Our steel is processed in a UK free zone. When is CBAM charged?
Not when the steel enters the free zone. Under storage (free zones), inward processing or authorised use, the UK CBAM charge arises when goods pass the tax point. If the steel is made into a non-CBAM good, only the original steel inside it is charged. Re-exported before the tax point, nothing is due.
The three outcomes
- CBAM good made into a non-CBAM good: charged when the processed good passes the tax point, only on the portion of the original CBAM good that forms part of it.
- CBAM good made into another CBAM good, or a non-CBAM good made into a CBAM good: charged on the CBAM good that passes the tax point.
- Exported from the UK before the tax point: no CBAM liability, and it does not count towards the £50,000 threshold.
The threshold
In every case the value of the CBAM good the charge is based on counts towards the importer's £50,000 registration threshold.
What your buyer needs from you
The emissions intensity of the steel you shipped, verified, or HMRC's default for its commodity code. For a non-CBAM finished good, the charge still rests on your steel, so your figure is still what matters.
Coil into inward processing
- 120 t of coil declared to inward processing and pressed into a finished good outside the CBAM list.
- 70 t of the coil ends up in goods released to the UK market; 50 t in goods exported before the tax point.
- Chargeable: the 70 t of coil. At 2.00000 tCO2e/t, embodied emissions are 70 x 2.00000 = 140 tCO2e.
- The 50 t exported carries no CBAM and does not count towards the threshold.
Example intensity.
What Senseible does here
Senseible's part is on your plant's side: a per-product figure built from your fuel and input invoices. 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)
Last reviewed 2026-11-03.