Our goods leave India in December 2026 and reach the UK in January 2027. Does the United Kingdom (UK) Carbon Border Adjustment Mechanism (CBAM) apply?

It turns on the import date, not the sailing date. HM Revenue and Customs (HMRC) says the UK CBAM applies to goods imported on or after 1 January 2027. In most cases the charge arises at the tax point: when goods are imported and become liable to duty, or enter the UK if no duty applies.

The tax point in plain words

The tax point is like a ticket barrier. It does not matter when you left home. What matters is when you pass the barrier.

HMRC's policy summary says the tax point arises "when a CBAM good is imported into the UK and becomes liable to import duty (or would become liable if legislation did not disapply that duty)". For goods with no import duty, "the tax point occurs when the goods enter the UK". HMRC's records page describes it as when the good "first entered the UK or cleared customs".

The same date applies only if the goods are not held under a special customs procedure.

What this means for a ship that sails in December

• The scheme applies to goods "imported into the UK on or after 1 January 2027". Goods that pass the tax point before that date are outside it.
• Our reading, not HMRC's: the bill of lading date or the date the cargo left India does not decide the matter. The date the goods are imported does.
• HMRC also says not to include the value of CBAM goods imported before 1 January 2027 when checking the £50,000 registration limit.
• Our reading: a delay at sea or at the port can push the tax point across 1 January in either direction, so the buyer should watch the declaration date, not the sailing date.

Which emissions figure

HMRC lets the buyer tie the figure to the import date or to the production year. If it ties it to the import date for goods imported in 2027, it asks for the most recently verified 2027 figure, or 2026 if 2027 is not available. If it ties it to the production year, a good made in 2026 uses the 2026 figure.

HMRC's example says the first return for 2027 imports is filed from 31 May 2028.

Before you load

• Tell your buyer the expected arrival week, and say it may move.
• Put the sailing date and the expected UK entry date on the shipping file.
• Ask your buyer to note the actual import declaration date when the cargo clears. It decides the quarter, whether the cargo counts at all and, if the buyer ties the figure to the import date, the figure year.

Two cargoes that both sail on 28 December 2026

• Cargo A is imported and becomes liable to duty on 30 December 2026. Tax point before 1 January 2027: outside the UK CBAM, and not counted towards the £50,000 limit.
• Cargo B is imported and becomes liable to duty on 6 January 2027. Tax point after 1 January 2027: inside the UK CBAM, counted towards the limit, and, if the buyer ties the figure to the import date, it asks for the 2027 figure, or 2026 if 2027 is not ready.

Both dates are examples for the logic. Neither is a real shipment.

What Senseible does here

Senseible reads fuel invoices and electricity bills into dated, fingerprinted records. It does not track cargo, set the import date or file the UK CBAM return. The importer and its customs broker hold those dates.

• When exactly the UK CBAM is charged
• Which year's emissions figure the buyer uses
• When UK importers can register
• UK CBAM for Indian exporters

Sources: HMRC, Carbon Border Adjustment Mechanism (CBAM): Policy summary (updated 2 November 2026), HMRC, Work out the date you will need to register for CBAM (updated 16 July 2026), HMRC, Keeping records for CBAM (updated 3 November 2026), HMRC, Getting the emissions intensity when importing CBAM goods (updated 16 October 2026)

Last reviewed 2026-11-07. Facts are from HMRC's policy summary, registration guidance, records guidance and emissions intensity guidance, all dated July to November 2026. The reading that sailing date does not matter is ours. The tax point example dates assume no special customs procedure. The import date logic is also on the live tax point page; this page stays for the year-end search.