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UK CBAM & UK ETS Explained: How Carbon Pricing Shapes Import Costs, Compliance and Financial Risk from 2027

CBAM Journal Research & Intelligence Team. See our Editorial Standards and AI Usage Disclosure for how this report was produced and verified — Sekason Research Limited, London


1. Executive Summary

The UK Carbon Border Adjustment Mechanism (UK CBAM) takes effect on 1 January 2027 with a rate set mechanically by the UK Emissions Trading Scheme (UK ETS), not a fixed tariff — meaning liability moves with the UK ETS price and rises structurally as UK ETS Free Allowances phase out over an indicative nine-year timeframe from 2027. Registration is triggered not only by a rolling 12-month £50,000 threshold but also by a forward-looking 30-day test, so importers monitoring only trailing import value risk missing the registration deadline entirely.

Three operational details that determine day-to-day compliance cost — the evidence standard for overseas carbon price relief, sector-specific default emissions values, and exact penalty rates within the applicable statutory schedules — are confirmed in structure but not yet published in full by HMRC, meaning compliance systems must be built now to receive that guidance, not built from it once it lands.


A compliance manager treating UK CBAM as a static customs duty will misforecast liability from year one. The CBAM rate is calculated as the sectoral average of emissions covered by UK ETS Free Allowances over a defined baseline period, adjusted annually by a reduction factor that reflects the scheduled phase-out of those allowances — budgeting on a single opening-year figure will understate cost by the third or fourth accounting period. The first UK CBAM accounting period runs the full calendar year 2027, with the first return and payment due by 31 May 2028 — an unusually long lead time compared with the quarterly reporting that follows from 2028 onward. This is a compliance advantage if used to build supplier data pipelines and internal governance before the regime tightens; it is a liability if importers treat the long first period as a reason to delay.


UK CBAM sits alongside, not identically to, EU CBAM, which has operated under its definitive regime since 1 January 2026. The two regimes diverge on scope (the EU includes electricity; the UK, as legislated, does not), on rate-setting method (EU CBAM certificate pricing is market-based; UK CBAM is administratively set from the UK ETS price), and on reporting cadence. A UK importer also moving EU-bound goods cannot run one compliance process for both.


This report sets out the regulatory mechanics, the compliance obligations attached to each stage from registration to payment, the financial exposure drivers, sector-specific considerations across the five in-scope sectors, a phased action framework, and the confirmed policy trajectory through 2028 — distinguishing throughout between what HMRC has confirmed and what remains pending publication.


The Carbon Cost Is Coming. The Guidance Isn’t Here Yet. UK CBAM & UK ETS report, red line below

2. Regulatory Context


2.1 Why the UK Introduced CBAM

Carbon leakage is the risk that domestic carbon pricing under the UK ETS pushes emissions-intensive production offshore rather than reducing it — UK manufacturers face a carbon cost that overseas competitors selling into the UK market do not. UK CBAM addresses this by applying an equivalent carbon cost to imported goods in the same five sectors already covered by the UK ETS: steel, aluminium, cement, fertilisers, and hydrogen.


This distinguishes UK CBAM from a conventional customs duty in one structural respect: a customs duty is typically a fixed percentage of value, set by trade policy and largely static year to year. UK CBAM is not. Its rate is derived mechanically from the domestic carbon price mechanism and moves with it. An importer's liability changes as the UK ETS price changes and as the Free Allowance reduction factor increases — it is a carbon-price pass-through, not a trade tariff.


Table 1 — Carbon Leakage: Why CBAM Exists

Without CBAM

With CBAM

UK producers pay UK ETS carbon cost on domestic output

UK producers pay UK ETS carbon cost on domestic output

Imported goods carry no equivalent carbon cost

Imported goods carry an equivalent carbon cost via CBAM

Production incentive shifts toward lower-regulation jurisdictions

Competitive position between domestic and imported goods is equalised on carbon cost

Table 2 — Policy Objectives

Objective

Mechanism

Prevent carbon leakage

Apply carbon cost to imports equivalent to domestic UK ETS liability

Preserve UK ETS price signal

Remove incentive to import around domestic carbon pricing

Align eventually with EU CBAM

UK–EU ETS linkage agreed in principle, 19 May 2025

2.2 How UK CBAM Connects with the UK ETS

This is the mechanical core of the regime, and it is where most compliance misunderstanding will occur. UK CBAM does not have an independently published tariff schedule. The CBAM rate is calculated as the sectoral average of emissions covered by UK ETS Free Allowances over a baseline period. In practice, this means the rate an importer pays per tonne of embedded emissions tracks what a comparable UK domestic producer in that sector would have paid under the UK ETS, net of the free allocation that producer currently receives.


