Our product is made in India from imported steel. Which origin counts for the UK CBAM?
The origin under the UK's non-preferential rules of origin, as customs defines it. The UK CBAM charges goods originating outside the UK, and the return records that origin for each consignment. Goods of UK origin are out of scope. Where your input steel was made matters for your emissions figure, not for this origin test.
Two different questions
- Origin of the good: decided by non-preferential rules of origin. It sets whether CBAM applies and what goes in the country of origin field on the return.
- Origin of the precursor steel: goes into your emissions figure, as embodied emissions from the mill that made it.
Preferential origin is a different test
A preferential origin claim for a lower tariff under a trade agreement is not what the UK CBAM uses. Ask your customs broker for the non-preferential origin of each product you ship.
When UK steel is involved
- Steel produced in the UK and used as a precursor in your product: its emissions are exempt from your figure, with evidence.
- A UK-origin CBAM good sent abroad for processing and returned as a CBAM good: the UK carbon price it already bore can reduce the CBAM liability.
Fasteners from imported wire rod
- You make bolts in Pune from wire rod bought from a mill abroad.
- Country of origin on the importer's return: whatever non-preferential rules give for the bolts.
- Your emissions figure: rod tonnes times the rod mill's verified figure, or the default, plus your own heat treatment emissions.
What Senseible does here
Senseible reads wire rod and billet purchases by supplier with your own fuel invoices, the inputs for the emissions side of this question. We build the figure from your records and check every figure in-house; for the UK it must then be verified by a verifier accredited for UK CBAM. Have your own verifier? Send it to them.
Sources: HMRC, Carbon Border Adjustment Mechanism (CBAM): Policy summary (updated 2 November 2026), HMRC, UK CBAM monitoring, reporting and verification technical guidance (October 2026)
Last reviewed 2026-11-03.