Is lime, limestone or a concrete product covered by the United Kingdom (UK) Carbon Border Adjustment Mechanism (CBAM) cement list?

Not on the list HM Revenue and Customs (HMRC) prints. The cement list has six lines: other kaolinic clays (2507 00 80), clinker (2523 10 00), white Portland, other Portland, aluminous and other hydraulic cements. Lime (2522), limestone (2521) and articles of cement or concrete (6810) are not named.

What HMRC's cement list names

• 2507 00 80: other kaolinic clays.
• 2523 10 00: cement clinkers.
• 2523 21 00: white Portland cement, whether or not artificially coloured.
• 2523 29 00: other Portland cement.
• 2523 30 00: aluminous cement.
• 2523 90 00: other hydraulic cements.
• Only carbon dioxide is counted for these goods.

Neighbours not named

• 2521: limestone flux, and limestone used to make lime or cement.
• 2522: quicklime, slaked lime and hydraulic lime.
• 6810: articles of cement, of concrete or of artificial stone.
• Heading names in this page that HMRC's CBAM pages do not print come from the UK Trade Tariff.

What this means for a maker

A commodity code is like a shelf number in a library, and HMRC's list names only some shelves. Limestone is the raw rock. Clinker is the intermediate that is baked from it. Cement is the ground product. Of these, HMRC names clinker and the cements, and not the rock or lime.

Our reading, not HMRC's: a UK buyer that imports concrete articles brings in goods under 6810, which is not named, so the cement inside them is not charged separately. A buyer that imports cement or clinker itself is in the named list. Check the code on the buyer's declaration.

What to do

• Get the 8-digit code your buyer will declare, in writing.
• If you sell both cement and cement products, keep their records apart, as only one is named.
• If a code is unclear, ask HMRC through its questions page.

What Senseible does here

Senseible reads fuel invoices and electricity bills into dated, fingerprinted records. It does not set commodity codes or tell you whether a product is in the UK CBAM. Your buyer's customs broker, or HMRC, settles that.

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• UK CBAM for Indian exporters

Sources: HMRC, Carbon Border Adjustment Mechanism (CBAM): Policy summary (updated 2 November 2026), HMRC, Check which goods are in scope of CBAM (sector pages, updated 16 July 2026), HMRC, Send HMRC questions about CBAM, UK Integrated Online Tariff, heading names for 2521, 2522 and 6810

Last reviewed 2026-11-07. List checked against the policy summary annex (updated 2 November 2026) and HMRC's cement scope page (updated 16 July 2026). The reading on concrete products is ours. Re-check each year. Heading names for 2521, 2522 and 6810 are from the UK Integrated Online Tariff.