UK CBAM is Coming And Preparation Can Help Avoid Surprises

Written by Eve Halliday, Customs Specalist, ChamberCustoms

With Halloween approaching, businesses may welcome a little less mystery around new regulations. For importers, the UK Carbon Border Adjustment Mechanism (CBAM) is one change worth understanding ahead of its introduction on 1 January 2027. 

CBAM will place a carbon charge on specified imported goods, helping ensure they face carbon costs comparable to those paid by UK manufacturers. Its purpose is to reduce “carbon leakage”, where production and associated emissions move overseas because countries apply different carbon pricing policies. 

Which goods are covered?

1. 1

   Aluminium

2. 2

   Cement

3. 3

   Fertiliser

4. 4

   Hydrogen

5. 5

   Iron & Steel

(The UK government is considering extending CBAM to include refinery products. A consultation launched on 28 October 2026 seeks views on the feasibility and potential impacts of bringing these products into scope. Their inclusion remains under consideration and has not yet been confirmed)

Businesses should check individual commodity codes to establish whether their products fall within scope. They also need to establish whether they are the importer responsible for CBAM and whether any exclusions apply when assessing the registration threshold. 

A useful starting point is to review product records alongside purchasing and customs information. This can help identify where further information is needed from suppliers or colleagues before the scheme begins. 

Understanding the registration threshold

The £50,000 threshold involves two tests:

Looking Forward

Looking forward: whether imports of CBAM goods are expected to reach £50,000 or more over the next 30 days. This test applies on any given day from 1 January 2027.

Looking backward

Looking back: on the first day of each month, whether imports totalled £50,000 or more during the preceding 12 months.

Meeting either test can trigger a requirement to register. During 2027, the backward-looking test only counts imports from 1 January 2027. Businesses therefore need to monitor both completed and anticipated imports. 

How the charge will work 

CBAM will initially cover direct emissions associated with producing the goods, including emissions in relevant precursor materials. Indirect emissions are delayed until 2029 at the earliest. Importers can use independently verified actual emissions data or government default values. 

The charge is calculated using embodied emissions and the applicable CBAM rate, less any eligible Carbon Price Relief for emissions already subject to a qualifying carbon pricing scheme. Actual emissions data must be supported by qualifying verification. 

For businesses, this makes early supplier conversations useful. Establishing who holds the emissions information, and whether it can be shared with supporting evidence, will help inform preparations. 

Key dates for businesses 

Registration opens on 1 January 2028. Businesses becoming liable during 2027 must register by 31 January 2028, with their first return and payment due by 31 May 2028. 

These later administrative deadlines do not delay liability arising in 2027. Businesses must also maintain the required CBAM records from 1 January 2027. Accounting periods become quarterly from 2028. 

How does UK CBAM compare with EU CBAM 

Both schemes aim to address carbon emissions associated with imported goods, but their administration differs. UK CBAM will operate as a tax administered by HMRC from January 2027. The EU’s definitive regime began in January 2026 and uses authorised CBAM declarants and a system of purchasing and surrendering certificates. 

The thresholds also differ: the UK uses a £50,000 value-based registration threshold, while the EU generally applies a 50-tonne annual threshold across covered goods. The EU threshold exemption does not apply to electricity or hydrogen. Electricity is also included in the EU scheme, but is outside the UK’s initial scope. 

Businesses trading in both markets should therefore check each scheme separately. Experience with EU CBAM can provide a useful starting point, but businesses should confirm the applicable products, responsibilities and reporting requirements for their UK imports. 

Further information and support 

Our International Trade Week 2026 UK and EU CBAM webinar will take place on Tuesday 10 November. We will also host a UK CBAM Overview webinar on Wednesday 18th November, with a more detailed UK CBAM Masterclass coming soon. 

ChamberCustoms can help businesses understand their UK CBAM obligations and prepare for the changes ahead. 

Our UK CBAM Managed Service combines specialist customs consultancy with dedicated software to help manage the ongoing requirements of the scheme. 

From reviewing import data and identifying potential liabilities to managing emissions information, forecasting carbon costs and supporting statutory reporting, our managed service is designed to reduce the administrative burden and give businesses greater visibility and control over their CBAM obligations. 

Get in touch with ChamberCustoms to discuss how we can support your business in preparing for UK CBAM.