CBAMcheck

UK CBAM explained

What the UK Carbon Border Adjustment Mechanism is, who it applies to, how the levy is worked out and what to do now.

Key facts

Start date1 January 2027
Sectors in scopeAluminium, cement, fertiliser, hydrogen, iron, steel
Registration threshold£50,000 of CBAM goods, expected in the next 30 days, or in the rolling 12 months (tested on the 1st of each month)
Liability basisEmbedded emissions × CBAM rate − relief for carbon price paid at origin
CBAM rateSet per sector, per quarter, from the UK ETS price. Not yet published
Filing frequencyAnnual (2027), quarterly from 2028
Record keepingRecords must be kept for 6 years
Rate in CBAMcheck estimates£35–£55 per tonne CO2e

What is UK CBAM?

The UK Carbon Border Adjustment Mechanism is a carbon levy on imports of certain carbon-intensive goods.

Its purpose is to prevent carbon leakage: the risk that UK manufacturers, who pay a carbon cost under the UK Emissions Trading Scheme (UK ETS), lose market share to cheaper imports from countries with weaker or no carbon pricing. CBAM levels the playing field by applying a comparable carbon cost to imported goods at the border.

It is not a tariff on the goods themselves. It is a charge based on the carbon intensity of production. Companies that import from countries with strong carbon pricing pay less or nothing. Companies importing from countries with no carbon pricing pay more.

Who is in scope?

UK CBAM applies to importers of goods in five sectors, defined by specific commodity codes. The liable person is the importer: the person named on the import declaration. A customs broker or freight forwarder filing on your behalf does not take on the liability. A tax representative can file a return for you, but cannot register on your behalf.

Once you meet the £50,000 threshold in Key facts, you must register with HMRC, report embedded emissions and pay the levy. Imports before 1 January 2027 do not count.

SectorKey commodity codes
Aluminium7601, 7603–7616, 7618
Cement2523, 6810, 6811
Fertilisers2814, 2834, 3102, 3105
Hydrogen2804.10
Iron7201–7207, 7218
Steel7208–7217, 7219–7229, 7304–7306

How is the liability calculated?

The calculation for each in-scope import line is:

Liability = Embedded emissions (tCO2e) × CBAM rate (£/t) − Carbon Price Relief (£)

Embedded emissions are calculated as: import weight (tonnes) × emission intensity factor (tCO2e per tonne). This covers both direct process emissions and indirect energy-related emissions in production.

Emission intensity factors are either supplier-verified, from actual production data, or default values. These figures use default emission values. HMRC hasn't published UK values yet, so we use the European Commission's published defaults where they exist and sector averages otherwise. If your suppliers emit less than the default, you're overpaying, and verified supplier data is how you prove it.

The CBAM rate has not yet been published. It will be set per sector, per quarter, from the UK ETS price.

Carbon Price Relief: If a carbon price was paid on the goods under a qualifying mandatory scheme in the country of production (for example, an emissions trading scheme), that amount can be deducted. The carbon price paid must be independently verified on HMRC's Carbon Pricing Verification Form, and the relief is capped at the CBAM liability.

Sector averages CBAMcheck uses where a product has no default value

ProductEstimate
Iron & steel (crude steel)1.92 tCO₂/t crude steel
Aluminium (primary)15.1 tCO₂e/t primary aluminium
Cement (clinker)0.8 tCO₂/t clinker
Fertiliser (ammonia)2.4 tCO₂/t ammonia
Hydrogen11 tCO₂e/t H2

Key dates

Autumn 2026Illustrative CBAM rate due; default emissions values due before end of 2026
1 Jan 2027UK CBAM goes live: all in-scope imports become liable
31 Jan 2028Deadline to register for anyone who met the threshold during 2027
31 May 2028First return and payment due (covering calendar year 2027)
2028Quarterly periods begin: Q1 2028 return due 31 Jul 2028

What importers need to do

1

Assess your exposure now

Find which of your imports fall under CBAM commodity codes and estimate your annual levy. Your CDS data has what you need: commodity codes, countries of origin and import weights.