The critical variable for forward planning is the reduction factor. UK ETS Free Allowances are not permanent — the government has confirmed a phase-out over an indicative nine-year timeframe beginning in 2027, applied at sub-installation level (meaning the reduction is calculated against specific production processes within a site, not a single site-wide figure). As Free Allowances shrink year on year, the reduction factor applied to the CBAM rate calculation increases, which raises the effective CBAM charge per tonne even if the underlying UK ETS carbon price stays flat. A liability forecast built on the opening 2027 rate alone will be structurally out of date by 2028 or 2029.


HMRC's published policy design materials set out this relationship in two reference diagrams: one showing how CBAM liability is calculated for a given consignment (embedded emissions × applicable CBAM rate, less any deductible overseas carbon price), and a second showing how the CBAM rate itself is derived from the UK ETS sectoral Free Allowance average and reduction factor.

Both diagrams are structural, not numerical — no fixed GBP-per-tonne rate is published in guidance, because the rate is not fixed. Importers calculating exposure must therefore model against the prevailing UK ETS price and the current reduction factor at the time of each accounting period, not against a static assumption.


Infographic titled How the UK CBAM Rate Is Calculated, showing five steps and a UK vs EU CBAM comparison table.

Table 3 — UK ETS to UK CBAM: The Calculation Chain

Step

Input

Output

1

UK ETS carbon price (market-set)

Base carbon cost per tonne CO2e

2

Sectoral Free Allowance average (baseline period)

Sector-specific starting adjustment

3

Reduction factor (increases annually, 2027–~2036)

Adjusted CBAM rate for the accounting period

4

Embedded emissions of imported goods (verified data or default value)

CBAM rate × embedded emissions = gross liability

5

Deductible overseas carbon price paid (evidenced)

Gross liability less credit = net CBAM payable

HMRC has not published the specific numerical UK ETS Free Allowance baseline figures, the exact reduction factor schedule year-by-year, or a worked GBP-per-tonne CBAM rate. Importers should treat any third-party figure claiming to state "the" UK CBAM rate with scepticism until HMRC publishes the calculation methodology document in full ahead of commencement.


2.3 UK CBAM vs EU CBAM (Focused Comparison)

The two regimes share a common goal — carbon leakage prevention at the border — and cover overlapping sectors, but a UK importer with EU-facing supply chains cannot run a single compliance process across both.


Table 4 — UK CBAM vs EU CBAM: Operational Differences

Dimension

UK CBAM

EU CBAM

Commencement

1 January 2027

1 January 2026 (definitive regime)

Scope sectors

Steel, aluminium, cement, fertilisers, hydrogen

Steel, aluminium, cement, fertilisers, hydrogen, electricity

Rate-setting method

Administratively derived from UK ETS Free Allowance average and reduction factor

Market-based CBAM certificate price

Registration threshold

£50,000 rolling 12-month value, or forward-looking 30-day test

Separate EU-specific threshold and registry regime

First reporting period

Full calendar year 2027; quarterly from 2028

Quarterly declarations under its own established timetable

First payment deadline

31 May 2028

Set under EU implementing acts (regime-specific)

Glass and ceramics

Excluded from 2027 scope (reversing an earlier 2023 proposal)

Not part of UK scope decision; EU treatment is separate

Refined products/fuels

Under review — forthcoming Call for Evidence

Governed separately under EU implementing rules

The scope divergence on electricity is the most consequential for multinational importers: a business managing EU CBAM electricity obligations cannot assume the same treatment applies to UK-bound electricity-intensive goods, because the UK regime as legislated does not include electricity at commencement.


3. Compliance Obligations


3.1 Registration Thresholds

An importer must register for UK CBAM where in-scope goods imported over a rolling 12-month period exceed £50,000 in value. Registration is not purely retrospective: HMRC's design also applies a forward-looking 30-day test — where an importer reasonably expects to exceed the threshold within the next 30 days, registration obligations are triggered ahead of the goods physically arriving. Businesses that assess liability only by looking backward at the trailing 12 months risk missing this forward trigger.


