Guide to UK CBAM Requirements in 2027

If you import aluminium goods, iron and steel goods, or other goods covered by the Carbon Border Adjustment Mechanism (CBAM) from 1 January 2027, then you may need to:

• Register for CBAM with HMRC
• Keep records concerning the imported goods
• Pay the relevant taxes

In this guide, I cover the key CBAM regulations and requirements.

Background

According to Part 5 – Carbon border adjustment mechanism of the Finance Act 2026, a CBAM tax must be charged on the emissions embodied in a “CBAM good” when:

a. The goods are imported into the United Kingdom, and

b. The value of the imported goods is GBP 50,000 or more over a period of 12 months, and

c. The goods are imported during the course of business

Here is the list of CBAM goods listed in the Act:

• Aluminium goods
• Cement
• Fertilisers
• Hydrogen
• Iron and steel goods

Besides the Act, in this guide I also list several regulations made under the Act that I found on the guidance page “Prepare for the Carbon Border Adjustment Mechanism (CBAM)” on the gov.uk website.

I understand that these regulations are made under the Act and set requirements that are complementary to those set by the Act.

Note that other regulations under the Act may also be published. I listed what I could find on the day of publication of this guide.

Part 5 – Carbon border adjustment mechanism of the Finance Act 2026

a. This part of the Finance Act sets requirements for:

• List of covered goods
• Importation
• CBAM charges, rates
• Exemptions
• Carbon price reliefs
• Administration and enforcement
• Regulations made under the part

b. Section 157 states that Regulations can be made under this Part in order to make provisions for different purposes, including incidental, consequential, supplementary or transitional provisions.

c. This Part has effect from 1 January 2027.

The Carbon Border Adjustment Mechanism (Calculation of CBAM Rate and Determination of Carbon Price Relief) Regulations 2026

a. These regulations set requirements concerning:

• The calculation of the CBAM rate
• The calculation of carbon price relief (if relevant)
• Verification and accreditation
• Record keeping

b. The regulations are made under section 157 of the Finance Act 2026.

c. These regulations come into force on 1 January 2027.

The Carbon Border Adjustment Mechanism (Administrative Provisions) Regulations 2026

a. These regulations set requirements concerning:

• Record keeping
• Registration
• Returns, assessments of weight, and reimbursements

b. The Commissioners made these Regulations in accordance with section 157 of the Finance Act 2026.

c. These regulations come into force on 1 January 2027.

The Carbon Border Adjustment Mechanism (Transitory Provision) Regulations 2026

a. These regulations make transitory provisions concerning Schedule 17 – Administration of CBAM of the Finance Act 2026 to temporarily delay the obligation to register for CBAM. They also extend the duration of the first accounting period for CBAM.

b. The Treasury made these Regulations in accordance with section 157 of the Finance Act 2026.

c. These regulations come into force on 1 January 2027.

The Carbon Border Adjustment Mechanism (Emissions and Verification) Regulations 2026

a. These regulations set requirements concerning:

• Calculating embodied emissions
• Monitoring and verification of emissions data

b. The Treasury and the Commissioners for His Majesty’s Revenue and Customs made these Regulations in accordance with the Finance Act 2026.

c. These Regulations come into force on 1 January 2027.

The Finance Act 2009, Sections 101 and 102 (Carbon Border Adjustment Mechanism) (Interest) (Appointed Day) Order 2026

This Order sets 1 January 2027 as the day on which requirements for CBAM set out in sections 101 and 102 of the Finance Act 2009 come into force:

• 101. Late payment interest on sums due to HMRC
• 102. Repayment interest on sums to be paid by HMRC

UK CBAM Process

1. Find out if CBAM applies to you

CBAM applies to you only if you import goods that are listed in Schedule 16 of the Finance Act 2026. Here is the list of relevant goods, covered commodity codes, and classifications:

Sector	Commodity code / Classification
Aluminium goods	7601 Unwrought aluminium 7603 Aluminium powders and flakes 7604 Aluminium bars, rods and profiles 7605 Aluminium wire 7606 Aluminium plates, sheets and strip, of a thickness exceeding 0.2 mm 7607 Aluminium foil (whether or not printed or backed with paper, paper-board, plastics or similar backing materials) of a thickness (excluding any backing) not exceeding 0.2 mm 7608 Aluminium tubes and pipes 7609 Aluminium tube or pipe fittings (for example, couplings, elbows, sleeves) 7610 Certain Aluminium structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge-sections, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, balustrades, pillars and columns); aluminium plates, rods, profiles, tubes and the like, prepared for use in structures 7611 Aluminium reservoirs, tanks, vats and similar containers, for any material (other than compressed or liquefied gas), of a capacity exceeding 300 litres, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment 7612 Aluminium casks, drums, cans, boxes and similar containers (including rigid or collapsible tubular containers), for any material (other than compressed or liquefied gas), of a capacity not exceeding 300 litres, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment 7613 Aluminium containers for compressed or liquefied gas 7614 Stranded wire, cables, plaited bands and the like, of aluminium, not electrically insulated 7616 Other articles of aluminium
Cement	2507 00 80 Other kaolinic clays 2523 10 Cement clinkers 2523 21 White Portland cement, whether or not artificially coloured 2523 29 Other Portland cement 2523 30 Aluminous cement 2523 90 Other hydraulic cements
Fertilisers	2808 00 Nitric acid; sulphonitric acids 2814 Ammonia, anhydrous or in aqueous solution 2834 21 Nitrates of potassium 3102 Mineral or chemical fertilisers, nitrogenous 3105 Mineral or chemical fertilisers containing two or three of the fertilising elements nitrogen, phosphorus and potassium; other fertilisers; goods of this chapter in tablets or similar forms or in packages of a gross weight not exceeding 10 kg Except: 3105 60 Mineral or chemical fertilisers containing the two fertilising elements phosphorus and potassium
Hydrogen	2804 10 Hydrogen
Iron and steel goods	2601 12 Agglomerated 72, Iron and steel Except: 7202 21 Ferro-silicon 7202 30 Ferro-silico-manganese 7202 50 Ferro-silico-chromium 7202 70 Ferro-molybdenum 7202 80 Ferro-tungsten and ferro-silico-tungsten 7202 91 Ferro-titanium and ferro-silico-titanium 7202 92 Ferro-vanadium 7202 93 Ferro-niobium 7202 99 10 Ferro-phosphorus 7202 99 30 Ferro-silico-magnesium 7202 99 80 Other 7204 Ferrous waste and scrap; remelting scrap ingots and steel 7301 Sheet piling of iron or steel, whether or not drilled, punched or made from assembled elements; welded angles, shapes and sections, of iron or steel 7302 Railway or tramway track construction material of iron or steel, the following: rails, check-rails and rack rails, switch blades, crossing frogs, point rods and other crossing pieces, sleepers (cross-ties), fish- plates, chairs, chair wedges, sole plates (base plates), rail clips, bedplates, ties and other material specialised for jointing or fixing rails 7303 Tubes, pipes and hollow profiles, of cast iron 7304 Tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel 7305 Other tubes and pipes (for example, welded, riveted or similarly closed), having circular cross-sections, the external diameter of which exceeds 406.4 mm, of iron or steel 7306 Other tubes, pipes and hollow profiles (for example, open seam or welded, riveted or similarly closed), of iron or steel 7307 Tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel 7308 Structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge-sections, lock- gates, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, shutters, balustrades, pillars and columns), of iron or steel; plates, rods, angles, shapes, sections, tubes and the like, prepared for use in structures, of iron or steel 7309 Reservoirs, tanks, vats and similar containers for any material (other than compressed or liquefied gas), of iron or steel, of a capacity exceeding 300 litres, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment 7310 Tanks, casks, drums, cans, boxes and similar containers, for any material (other than compressed or liquefied gas), of iron or steel, of a capacity not exceeding 300 litres, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment 7311 Containers for compressed or liquefied gas, of iron or steel 7318 Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel 7326 Other articles of iron or steel

Note that my understanding is that CBAM only applies if you are importing goods that fall under the listed commodity codes, excluding the ones marked under “except”.

