ASI Performance Standard readiness and CBAM exposure modelling
ESG risk assessment, ASI Performance Standard gap analysis, and CBAM embedded-emissions readiness for a GCC aluminium and recycled metals manufacturer with European trade exposure.
Client · A GCC aluminium and recycled metals manufacturer
- Standard ASI Performance V3
- Regulatory exposure EU CBAM
- Scope Mine-to-metal
The situation
A GCC aluminium and recycled metals manufacturer faced compounding pressure from two directions: tier-1 European automotive and packaging buyers signalling that ASI (Aluminium Stewardship Initiative) Performance Standard certification would become a procurement prerequisite within 18 months; and the EU Carbon Border Adjustment Mechanism (CBAM) creating direct revenue exposure on EU-bound shipments through embedded-emissions reporting requirements.
Internal sustainability function had foundational policies and a Scope 1+2 GHG inventory, but Scope 3 supply chain coverage was partial, environmental management was not formally aligned to ISO 14001, and product-level carbon footprinting required for CBAM verification did not exist.
The work
Phase 1 — ESG risk assessment & gap mapping (6 weeks). Full mapping against ASI Performance Standard V3 across all 11 principles. Output: prioritised gap register with 47 items spanning environmental performance, supply chain due diligence, human rights, governance, and material stewardship. Effort and timeline estimate per gap; sequencing logic for buyer-priority items first.
Phase 2 — KPI integration & operational embedding (4 months). Worked alongside the internal team on the highest-priority gaps:
- GHG performance benchmarking against ASI’s cradle-to-gate threshold for “low carbon” primary aluminium (≤4 tCO₂e/t Al)
- Mine-to-metal carbon footprint methodology — bauxite-origin tracing, alumina refining allocation, smelter emissions, downstream processing
- Supply chain due diligence framework for primary aluminium sourcing with traceability requirements
- Site-level environmental management uplift toward ISO 14001 alignment
- Human rights policy refresh and operational rollout under ASI V3 Principle 9
- Documentation and evidence packaging for audit
CBAM readiness workstream (parallel). Embedded-emissions methodology aligned with CBAM verification requirements, product-level data architecture, monitoring plan, and verifier engagement strategy. Reconciled methodology with EU ETS approach.
The outcome
ASI Performance Standard certification recommended on first audit. CBAM-compliant embedded-emissions reporting structure operational ahead of the full implementation phase.
The buyer-driven commercial pressure that prompted the engagement was successfully addressed: anchor customers retained, new European OEM commercial conversations initiated with ASI status confirmed.
What we’d do differently
- Earlier supply chain engagement. We started supplier traceability work in month 3. Earlier engagement would have surfaced data gaps before they became audit findings.
- Tighter integration with the GHG inventory rebuild. GHG performance benchmarking was technically separate from the inventory work but ultimately fed the same audit evidence pack. Running them as one workstream would have been more efficient.
- Run CBAM verification design in parallel from week 1. We sequenced it after ASI; running both in parallel would have surfaced the methodology overlap and consolidated the evidence file.