What the buyer does: run both tests — trailing 12-month import value and forward 30-day forecast — at import planning stage, not just at year-end reconciliation.


3.2 Reporting Obligations

Registered declarants must submit CBAM returns covering the quantity of in-scope goods imported and their embedded emissions. The first accounting period runs the full calendar year 2027, moving to quarterly returns from 2028. This structure gives importers an unusually long runway in year one, but it converts to a materially tighter quarterly cadence the following year.


What the buyer does: use the extended first period to build data collection systems capable of quarterly turnaround before the quarterly regime begins in 2028, not as a reason to delay system-building.


3.3 Embedded Emissions Requirements

Liability is calculated on the embedded emissions of imported goods — the emissions associated with their production. Where verified supplier-specific data is unavailable, default values apply instead. HMRC has confirmed that default value figures will be published in advance of CBAM's introduction, but they are not yet available; sector-specific default emissions values have not been published, and importers should not rely on third-party estimates presented as official figures.


What the buyer does: prioritise verified supplier emissions data collection now, since default values — once published — are generally set conservatively and are likely to produce a higher liability than accurate supplier-specific data.


3.4 Overseas Carbon Price Relief

Where an importer can evidence that a deductible carbon price has already been paid on the goods in their country of production — a carbon tax, an emissions trading scheme charge, or another jurisdiction's CBAM — that amount can be credited against the UK CBAM liability, reducing the net amount payable. The categories of deductible carbon price are confirmed; the evidence standard an importer or overseas supplier must meet to substantiate a claim is not. HMRC has confirmed further detail and guidance on this evidence requirement will be published ahead of commencement, but the documentary standard itself is not yet available.


What the buyer does: begin requesting overseas carbon price documentation from suppliers now — tax receipts, ETS compliance certificates, other CBAM payment evidence — so the evidence base exists regardless of the exact standard HMRC ultimately specifies.


3.5 Record Keeping & Evidence

Registered declarants must retain records supporting both the embedded emissions figures used in returns and any overseas carbon price relief claimed, sufficient to withstand HMRC compliance checks. Given that both the default value methodology and the overseas relief evidence standard are still pending publication, the safest current position is to over-document rather than under-document: retain supplier correspondence, production process data, and any overseas carbon pricing evidence in full, even where the eventual HMRC standard may prove less demanding.


3.6 Governance Responsibilities

UK CBAM compliance is not a single-function obligation. Effective execution spans customs and trade (import classification and threshold monitoring), procurement (supplier emissions data collection), finance (liability calculation and payment), and compliance (registration, returns, and evidence retention).


Table 5 — Governance Responsibility Matrix

Function

Responsibility

Customs/Trade

Import classification, threshold monitoring (12-month and 30-day tests)

Procurement

Supplier engagement, embedded emissions data collection, overseas carbon price evidence

Finance

Liability calculation, payment scheduling, budgeting for rising reduction factor

Compliance

Registration, return submission, record retention, HMRC correspondence

Compliance Workflow: threshold monitoring → registration (12-month or 30-day trigger) → supplier data collection → embedded emissions calculation → overseas relief evidence assembly → CBAM return submission → payment → record retention.

4. Key Dates and Deadlines


Table 6 — UK CBAM Compliance Timeline

Date

Milestone

1 January 2026

EU CBAM definitive regime in force (relevant for UK importers with EU-facing supply chains)

9 April 2026

Draft UK CBAM secondary legislation published for consultation

21 May 2026

UK CBAM secondary legislation consultation closes

1 January 2027

UK CBAM commences — registration and reporting obligations begin

1 January 2027 – 31 December 2027

First UK CBAM accounting period (full calendar year)

31 May 2028

First UK CBAM return and payment due

From 2028

UK CBAM moves to quarterly returns and payments

The gap between commencement (1 January 2027) and the first payment deadline (31 May 2028) is the single most important planning window in the regime: seventeen months to build systems before the cadence tightens to quarterly.


5. Financial Exposure and Risk


5.1 UK ETS Carbon Price and CBAM Rates

CBAM liability is driven by the prevailing UK ETS carbon price, filtered through the sectoral Free Allowance average and reduction factor described in Section 2.2. There is no fixed GBP-per-tonne CBAM rate published in guidance, and none should be assumed. Exposure is a function of three moving variables: the UK ETS price at the time of the accounting period, the sector-specific reduction factor for that year, and the embedded emissions of the specific goods imported.


