Senseible

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

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

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.