Written by Mitch Perks, Deputy Director of Trade Services, British Chambers of Commerce
Three months ago, I stood in the QEII Centre ahead of our Driving International Trade Conference and reflected on a simple assumption I had held for some time.
I thought CBAM would take longer to land.
Not in terms of legislation. The direction of travel has been clear for a while. What I underestimated was the speed at which CBAM would move from being a regulatory discussion into a commercial reality for businesses trading internationally.
From Regulatory Discussion to Commercial Reality
Since March, I have had the opportunity to speak at conferences, industry events and international forums across the UK and Europe. I have spoken with manufacturers, exporters, importers, customs professionals and supply chain leaders.
Whilst the discussions have covered everything from customs compliance and free trade agreements through to geopolitics and market access, one theme continues to surface time and time again.
Businesses are operating in an increasingly complex environment, but complexity should never become a barrier to growth.
That message felt particularly relevant in the last week as we returned to the QEII Centre for the British Chambers of Commerce Global Annual Conference 2026.
The theme of this year's conference was Delivering Growth.
In her keynote address, our Director General, Shevaun Haviland CBE, set out clearly what businesses need from Government and what the Chamber Network is already doing to support growth across the UK and internationally.
Her message was straightforward. This is about action, not ambition.
As Shevaun said, "Back business, and we'll deliver growth. If we want to see growth, our political leaders must reduce the burdens on business. You must back businesses, not tax them."
Listening to that speech, I found myself reflecting on the conversations I have been having throughout the year.
Because growth and compliance are often discussed as though they are competing priorities.
In reality, they are becoming increasingly interconnected.
What Businesses Are Telling Us
Back in March, at our Driving International Trade Conference, we hosted a dedicated CBAM Lunch and Learn session. We brought together businesses, chambers and trade professionals to discuss what is arguably one of the most significant changes to impact UK and EU trade in recent years.
What struck me most that day was not the complexity of the regulation itself… It was the level of uncertainty.
Many businesses were still trying to determine whether CBAM applied to them. Others assumed it did without fully understanding why. Some believed that because the legal responsibility sits with the EU importer, there was little they needed to do.
Yet the conversations taking place in the room told a very different story.
Businesses were already receiving requests for emissions data. Supply chains were beginning to ask questions. Commercial teams were starting to consider how carbon costs could influence pricing and competitiveness.
Even then, it was becoming clear that CBAM was no longer simply a compliance exercise; it was becoming a business issue.
That message has only strengthened over the last three months.
The Pressure Is Moving Up the Supply Chain
In May, I had the privilege of delivering a session on UK CBAM at the IACBAM Summit in Prague. Discussions there focused not only on the UK's planned implementation from January 2027, but also on potential future linkage arrangements, implementation challenges and the practical realities businesses are likely to face as the UK develops its own approach.
What became clear from those discussions was that businesses are looking for certainty.
They want to understand timelines, they want to understand what good preparation looks like but most importantly, they want to understand how today's decisions could affect tomorrow's competitiveness.
The same themes emerged during my conversation with Tanya Beckett at GTR UK 2 weeks ago.
We discussed the growing impact of CBAM on UK and EU supply chains and what businesses should be doing now.
One of the key points I made during that discussion is something I continue to repeat in almost every conversation I have.
Whilst the legal obligation under EU CBAM sits with the EU importer, UK exporters increasingly have a commercial responsibility to support their customers with robust emissions data. EU importers are required to account for the embedded emissions within the products they import, and to do that effectively they need accurate information from their suppliers. They need transparency. They need confidence in the information they receive.
The pressure is moving up the supply chain.
Businesses that fail to engage with that reality risk becoming more expensive, more difficult to work with and ultimately less competitive.
Why Classification Still Matters
At the same time, I continue to see one misunderstanding appear more frequently than almost any other.
Classification.
Many businesses still do not fully understand whether their goods fall within CBAM scope.
Some assume they are unaffected because of the products they manufacture or sell, others assume they are impacted because of broad product descriptions but neither approach is sufficient.
CBAM scope is determined by commodity codes, not assumptions.
Time and time again, I find myself having conversations where businesses are making decisions based on how they describe a product rather than how it is legally classified. In some cases, businesses are relying on internal product descriptions or sales terminology instead of the commodity codes used for customs purposes. That distinction matters because CBAM does not follow marketing descriptions. It follows classification. If the classification is wrong, everything that follows can be wrong as well.
The same principle applies more broadly to compliance.
Compliance as Part of Growth
Earlier this month, I spoke at the Global Britain Trade Expo on Navigating Compliance. Whilst much of the discussion focused on customs compliance, the wider message remains equally relevant to CBAM.
Too often businesses see compliance as something that happens after the fact.
A box to tick, a problem to solve when an audit arrives or a task for one individual or department.
The most successful businesses do not think that way, they embed compliance into how they operate.
They understand their products, they understand their supply chains and they understand their responsibilities. But most importantly, they prepare before they are forced to.
That is why I increasingly view CBAM not as an environmental policy discussion, but as a business preparedness discussion.
Yes, it introduces new reporting requirements.
Yes, it creates additional financial considerations.
Yes, it adds complexity.
But it also rewards businesses that invest in understanding their data, engaging with their supply chains and preparing early.
Over the last three months, whether speaking at DITC, Prague, GTR UK, the Global Britain Trade Expo or this week's Global Annual Conference, I have found myself coming back to the same conclusion.
Growth does not happen by accident. It happens when businesses have the confidence to invest, trade and expand and that confidence comes from clarity.
And clarity comes from preparation.
CBAM is not coming. It is here.
The businesses that recognise that now, understand their exposure, engage with their supply chains and build compliance into their wider growth strategy will be the businesses best positioned to succeed in the years ahead.
Because in today's trading environment, compliance is no longer separate from growth. It is part of it.
Three Takeaways for Businesses
If there are three things I would encourage every business to take away from these conversations over the last few months, they would be these.
Make compliance part of your business strategy, not just a regulatory requirement.
Whether it is customs, CBAM or wider international trade obligations, compliance should sit at the heart of how your business operates, not become an afterthought when a problem arises.
Be proactive rather than reactive.
The businesses that are preparing now, engaging with their supply chains and asking the right questions today will be in a far stronger position than those waiting for legislation or customers to force action.
Understand your products.
Classification matters. Knowing your commodity codes, understanding whether your goods fall within scope of CBAM and having confidence in your data will help avoid costly mistakes and put you in a much stronger commercial position.
Conclusion
For me, that is what delivering growth is really about. Giving businesses the confidence, knowledge and practical support to navigate an increasingly complex trading environment, not just for today, but for the future.
Mitch Perks
Deputy Director of Trade Services, British Chambers of Commerce
Written in a personal capacity