5.2 Free Allowance Adjustments

The UK ETS Free Allowance phase-out, confirmed over an indicative nine-year timeframe from 2027, is applied at sub-installation level. For CBAM purposes, this means the reduction factor built into the rate calculation increases progressively through the phase-out period. The financial consequence for importers is structural rather than cyclical: liability per tonne of embedded emissions will trend upward over the phase-out window independent of any change in the underlying UK ETS carbon price itself.


What the buyer does: build multi-year budget models that assume a rising reduction factor, not a static year-one figure carried forward.


5.3 Carbon Price Relief

As set out in Section 3.4, overseas carbon price relief reduces net liability where evidenced. The categories of deductible carbon price (tax, ETS, other CBAM) are confirmed. The precise evidentiary threshold is not yet published, so importers cannot yet quantify with certainty how much of a given overseas carbon cost will be accepted as deductible — this is a live financial-planning uncertainty, not a settled input.


5.4 Financial Exposure Scenarios

A precise worked liability calculation (low/medium/high scenarios in GBP) cannot currently be produced to CBAM Journal's sourcing standard, because two of the three required inputs — the numerical Free Allowance baseline and the year-by-year reduction factor schedule — are not yet published by HMRC. No worked exposure scenario table is presented here; any such table published elsewhere before HMRC releases the underlying methodology figures should be treated as illustrative estimation, not confirmed guidance.


What can be stated with confidence is the direction of exposure: importers of goods with high embedded emissions intensity, sourced from jurisdictions with no equivalent domestic carbon pricing (and therefore no deductible relief), face the highest net CBAM liability. Importers able to source verified low-emissions supplier data, or import from jurisdictions with an established carbon price, face materially lower net exposure — both through lower embedded emissions figures and through relief credits.


Table 7 — Directional Risk Matrix

Supplier profile

Embedded emissions

Overseas carbon price paid

Relative CBAM exposure

High-emissions producer, no carbon pricing in origin country

High

None

Highest

High-emissions producer, established carbon price in origin country

High

Yes (relief available)

Reduced by relief, still elevated

Low-emissions producer, verified data

Low

Variable

Lowest

Default value applied (no supplier data)

Conservative default (likely elevated)

None claimed

Elevated — incentive to obtain verified data

5.5 Compliance Risks

The principal near-term compliance risk is not miscalculation of a known rate — it is building systems against guidance that has not yet been published (default values, relief evidence standard) and having to retrofit processes once HMRC releases final detail. The secondary risk is missing the forward-looking 30-day registration trigger by monitoring only trailing 12-month import value.


5.6 Penalties and Administrative Risk

UK CBAM penalties are not a bespoke schedule — Finance Act 2026, Schedule 17, paragraphs 33–39, confirms that CBAM compliance failures are addressed by amending and applying existing HMRC penalty regimes: failure to register or provide information (Schedule 41, Finance Act 2008), failure to make a return (Schedule 24, Finance Act 2021), errors in returns and other documents (Schedule 24, Finance Act 2007), failure to pay CBAM (Schedule 26, Finance Act 2021), and failure to notify changes to registration information.


The specific penalty percentages and fixed amounts applicable within each of these schedules, as they apply to CBAM specifically, are not stated here pending further extraction. Importers should treat CBAM penalty exposure as governed by the UK's standard behaviour-based penalty architecture — which generally scales with whether an error was careless, deliberate, or concealed, and whether disclosure was prompted or unprompted — rather than assume a flat penalty figure.


What the buyer does: treat CBAM penalty risk with the same seriousness as VAT or corporation tax penalty risk — it sits within the same statutory family, not a separate lower-consequence regime.


UK CBAM Compliance Timeline infographic showing key regulatory dates 2026–2028, consultation, commencement, and payment deadlines.

6. Sector-Specific Impact Analysis

Official UK guidance confirms the five in-scope sectors and their inclusion at commencement, but does not publish unified per-sector GBP/tCO2 exposure figures — because, as established in Section 2.2, the CBAM rate is not fixed and depends on the prevailing UK ETS price and reduction factor at the time of each accounting period, not a static sectoral tariff.


