EU CBAM vs UK CBAM: What You Need if You Import into Both (2026)

If you import into both the EU and Great Britain, you have two carbon border obligations, not one. The EU Carbon Border Adjustment Mechanism entered its definitive phase on 1 January 2026 and is live now. The UK's separate scheme starts on 1 January 2027. They cover an overlapping but not identical list of goods, they use different thresholds, they price against different carbon markets, and you register with different authorities. The one thing that carries across is your supplier emissions data — collect it once and it serves both filings.

The short answer

The threshold difference is the one that catches people out

This is where the two schemes diverge most sharply, and it is the question most importers get wrong.

The EU threshold is a mass threshold. Regulation (EU) 2025/2083, which entered into force on 20 October 2025, replaced the old €150 per-consignment value exemption with a single annual mass-based de minimis: if you import less than 50 tonnes net mass of CBAM goods in a year, you are out of scope. The European Commission estimates this exempts around 90% of importers — mostly SMEs — while still capturing 99% of the embedded emissions, because the tonnage is concentrated in a small number of large importers.

The UK threshold is a value threshold. You must register where the value of CBAM goods you import reaches or exceeds £50,000. It can be triggered two ways: a forward-looking test, if you expect to import £50,000 or more of CBAM goods in the next 30 days, or a backward-looking test, if your imports have reached £50,000 over the preceding 12 months.

The practical consequence: a shipment can put you in scope in one jurisdiction and not the other. Dense, low-value goods hit the EU mass threshold first. High-value, low-tonnage goods hit the UK value threshold first. You cannot assume that being out of scope in one means you are out of scope in the other.

Scope is close, but not the same

Both schemes cover aluminium, cement, fertilisers, hydrogen, and iron and steel. Two differences matter:

• Electricity is in scope for the EU and not for the UK. If you import cross-border electricity into the EU, that is a CBAM obligation with no UK equivalent.
• Glass and ceramics are not in UK scope from 2027, despite having been considered during consultation.

EU scope is also set to widen. Chemicals and polymers are expected to be added as the definitive regime matures, so a product that is out of scope today may not stay that way.

Who actually carries the obligation

Under the EU scheme, only an Authorised CBAM Declarant may import covered goods. That is a status you apply for with your national competent authority, and without it your goods do not clear customs. Importers who submitted an application by 31 March 2026 were permitted to keep importing during 2026 while their application was being decided.

Under the UK scheme, the liability sits with the importer, registered with HMRC. There is no separate authorised-declarant status to obtain. HMRC laid the secondary legislation before Parliament on 13 July 2026 and has been publishing supporting guidance since.

The carbon price is calculated against different markets

EU CBAM certificates are priced against the EU Emissions Trading System. UK CBAM is priced against the UK ETS. The two markets do not track each other, so the same tonne of embedded carbon in the same product can carry a materially different cost depending on which border it crosses. Both schemes allow you to deduct a carbon price already paid in the country of production, but you have to evidence it.

What to do now, in order

1. Map your imports against both goods lists using CN codes for the EU and the UK commodity codes. Do this per entity, not per group — thresholds apply to the importing legal entity.
2. Measure against both thresholds separately. Tonnage for the EU, value for the UK. Track them on a rolling basis, not per shipment.
3. If you are in EU scope and not yet an Authorised CBAM Declarant, that is urgent — the definitive phase is live and unauthorised imports do not clear.
4. Collect supplier emissions data once, structured for both. This is the only genuine efficiency available. The embedded emissions figures your EU declaration needs are the same figures the UK scheme will ask for from 2027.
5. Diarise the UK dates now. Obligations begin 1 January 2027; registration opens by 1 January 2028.

The mistake that costs the most

Treating these as one project with one dataset, or treating them as two entirely separate projects with two data collections. Neither is right.

The regimes are separate — different thresholds, authorities, filings and prices. The data is shared. Companies that run two parallel supplier outreach programmes pay twice for the same information and burn credibility with suppliers who are asked the same questions in two formats. Companies that assume one filing covers both discover the gap at a border.

Frequently asked questions

Does EU CBAM registration cover me for UK CBAM?

No. They are separate legal regimes with separate registration. EU authorisation is granted by a national competent authority in a member state; UK registration is with HMRC. Holding one gives you no standing under the other.

I import into both. Do I need to collect emissions data twice?

No, and you should not. The embedded emissions data is fundamentally the same. Collect it once, structured per product and per installation, and it serves both filings. What differs is the reporting format and the carbon price applied, not the underlying measurement.

I am under 50 tonnes into the EU. Am I also exempt in the UK?

Not necessarily. The UK threshold is £50,000 by value, not by weight. A low-tonnage, high-value shipment can be under the EU mass threshold and over the UK value threshold at the same time. Check both separately.

What happens if I import EU CBAM goods without authorisation?

Since 1 January 2026, only Authorised CBAM Declarants may import covered goods into the EU. Without that status the goods do not clear customs, which makes this an operational blocker rather than a paperwork problem.

Is electricity covered by UK CBAM?

No. Electricity is in scope for EU CBAM but is excluded from the UK scheme. If you import cross-border electricity into the EU, that obligation has no UK counterpart.

Will EU CBAM scope expand?

Yes. Chemicals and polymers are expected to be brought into scope as the definitive regime matures. Products outside the list today should not be assumed permanently out of scope.

Getting help with both

EcoComply covers EU and UK CBAM together, so the same supplier emissions dataset serves both filings instead of being collected twice. That includes CN-code applicability mapping, Authorised Declarant registration, supplier outreach in seven languages, and quarterly and annual filings. See the CBAM reporting service, from €1,500 per year.

If you are not sure which regimes apply to your products at all — CBAM, CE marking, EPR or others — a €399 product compliance assessment maps every applicable obligation for your product and markets in 48 hours.