Which year's emissions figure will our UK buyer use under the CBAM?
Your UK buyer can tie the figure either to the import date or to the production year. For goods imported in 2027 they use your verified 2027 figure, or 2026 if 2027 is not ready. From 2028 they use the latest verified figure from the two calendar years before import.
Option 1: linked to the import date
- Imported in 2027: the verified figure for calendar year 2027 if it exists; if not, the verified figure for 2026.
- Imported from 1 January 2028: the most recent verified figure from either of the two calendar years before the import year.
- HMRC example: a good imported on 25 June 2029 uses the 2028 figure if verified, otherwise 2027.
Option 2: linked to the production year
The buyer uses the verified figure for the calendar year in which the good was made. HMRC's example: made in 2030, imported in 2032, use 2030.
What this means for your plant
- Your monitoring year is always the calendar year, not April to March.
- A 2027 import is reported on the buyer's first return, due 31 May 2028, so your 2027 figure needs verifying by spring 2028.
- Keep production dates on dispatch documents if a buyer chooses option 2.
What Senseible does here
Senseible keeps records by date, so it can total a calendar year even when your books run April to March. 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, Getting the emissions intensity when importing CBAM goods
Last reviewed 2026-11-02.