For policy-makers –Close CBAM boundary gaps: include electricity (indirect) in chargeable emissions with robust recognition of clean power contracts; consider bringing alumina into scope or otherwise recognizing refining emissions; and harmonize with UK design to avoid arbitrage. –The European Commission’s ongoing work to simplify and strengthen CBAM and to explore downstream coverage provides an opportunity to correct known distortions before full charging starts. –Use ETS revenues to fund material CfDs that bridge the step-change to 3.0 tCO2e/t and first wave to 2.0 tCO2e/t.131 For financiers –Underwrite “3.0 by 2030” packages that combine: –Customer offtake with minimum carbon floors and step-up volumes. –Indexed pricing or CfDs. –Dedicated power hedges (e.g. renewable PPAs + storage). –Prioritize projects in grids where marginal electricity emissions are falling fast and CO2 transport/storage options are bankable.Conclusion The suppliers interviewed for this report were clear: technology is not the bottleneck, the market signal is. Where price signals exist as a result of ETS-linked obligations or buyers willing to pay for verified intensities, capital can move from efficiency retrofits into deeper process upgrades. Where policy boundaries exclude electricity and alumina, where RFQs conflate recycled content with carbon performance and where offtake stops at one- or two-year pilots, the result is predictable: projects stall in the pre-FID valley of death. The near-term path is practical and specific. Buyers can unlock scale by specifying intensity bands, rewarding post-consumer scrap and signing bankable tenors. Policy-makers can help to repair boundary gaps in CBAM and recycle carbon revenues into CfDs that bridge the next tranche of capex. Financiers can syndicate risk across offtake, power and carbon revenue so that suppliers can underwrite calciners, anode plants and power- switching at pace. Meanwhile industry platforms can keep score publicly on contracts that actually move tonnage. Turning Challenge into Opportunity: Supplier Voices from Heavy-Emitting Sectors 43

Turning Challenge into Opportunity 2025