UK CBAM 2027: importer checklist and £50,000 threshold

UK CBAM starts on 1 January 2027. Start with your customs declarations and purchase orders. Identify covered goods, test their combined import value against £50,000, then ask suppliers for emissions evidence. The threshold uses import value. The tax calculation uses embedded emissions.

Check your goods and threshold with the free EU and UK CBAM scope checker.

1. Which imported goods fall under UK CBAM?

Ask your customs broker for a spreadsheet with the commodity code, description, origin, import date, customs value and net weight for each line. Include expected deliveries for the next 30 days. Screen steel, aluminium, cement, fertilisers and hydrogen against HMRC’s covered codes. A finished product containing steel can have a different code from steel parts imported separately.

For example, HMRC lists certain steel screws and bolts under 73181595. An invoice saying only “fasteners” gives you too little information to assign that code. Ask for the specification and confirm classification with your broker. Check HMRC’s iron and steel list.

2. When do UK imports meet the £50,000 registration threshold?

• Look forward. From 1 January 2027, check whether you expect £50,000 or more of qualifying goods in the next 30 days. A confirmed order can trigger liability before delivery.
• Look back. On the first of each month, check the preceding 12 months of qualifying imports. Count imports from 1 January 2027 onward. Record the earliest date either test applies.

Suppose on 8 January you expect £32,000 of covered steel and £21,000 of covered aluminium within 30 days. Together they total £53,000. If both values qualify and no exclusion applies, the forward test is met on 8 January. Keep the purchase orders that support that date. See HMRC’s registration tests.

3. What should you ask the supplier for?

Send one request per product line: “Please identify the production installation, the goods and period covered, and the emissions intensity per tonne. If you have verified actual data, please send the verification report or product-specific verification summary.” Match the evidence to the shipment. Ask separately for supporting evidence if you intend to claim relief for a qualifying carbon price paid abroad. HMRC’s records checklist.

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4. What might a shipment cost?

Illustration for an importer already liable: 10 tonnes of steel fasteners correctly classified under 73181595. HMRC’s published default is 5.584 tonnes CO₂e per tonne of product. Using its illustrative steel rate of £9.69 per tonne CO₂e, and assuming no carbon price relief:

10 × 5.584 × £9.69 = £541.09. If acceptable verified data gave an intensity of 4.000 instead, the same illustration would give £387.60. The difference is £153.49 per shipment. For ten identical shipments it is about £1,535, a useful figure to compare with the cost of obtaining verification.

The 4.000 intensity is hypothetical. For an actual return, use the rate for the quarter of import and check relief eligibility. HMRC default for the goods · HMRC illustrative rates

5. Who owns the next step?

Ask purchasing to flag new orders, the broker to confirm codes and customs values, and finance to record the threshold date and budget the tax. For 2027 imports the first return and payment are due by 31 May 2028. Reporting periods are quarterly from January 2028. HMRC timetable.

EcoComply can coordinate supplier evidence and file UK returns as your agent. You remain liable. Get a free CBAM scoping assessment with your main goods, markets and approximate import value.

CBAM guide for importers · EU and UK CBAM compared

Also importing into the EU? Budget for EU CBAM certificates separately from UK tax.

Common questions

Do we need to wait until registration opens to keep records?

Keep relevant import records from your first covered imports in 2027. Registration opens on 1 January 2028. Anyone liable during 2027 must register by 31 January 2028.

Can we replace default emissions with actuals after filing?

HMRC says a return filed using default values cannot later be amended to substitute actual emissions. Decide which evidence to use before filing.