Senseible

Is UK-made steel inside our product exempt from the UK CBAM?

It is left out. HMRC's UK CBAM guidance exempts the emissions in precursor goods produced in the UK, so they do not enter your product's figure. You must give your verifier evidence that the precursor was made in the UK, and the verifier confirms the exemption was applied correctly and is evidenced.

How the exemption works

A precursor is a CBAM good used to make another CBAM good, such as billet rolled into bar. Normally its embodied emissions are added to your figure. Where the precursor was produced in the UK, those emissions do not need to be included. The legal basis is section 147(3) of the Finance Act 2026.

What your verifier will ask for

On the importer's side

Your UK buyer must keep records of evidence of UK origin provided for goods exported and then reimported inside a complex good. Send them the same evidence your verifier saw.

Bars rolled from mixed billets

Example figures, not HMRC defaults.

What Senseible does here

Senseible reads billet and coil purchase invoices by supplier, so UK-made and other precursor tonnes stay on separate lines. 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), HMRC, UK CBAM monitoring, reporting and verification technical guidance (October 2026)

Last reviewed 2026-11-03.