Why Recycled Content Matters for CBAM and Scope 3 Reporting.
Two separate reporting frameworks are now landing on the same aluminum purchasing decision. Neither one is optional for the buyers it applies to, and both are easier to answer with a documented recycled-content figure in hand than without one.
Key takeaways
- CBAM is an EU border mechanism tied to imports; Scope 3 is a corporate emissions accounting standard tied to your supply chain generally. They are different frameworks with overlapping data needs.
- Recycled aluminum generally carries a lower embedded-carbon footprint than primary aluminum, since remelting skips the electrolytic smelting step.
- Orbit can supply a batch-level, traceable recycled-content figure for your order; Orbit does not calculate your CBAM declaration or Scope 3 footprint.
- Orbit's confirmed recycled-content example is a 3105 substrate with a PUPA coating, reaching roughly 75%, confirmed per order.
- Compliance obligations and thresholds should be confirmed against the official CBAM and GHG Protocol sources, not assumed from general guidance.
Why are two separate reporting frameworks landing on the same purchase?
Because CBAM and Scope 3 reporting, though administered by different institutions for different purposes, both create demand for the same underlying thing: documented, traceable data about the material you are buying, not a general industry statement about aluminum.
If you buy aluminum coil into the EU, or you report your company's value chain emissions to customers or investors, you are likely dealing with one or both of these frameworks already.
What does CBAM actually cover?
The Carbon Border Adjustment Mechanism is the EU's mechanism for addressing carbon leakage on imports of carbon-intensive goods, aluminum among them, by pricing the emissions embedded in those imports. EU importers, or their customs representatives, take on authorization and reporting obligations tied to those embedded emissions.
The mechanism and its current requirements are set out directly by the European Commission's Taxation and Customs Union, the authoritative source for compliance obligations and the right first reference for how CBAM applies to your specific import volumes and timeline.
Why does recycled content matter for a CBAM calculation?
Because recycled aluminum generally carries a lower embedded-carbon footprint than primary aluminum, since remelting scrap skips the electrolytic smelting step primary production requires. That relationship is why a documented recycled-content figure is a relevant input to an importer's own embedded-emissions calculation.
It sits alongside whatever other data your CBAM methodology requires; it is one input, not the whole calculation.
What does Scope 3 reporting actually cover?
The emissions in a company's value chain that fall outside its own operations and energy purchases, covering everything from purchased materials to downstream product use. The GHG Protocol's Corporate Value Chain (Scope 3) Standard is a widely used method for this accounting, organized into a defined set of categories, purchased goods and services typically being the one that captures material inputs like aluminum coil.
As with CBAM, a documented, supplier-specific recycled-content figure is a more useful input than a general industry average, because it reflects the actual material in your order rather than a sector-wide estimate.
What can Orbit actually provide toward either framework?
A batch-level recycled-content figure, traceable to the cast for your specific order, confirmed against your alloy and coating. What Orbit does not do is calculate your CBAM declaration or your company's Scope 3 footprint on your behalf.
Buying recycled-content coil does not by itself satisfy either framework's requirements. Those calculations depend on your own methodology, import volumes and reporting boundary, and are properly handled by your compliance team or advisor. Orbit's role is to give that process an accurate number to work with, not to replace it.
What is Orbit's confirmed recycled-content figure?
A 3105 substrate with a PUPA coating, reaching roughly 75% recycled content, confirmed per order. That figure is specific to that alloy and coating pairing, not a blanket claim across every product Orbit rolls.
How it is calculated and what "confirmed per order" actually means is explained in what recycled-content aluminum coil actually means.
What should I ask a supplier for, whichever framework applies?
Four things: a recycled-content percentage tied to a specific alloy and coating, confirmation of how that figure is calculated and at what stage of production, traceability to a cast batch or production record, and a clear statement of what the supplier is and is not certifying.
- A recycled-content percentage tied to a specific alloy and coating, not a company-wide average.
- How that figure is calculated, at what stage of production, and whether it covers the substrate alone.
- Traceability to a cast batch or production record, so the figure can be defended if questioned later.
- A clear statement of what the supplier is and is not certifying, so it is not mistaken for a compliance filing the supplier does not perform.
A supplier that can answer all four without a general statement about the aluminum industry standing in for specifics is giving you something you can actually use. If either framework applies to your purchasing, send us the alloy, coating and order volume, and see Orbit's recycled-content page for the full worked example and request process.
Common questions
Does Orbit handle CBAM declarations on our behalf?
No. Orbit supplies a traceable recycled-content figure that can be an input to your own CBAM calculation. The declaration and calculation itself is the importer's responsibility, handled through your compliance team or advisor.
Does buying recycled-content coil automatically satisfy Scope 3 requirements?
No. Scope 3 accounting depends on your own methodology and reporting boundary. A documented, supplier-specific recycled-content figure is a useful input to that accounting, not a substitute for it.
What recycled-content figure can Orbit confirm?
The confirmed worked example is a 3105 substrate with a PUPA coating at roughly 75%. For other alloy and coating combinations, send your specification and we will confirm the achievable figure.
Where should I check current CBAM requirements?
The European Commission's Taxation and Customs Union publishes the current CBAM mechanism, obligations and thresholds directly, and is the authoritative source to confirm requirements against for your specific import volumes.
Is the recycled-content figure traceable if our reporting is audited?
Yes. The figure is traceable to the cast batch for your order, which is why it is documentation rather than a general claim. Certifications and credits built on it remain yours to claim.
References
- European Commission, Taxation and Customs Union — Carbon Border Adjustment Mechanism.
- GHG Protocol — Corporate Value Chain (Scope 3) Standard.
Need documentation for CBAM or Scope 3 reporting?
Send the alloy, coating, order volume and destination. We will confirm the achievable recycled-content figure and respond within one business day.