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UK CBAM comes into force on 1 January 2027 – is your business ready?

The UK Government has now published the supporting legislation and guidance for the UK’s Carbon Border Adjustment Mechanism (CBAM), providing businesses with greater clarity on how the scheme will operate ahead of its introduction on 1 January 2027.

UK CBAM introduces a carbon-based charge on imports of certain carbon-intensive goods into the UK. If your business imports products within the following sectors, now is the time to understand how the new requirements may affect you:

  • Aluminium
  • Cement
  • Fertiliser
  • Hydrogen
  • Iron & Steel

Although the first CBAM return and payment will not be due until 31 May 2028, businesses should use the remainder of 2026 to understand their obligations and ensure the appropriate processes are in place from the start of 2027.

What you need to know.

  • UK CBAM comes into force on 1 January 2027.
  • The liable person will normally be the UK importer named on the customs declaration.
  • Registration may be required where the value of in-scope imports exceeds £50,000 over the relevant registration period.
  • Importers will need to obtain embedded emissions data from their overseas suppliers.
  • Where a recognised carbon price has already been paid in the country of manufacture, Carbon Price Relief may be available, subject to the relevant conditions and supporting evidence.
  • The first CBAM return and payment are due by 31 May 2028, covering imports made during the 2027 accounting period.

What should importers do now?

We recommend that businesses:

  • Review whether imported goods fall within the scope of UK CBAM.
  • Confirm the correct commodity codes are being used.
  • Engage with overseas suppliers to obtain embedded emissions data.
  • Assess the potential financial impact of the new requirements.
  • Establish internal processes ahead of 1 January 2027.

Further information

HMRC has now published the supporting legislation, guidance and technical documents covering the operation of UK CBAM, including registration requirements, reporting obligations, Carbon Price Relief and record keeping.

The full collection of guidance and supporting documents is available on GOV.UK

If you have any questions regarding the customs or logistics implications of UK CBAM, please contact your usual Simarco representative.