Table 8 — Sector Scope Confirmation

Sector

UK CBAM scope (2027)

Note

Steel/Iron

In scope

Confirmed at commencement

Aluminium

In scope

Confirmed at commencement

Cement

In scope

Confirmed at commencement

Fertilisers

In scope

Confirmed at commencement

Hydrogen

In scope

Confirmed at commencement

Glass & Ceramics

Excluded

Earlier 2023 proposal reversed

Refined products/fuels

Under review

Forthcoming Call for Evidence

Electricity

Not in UK scope

Included in EU CBAM — material UK/EU divergence

Steel/Iron

No official UK default emissions intensity figure for steel has been published, and no sourced data on emissions variation by production route was found in the research record. The compliance priority is unaffected by that gap: engage overseas steel suppliers now for verified embedded emissions data ahead of default values being published.


Aluminium

Sector-specific default values and cost exposure figures for aluminium are not yet published. The compliance priority is the same as steel — prioritise verified supplier-specific embedded emissions data now, ahead of default value publication, rather than waiting for HMRC's default figures to arrive.


Cement

Cement importers must apply the same registration and reporting rules as every other in-scope sector, using verified supplier data or default values once published. No sourced data on cement's typical import volume or value profile relative to the £50,000 threshold was found in the research record; compliance priority is to apply both the 12-month and 30-day threshold tests (Section 3.1) without assuming any sector is inherently below the registration trigger.


Fertilisers

Fertiliser production is characterised by high process emissions (as distinct from purely energy-related emissions), which official guidance highlights as a factor requiring robust supplier data. Process emissions are harder to estimate by proxy than energy-related emissions, which increases the practical value of direct supplier engagement over default-value reliance for this sector specifically.


Hydrogen

Hydrogen (specified forms) is in scope, with emissions accounting rules detailed in policy design documents; the specific methodology was not extracted from the retrieved sources at a level of detail sufficient to summarise beyond confirming in-scope status. Compliance priority: monitor HMRC guidance closely as the methodology is published.


Table 9 — Sector Compliance Priority Summary

Sector

Primary data challenge

Immediate action

Steel

Production-route emissions variation

Engage suppliers on route-specific data

Aluminium

Electricity-source dependency

Prioritise smelter energy source disclosure

Cement

Volume-driven threshold exposure

Recheck registration threshold by volume, not just value

Fertilisers

Process emissions (non-energy)

Direct supplier engagement over default reliance

Hydrogen

Methodology not yet fully published

Monitor HMRC guidance closely


7. Practical Action Framework


  • Phase 1 — Assess Imports. Map all imported goods against the five in-scope sectors. Run both the trailing 12-month value test and the forward-looking 30-day test monthly, not annually. Owner: Customs/Trade.

  • Phase 2 — Collect Supplier Data. Begin requesting verified embedded emissions data and overseas carbon price evidence from suppliers now, ahead of default values and the relief evidence standard being published. Document what is collected even before HMRC confirms the exact standard it will accept. Owner: Procurement.

  • Phase 3 — Calculate Exposure. Build a liability model using the confirmed calculation chain (Table 3) with placeholder variables for the still-unpublished baseline and reduction factor figures, so the model is ready to populate the moment HMRC releases them. Owner: Finance.

  • Phase 4 — Establish Governance. Assign the Governance Matrix (Table 5) formally, with named ownership per function, before registration obligations begin. Owner: Compliance, with cross-functional sign-off.

  • Phase 5 — Prepare Reporting Systems. Use the extended first accounting period (calendar year 2027) to build and test a reporting process capable of the quarterly cadence that begins in 2028 — do not build only for the annual first-period requirement. Owner: Compliance/Finance.

  • Phase 6 — Internal Audit Readiness. Establish record-retention practice now (Section 3.5) sufficient to withstand HMRC compliance checks, given the statutory penalty regimes in play (Section 5.6). Owner: Compliance.


2026 Readiness Checklist

  • Threshold monitoring process live (12-month and 30-day tests)

  • Supplier data request process initiated

  • Overseas carbon price evidence collection underway

  • Governance Matrix assigned with named owners

  • Draft liability model built, ready for HMRC figures

  • Record-retention system in place

8. Strategic Outlook

The dominant forward driver of rising CBAM cost is confirmed and quantifiable in trajectory, if not yet in figures: the UK ETS Free Allowance phase-out runs over an indicative nine-year timeframe from 2027, applied at sub-installation level, and as Free Allowances shrink, the reduction factor increases — CBAM rates rise structurally through to roughly the mid-2030s independent of carbon price movements.

