Are stainless steel utensils and other steel household articles covered by the United Kingdom (UK) Carbon Border Adjustment Mechanism (CBAM)?
Not on the list HM Revenue and Customs (HMRC) prints. Its chapter 73 entries are headings 7301 to 7311, 7318 and 7326, so table, kitchen and household articles under heading 7323 are not named. Check the exact code with your buyer, because 7326, other articles of iron or steel, is on the list.
What HMRC's iron and steel list names in chapter 73
- Chapter 72, iron and steel, is listed as a whole, with named exceptions such as scrap.
- In chapter 73 the list names headings 7301 to 7311, 7318 (screws, bolts, nuts, washers and similar) and 7326 (other articles of iron or steel).
- HMRC's rule: goods in scope of the tax in the list include "the heading" and "sub-headings that are under the heading".
- HMRC's policy summary says the list of commodity codes is "correct as at the date of this publication".
Household headings next door that are not named
- 7321: stoves, cookers, barbecues and similar non-electric domestic appliances.
- 7322: radiators for central heating, not electrically heated, and air heaters.
- 7323: table, kitchen or other household articles, and parts, of iron or steel; iron or steel wool; pot scourers.
- 7324: sanitary ware of iron or steel.
- Heading names in this page that HMRC's CBAM pages do not print come from the UK Trade Tariff.
Why the code decides
A commodity code is like a shelf number in a library. The book is found by its number, not by what it is made of. HMRC says the goods in scope are "identified by the commodity codes as listed in the Annex".
Our reading, not HMRC's: a steel pan or plate classifies under its own heading, 7323, and not under the catch-all 7326. HMRC's list does not name 7323, so the pan itself would not be a named CBAM good on HMRC's list; the broker confirms the code. The steel sheet it was pressed from is not what the UK importer brings in, so it is not charged.
What could change the answer
- A different code. A tank or drum is under 7309 or 7310, which are named. Check the code on the buyer's declaration, not only your own.
- A tariff change. HMRC says it will update codes "to maintain the product scope of CBAM" if the UK Tariff changes.
- Steel sold as plain sheet, coil or bar for a UK maker to press into utensils. That is chapter 72 and is named.
What to do
- Ask your buyer or its customs broker for the 8-digit code it will declare.
- If you and the broker disagree on the code, ask HMRC through its questions page.
- A buyer may still ask for a footprint for its own reports, even where the UK CBAM does not apply.
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.
- Chains, springs and wire rope
- Cast iron castings
- Steel tanks, drums and cylinders
- Which listed code covers my code
- UK CBAM for Indian exporters
Sources: HMRC, Goods within the iron and steel sector (updated 16 July 2026), HMRC, Carbon Border Adjustment Mechanism (CBAM): Policy summary (updated 2 November 2026), HMRC, Send HMRC questions about CBAM, UK Integrated Online Tariff, heading names for 7321 to 7324
Last reviewed 2026-11-07. List checked against HMRC's iron and steel scope page (updated 16 July 2026) and the policy summary annex (updated 2 November 2026). HMRC says codes can change with the UK Tariff, so re-check each year. Heading names for 7321 to 7324 are from the UK Integrated Online Tariff.