly critical.
The main challenges expected over the next 12–24 months are:
- rising raw material prices;
- material shortages;
- a reduction in the number of available suppliers;
- geopolitical risks;
- energy price volatility.
A significant share of respondents has already implemented alternative sourcing strategies.
This is an important signal: the issue is not perceived solely as a future risk, but is already driving concrete action to diversify sourcing.
Future trade restrictions
The majority consider further restrictions or bans on strategic materials or products to be likely or possible.
Although assessments of the potential impact vary, the prevailing view is that additional restrictions could have a high or very high impact.
This leads to a clear strategic priority:
Supply-chain resilience is increasingly becoming a matter of industrial competitiveness, not simply a procurement issue.
- Key Differences Across Companies
Another relevant aspect is the degree of heterogeneity in responses, particularly according to company size and profile.
More structured companies appear to have greater capacity to prepare for CBAM and manage risks, while smaller companies show greater uncertainty regarding future impacts and their ability to respond.
This suggests a potential capability gap across companies, particularly in access to:
- technical expertise;
- emissions data;
- compliance resources;
- supplier diversification capabilities;
- regulatory monitoring.
- Five Priorities Emerging from the Survey
Bringing the responses together, the priorities for the value chain can be summarised in five areas:
- Make CBAM simpler and more transparent
Standardise data, develop appropriate European data infrastructure, ensure certified emissions values and reduce administrative burdens.
- Ensure a genuine level playing field
CBAM should prevent non-EU imports from benefiting from competitive advantages resulting from lower environmental standards or lower regulatory costs.
- Avoid excessive inflationary effects from trade protection
A balance must be found between protecting European industry and ensuring access to raw materials at competitive prices.
- Reduce the structural cost disadvantage of European industry
Companies particularly highlight the need for competitive energy, investment incentives and reduced bureaucracy.
- Strengthen supply-chain resilience
Diversify sources, monitor geopolitical risks, improve coordination among operators and provide better market intelligence.
Conclusion
Overall, the survey portrays a value chain that is aware of the transformations underway, but increasingly concerned about the cumulative effect of costs, regulatory obligations and geopolitical risks.
The strongest message is not simply that “CBAM is a problem”. Rather:
Companies are prepared to engage with the transition towards a more sustainable and regulated value chain, but they want this transition to take place without undermining the competitiveness of European industry.
In this context, CBAM, tariffs, energy costs and supply-chain resilience are perceived as closely interconnected issues. Companies are therefore calling for a framework that combines decarbonisation, protection against unfair competition, competitive access to raw materials and regulatory simplification.
