The UK Carbon Border Adjustment Mechanism (CBAM) applies to goods imported on or after 1 January 2027. It puts a carbon price on the emissions embodied in imports from five sectors: aluminium, cement, fertiliser, hydrogen, and iron and steel.
Does it apply to you? There are two tests, and meeting either one means you must register with HMRC. On the first day of any month, look back: have you imported CBAM goods worth £50,000 or more in the last 12 months? And on any day, look ahead: do you expect to import £50,000 or more in the next 30 days? In 2027 the look-back only goes back to 1 January 2027, and you have until 31 January 2028 to register.
Key dates.
- 1 January 2027: CBAM starts.
- 31 January 2028: registration deadline for the first year.
- 31 May 2028: the first return and payment, for the period ending 31 December 2027.
- From 2028, returns are quarterly: 31 July 2028, 29 September 2028, 30 November 2028 and 28 February 2029 for 2028's four quarters.
Your checklist before 1 January 2027.
- List what you import and check each commodity code against the CBAM goods list.
- Add up the value of those goods (the value used for customs duty) month by month, for both tests: £50,000 or more in the last 12 months, or expected in the next 30 days.
- Ask each overseas supplier whether they can give you the emissions embodied in their goods, with a verification report.
- Where they can't, plan to use HMRC's default values.
- Decide who in the business will register, keep the records and file the returns.
- Set up records you can keep for six years after each accounting period.
- Put the deadlines above in your calendar now.
Scopterra's compliance calendar tracks these dates, and our CBAM Readiness Check goes through your imports, codes and supplier data with you. This guide is a summary, not legal or tax advice: check HMRC's guidance for your own goods.
Sources
- legislation.gov.uk, Finance Act 2026, section 158(1) (opens in a new tab)
- legislation.gov.uk, Finance Act 2026, Schedule 17 (paragraph 2(2) for the two registration tests, and paragraphs 6 and 7) (opens in a new tab)
- legislation.gov.uk, The Carbon Border Adjustment Mechanism (Transitory Provision) Regulations 2026, regulation 2 (opens in a new tab), Made 14 July 2026
- HMRC, Carbon Border Adjustment Mechanism (CBAM): Policy summary (opens in a new tab), Updated 2 November 2026