2

Register with HMRC

If you meet the threshold during 2027, register by 31 January 2028. You are liable for the levy on 2027 imports once you meet the threshold.

3

Engage your in-scope suppliers

Contact suppliers of CBAM goods and request verified emissions data. Where a supplier emits less than the default, its actual figure lowers your levy. Overseas suppliers can take months to produce verified data.

4

Set up your reporting process

The first accounting period covers the full calendar year 2027, with the return and payment due 31 May 2028. From 2028, accounting periods are quarterly: the Q1 2028 return is due 31 July 2028, Q2 2028 is due 29 September 2028, and thereafter returns are due on the last working day of the second month after the quarter ends. You will need systems to track in-scope imports, embedded emissions, and any carbon prices paid at origin, and records must be kept for 6 years.

How to get your import data

To assess your CBAM exposure, you need a record of your imports with commodity codes, countries of origin, and weights (or values). The simplest source is your CDS (Customs Declaration Service) data.

You can download your declarations from HMRC, or ask your customs broker or freight forwarder for an extract with 8 or 10 digit commodity codes.

If your freight forwarder or customs broker declares in their own name, ask them for the data they hold for you: the obligation falls on the importer of record.

CBAMcheck takes CSV or Excel files, matches each commodity code to the CBAM scope and prices it on default emission values.

UK CBAM vs EU CBAM: key differences

The EU CBAM's definitive regime began on 1 January 2026. The UK CBAM is a separate regime with different rules. Complying with one does not satisfy the other.

FeatureUK CBAMEU CBAM
Start date1 Jan 20271 Jan 2026 (full)
SectorsAluminium, cement, fertiliser, hydrogen, iron, steelSimilar, plus electricity
Carbon price linkCBAM rate derived from UK ETS price, adjusted for free allocationEU ETS allowance price
Payment mechanismLevy paid via HMRC returnsEU centralised CBAM registry
Reporting frequencyAnnual (2027), quarterly from 2028Annual declaration, due 30 September (quarterly was transitional only)
Default emissions valuesOne value per product, set by Treasury notice (not yet published)Country-specific defaults
De minimis£50,000 (30-day or rolling 12-month tests)50 tonnes per year (2025 Omnibus package)

Common questions

What if I import below the £50,000 threshold this year but may exceed it next year?+

Once you meet either threshold test in Key facts, you must register. If you are close, check your imports each month.

Do I need verified emissions data from my suppliers?+

No. Without it, default values apply. Where a supplier emits less than the default, its verified data lowers your levy, so start with your largest suppliers.

What if I import through a customs broker or freight forwarder?+

The liable person is the importer: the person named on the import declaration. A customs broker or freight forwarder filing the declaration for you does not take on the liability. A tax representative can file a CBAM return for you, but cannot register on your behalf.

Will goods from the EU attract a carbon price deduction?+

Only if a carbon price was paid on the goods under a qualifying mandatory scheme, such as the EU ETS. There is no blanket exemption for EU-origin goods. The carbon price must be independently verified on HMRC's Carbon Pricing Verification Form, and the relief is capped at the CBAM liability. UK-EU emissions trading linkage has been agreed in principle but has no timetable and is not in force.

Glossary

Embedded emissions

The greenhouse gases emitted during the production of a good, including process emissions and energy used in manufacturing. Measured in tonnes of CO2 equivalent (tCO2e).

UK ETS

The UK Emissions Trading Scheme, the domestic carbon market. The CBAM rate is set from its price.

Carbon price at origin

A carbon cost already paid in the country where the goods were produced, for example under the EU ETS. It is deducted from the UK CBAM levy.

Default emission factor

The value set by HMRC for each product, used where verified supplier data is not available. Not yet published.

Importer of record

The business legally responsible for the import, typically the entity named on the customs declaration. This is who bears the CBAM obligation.

CDS

The Customs Declaration Service, the UK's customs system. Your CDS data has the commodity codes, countries of origin and weights a CBAM estimate needs.

Find out what CBAM will cost your business

Upload your import data for a free estimate.