2. Find out if you need to register

According to Schedule 17 of the Act, you need to register only if one of the following two situations occurs:

a. In the previous 12 months you have imported CBAM goods for a value of at least GBP 50,000, or

b. You expect to import CBAM goods for a value of at least GBP 50,000 within 30 days

When is CBAM registration required?

According to the guidance page “Check if you’ll need to register for Carbon Border Adjustment Mechanism (CBAM)”, registration will be opened by 1 January 2028.

Required information

Here is the information that you need to provide during registration, as listed in Part 3 of the Carbon Border Adjustment Mechanism (Administrative Provisions) Regulations 2026:

a. Person’s name, address, phone number, and email address

b. If the information is provided by an officer or employee, their name, position in the company, phone number, and email address

c. The address of the place of business

d. Company type (e.g., limited company, partnership, etc.)

e. EORI number

f. VAT registration number, if any

g. Date on which registration was triggered

h. Value of the imported CBAM goods

i. Estimated weight of the CBAM goods in each CBAM sector

3. Determine what kind of documentation you need

According to the Carbon Border Adjustment Mechanism (Administrative Provisions) Regulations 2026, you will need to keep the following records for 6 years:

• The 8-digit commodity code and description of the goods
• The date of importation of the goods in the UK
• The value of the goods
• The weight of the goods
• Registration information records
• Records for returns, if any
• Records relating to reimbursement arrangements, if any

The guidance page “Keeping records for Carbon Border Adjustment Mechanism (CBAM)” also mentions that records could be:

• Import declarations
• Import entry acceptance advice
• Bill of lading documents
• Discharge of a customs procedure
• Commercial documents (e.g., record of movement of goods in the UK)
• UK customs duty documents
• Repayment or remission of duty documents
• Evidence of UK origin materials, already carbon taxed in reimported goods

It also mentions that some of these documents may come from manufacturers and suppliers (e.g., to show the weight and value of the goods).

4. Pay taxes (if any)

CBAM is charged according to the type of goods that you import multiplied by the “number of tonnes of carbon dioxide equivalent emissions embodied in the CBAM good”.

The “sectoral domestic price” will be published by the Treasury each quarter. I understood that HMRC plans to publish guidance on the specific rates for the different goods soon. Also, by reading the Act, I understand that you need to pay taxes only if the registration requirements are triggered.

5. Claim reliefs, if any

According to the Act, CBAM is not charged if a “returned goods relief” is applicable, which means that goods that have previously been exported have been returned to the UK.

There are also other cases in which reliefs are applicable, as explained in the guidance page “Claiming Carbon Price Relief for Carbon Border Adjustment Mechanism (CBAM)”. I understand that this concerns a situation in which the imported goods were already subject to a qualifying carbon pricing scheme (e.g., in other countries).

To claim relief, you should complete a carbon pricing verification form. You can find more information in the Carbon Border Adjustment Mechanism (Calculation of CBAM Rate and Determination of Carbon Price Relief) Regulations 2026.

FAQ

When will UK CBAM requirements apply?

The CBAM requirements apply to certain goods that are imported into the UK from 1 January 2027.

What kind of goods are covered by UK CBAM?

Schedule 16 of the Finance Act 2026 lists the types of goods that are deemed to be CBAM goods, and their respective commodity codes. The following types of goods are mentioned:

• Aluminium goods
• Cement
• Fertilisers
• Hydrogen
• Iron and steel goods

Who is responsible for UK CBAM?

The person who is responsible for the emissions embodied in a CBAM good is the importer. In particular, the importer is described as:

a. The person listed in a declaration for the Customs procedure, or

b. The person on whose behalf the goods are imported

What sort of documents do we need?

You need to keep records, such as the following information:

• The 8-digit commodity code and description of the goods
• The date of importation of the goods in the UK
• The value of the goods
• The weight of the goods
• Registration information

If you want to claim relief, you may need to fill in a carbon pricing verification form.