UK–EU ETS linkage was agreed in principle at the 19 May 2025 UK–EU Summit, with both parties committing to link the two systems "as soon as feasible." A future linkage would materially change the CBAM landscape for businesses trading across both markets, potentially reducing the compliance burden of running separate UK and EU carbon-cost calculations — but no implementation timetable has been confirmed, and this remains a directional commitment rather than a scheduled milestone.


Scope developments: glass and ceramics were excluded from the 2027 scope, reversing an earlier 2023 proposal to include them — a live example of scope narrowing rather than only expansion. Refined products and fuels remain under active review via a forthcoming government Call for Evidence, meaning further scope changes before or shortly after commencement cannot be ruled out.

No confirmed timetable exists for UK–EU ETS linkage implementation, and no outcome has been confirmed for the refined products/fuels Call for Evidence — both are correctly characterised here as directional signals, not scheduled certainties.


Regulatory Horizon Map

Horizon

Development

Status

2027–2036 (indicative)

UK ETS Free Allowance phase-out

Confirmed trajectory

Post-2025 Summit

UK–EU ETS linkage

Agreed in principle; no timetable

Pre-2027

Default values and relief evidence standard

Pending publication

TBC

Refined products/fuels scope decision

Under Call for Evidence

2028 onward

Quarterly UK CBAM reporting

Confirmed

For the Compliance Manager, the action this outlook demands is not to wait passively for HMRC's remaining publications: build governance, supplier data pipelines, and a liability model now, per Section 7, so that when the Free Allowance baseline, reduction factor schedule, and relief evidence standard are published, they can be applied on day one rather than triggering a system rebuild under deadline pressure.


9. Frequently Asked Questions


How exactly is the UK CBAM rate calculated using the UK ETS carbon price?

The CBAM rate is the sectoral average of emissions covered by UK ETS Free Allowances over a baseline period, adjusted annually by a reduction factor reflecting the scheduled phase-out of those allowances. It is not a fixed tariff — it moves with the UK ETS price and the reduction factor for each accounting period. HMRC has not published a numerical baseline or year-by-year reduction factor schedule.


How do UK ETS free allowances affect my UK CBAM liability after 1 January 2027? Free Allowances are phased out over an indicative nine-year timeframe from 2027, applied at sub-installation level. As allowances shrink, the reduction factor built into the CBAM rate increases, raising the effective charge per tonne of embedded emissions year on year, independent of any change in the underlying carbon price.


What evidence must overseas suppliers provide for carbon price relief claims?

Deductible carbon prices include tax, emissions trading scheme charges, and other CBAM payments already made in the country of production. HMRC has confirmed the categories of eligible carbon price but has not yet published the specific evidence standard required to substantiate a claim; further guidance is expected ahead of commencement.


Which internal teams should be responsible for UK CBAM compliance and reporting? Customs/Trade owns threshold monitoring and import classification, Procurement owns supplier emissions data and overseas carbon price evidence, Finance owns liability calculation and payment, and Compliance owns registration, returns, and record retention. Cross-functional governance should be assigned before registration obligations begin.


How should imported goods from countries with their own carbon pricing systems be treated under UK CBAM?

Where a deductible carbon price — a tax, an ETS charge, or another CBAM — has been paid in the country of production, that amount can be credited against the UK CBAM liability, reducing the net amount payable. The importer must evidence the payment to HMRC's required standard, which is not yet published.


What should my organisation complete before UK CBAM starts on 1 January 2027? Complete threshold monitoring for both the 12-month and 30-day tests, begin supplier data and overseas carbon price evidence collection, assign governance ownership across Customs, Procurement, Finance, and Compliance, and build a liability model structured to receive HMRC's baseline and reduction factor figures once published.


10. References and Sources

See SOURCES USED IN THIS REPORT below.


Sources


Legal Disclaimer:

This report is produced for informational and compliance-planning purposes only. It does not constitute legal, tax, or financial advice. Organisations should seek independent professional advice before making compliance or financial decisions based on this content. Figures and mechanisms described reflect published UK government guidance available as of the date of this report and are subject to change as HMRC publishes further detail ahead of UK CBAM's commencement on 1 January 2027.

Read complete disclaimer here: https://www.cbamjournal.com/disclaimer


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