Senseible

UK CBAM starts on 1 January 2027. See if your shipments are caught.

The UK will tax the emissions in imported aluminium, cement, fertiliser, hydrogen, and iron and steel. The importer pays HMRC. Your buyer will ask you for the number.

From when, and what your buyer does first

1 Jan 2027: UK CBAM starts. It applies to goods imported into the UK on or after this date, across the whole UK including Northern Ireland.
From 1 Jan 2027: Your buyer starts counting. An importer registers when it expects £50,000 or more of CBAM goods within 30 days, or has imported £50,000 or more in the previous 12 months. HMRC says to check on the first day of each month.
1 Jan 2028: Registration opens. Importers over the threshold register with HMRC. In this first year they have until 31 January 2028.
31 May 2028: First return and payment. One 12-month period covers everything imported in 2027.
31 Jul 2028: Quarterly returns begin. From 1 January 2028 the periods are quarterly. The first, 1 January to 31 March 2028, is due on 31 July 2028.

What your UK buyer will ask for

Emissions per tonne (From you): The tonnes of CO2 your plant gives off per tonne of each good, for one calendar year. Your buyer reports it on the CBAM return and HMRC multiplies it by the weight. Without it, your buyer uses HMRC's default value for the good.
Verification report or summary (From you): Your verifier's full report, or the summary for the good your buyer imported. Your buyer needs it to report your figure instead of the default.
The year it covers (From you): For goods imported in 2027, your buyer asks for the 2027 figure, or the one from the year before if 2027 is not verified yet. 1 January to 31 December is the monitoring year.
Net weight (On your invoices): Weight of each good in kilograms, without packaging, as it arrives in the UK. Your buyer gets it from import papers, invoices or packing lists, so make yours match what you ship.
Code, value and origin (On your invoices): For each good your buyer keeps the 8-digit commodity code, a description, the date it cleared UK customs, the value and proof of origin. Your invoices and customs papers carry most of it.

How to get your numbers ready

Monitor one calendar year. 1 January to 31 December, using the method in HMRC's technical guidance.
Appoint a verifier accredited for UK CBAM. Independent of your plant, and accredited for your production processes. A verifier accredited for fertiliser plants cannot verify a steel plant.
Send your buyer the report or summary. The full report, or the summary for the good they imported.
Your buyer keeps it for 6 years. It is their evidence on the return. Keep your own copy and the records behind it.

Send us your fuel, power and production records. We build your figure and check every number ourselves. For the UK it must then be verified by a verifier accredited for UK CBAM. Already have a verifier? Send them the file.

Selling into the EU too? Two schemes, two sets of rules

Starts. UK: 1 January 2027. EU: 1 January 2026.
What your buyer does. UK: Registers with HMRC, files returns and pays the tax. EU: Becomes an authorised CBAM declarant and buys CBAM certificates.
Smallest importer caught. UK: £50,000 of CBAM goods in 12 months, by value. EU: More than 50 tonnes of CBAM goods, by weight.
Goods. UK: Aluminium, cement, fertiliser, hydrogen, and iron and steel. EU: The same five, plus electricity.

HMRC says its monitoring and verification methods are broadly designed to work with the EU CBAM. They are still two schemes, so each buyer needs a file that meets its own rules. EU CBAM for Indian exporters

Straight answers

Does my company pay UK CBAM?

Only if you are the importer. The importer is the person named on the UK import declaration where duty is due, and it can be based inside or outside the UK. Your UK buyer usually is the importer. If you sell delivered duty paid and your name is on the declaration, it is you.

What if I have no verified figure?

Your buyer uses the default value HMRC sets for the good. HMRC says an importer must use a default value when it has no evidence that the actual emissions data was verified.

Can my buyer deduct a carbon price paid in India?

Only a carbon price paid under a qualifying carbon pricing scheme counts, as Carbon Price Relief. It needs a carbon pricing verification form from the plant that made the goods. Our answer on India's carbon market is linked below.

Does the India-UK trade deal change this?

HMRC's policy summary names one route to an exemption: goods from a country whose carbon market is linked to the UK's. Our answer on the trade deal is linked below.