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Department of Climate Change, Energy, the Environment and Water https://consult.dcceew.gov.au/tranche-1-exposure-draft-guarantee-of-origin-rules
27 March 2025
Dear Minister
Exposure draft (tranche 1) – Future Made in Australia (Guarantee of Origin) Rules 2025
The Australian Aluminium Council (the Council) represents Australia’s bauxite mining, alumina refining, aluminium smelting and downstream processing industries. The aluminium industry has been operating in
Australia since 1955, and over the decades has been a significant contributor to the nation’s economy.
Department of Industry, Science and Resources has recently forecast1 that earnings for Australian exports of aluminium, alumina and bauxite are expected to rise from $16 billion in 2023–24 to $18 billion in 2024–25.
More than $14B of this comes from the alumina and aluminium industries, as value adding mineral processing sectors. The industry includes six large bauxite mines plus several smaller mines which collectively produce over 100 Mt per annum making Australia one of the world’s largest producers of bauxite. Australia is the world’s largest exporter of alumina with five alumina refineries producing around 20 Mt per annum of alumina. Australia is the seventh largest producer of aluminium, with four aluminium smelters and additional downstream processing industries including more than 20 extrusion presses. Aluminium2 is one of the commodities most widely used in the global transition to a clean energy future. It is also recognised for its importance to both economic development and low emissions transition. Aluminium is Australia’s top manufacturing export. The industry directly employs more than 21,000 people, including 6,600 full time equivalent contractors. It also indirectly supports a further 55,000 families predominantly in regional
Australia. The integrated industry contributes around $18 B to Australia’s GDP.
The Department of Climate Change, Energy, the Environment and Water (DCCEEW) has released a
Consultation Paper (the Paper) on the Exposure draft (tranche 1) – Future Made in Australia (Guarantee of
Origin [GO]) Rules 2025. The Council will respond to selected aspects of this Paper and notes that that some of its Members may have also made submissions, and these should be read alongside this submission.
Below-baseline certificate retirement restrictions and any temporal and spatial data matching
The Council notes that key aspects of the implementation of the Future Made in Australia program, namely the additional product guarantee of origins for alumina and aluminium and details on the use of below baseline Renewable Electricity Guarantee of Origin (REGO) and any temporal and spatial data matching for particular products and schemes are not yet included in this consultation. The Council notes that the last statement on the operation of below baseline REGOs was as part of an Options Paper released in September
2023. As iterated at the time, the Council and its Members primary concerns with the GO / REGO is the treatment of electricity and how that flows through to manufactured goods such as aluminium and with future electrification, alumina, and the utility of the GO/REGO scheme in accounting for real reductions in scope 1 and 2 emissions from their operations. The Council continues to urge the Department to release the detailed consultation on retirement of below baseline certificates and the application of these to entities
1 https://www.industry.gov.au/publications/resources-and-energy-quarterly-december-2023
2 https://www.worldbank.org/en/topic/extractiveindustries/brief/climate-smart-mining-minerals-for-climate-action
Australian Aluminium Council Page 1 of 2
who are carrying out emissions-intensive, trade-exposed activities as a matter of priority. The rules which will govern this are material to parts of the industry which are currently negotiating electricity contracts.
Other Matters
Part 3: Certification of products
Due to the limited time for review and the complexity of the definitions there are a number of areas that are unclear:
• Certificates are required to include the amount of electricity use in the production of a product, does
this include internally generated electricity? Is there any differentiation for internal generation?
• For a batch produced over several days, how would you report the time period within which the
renewable electricity and produced and used? If you had 24 hour operations, but bought solar (no
storage) REGOs for the production, if they were generated on the same days would it be apparent
that there wasn’t full temporal matching?
• Are there traceability requirements for matching production with delivery? For example, a bulk
product such as alumina may be delivered to storage at a delivery gate from production at more than
one refinery. Does the intensity need to be dependant on the blend? For materials that are delivered
into storage, how is the production time matched to the delivery date and time? If a facility has part
of a plant running on a lower emission stream eg for an alumina refinery, one of four calciners is
running on hydrogen or electricity, could the emissions intensity of a batch be determined based on
a narrow product pathway?
• How would delivery date and time be determined for a product that is being almost constantly
delivered into a pipeline?
• If batches are small (when there could be several ships weekly), how is emission intensity calculated?
Where some emissions sources are calculated based on invoices (NGERS criterion A), would it only
be counted if there is a delivery during that period? How would an annual reconciliation check verify
the emissions from a single batch?
An example of how a certificate would look would be very useful in future consultation.
Conclusion
The Council welcomes the opportunity to continue to engage with the Department on Guarantee of Origin and Renewable Energy Guarantee of Origin and reiterates the urgency of the next phase of consultation. The
Council is happy to provide further information on any of the issues raised in this submission.
Kind regards,
Chief Executive Officer
Australian Aluminium Council
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