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UK CBAM vs EU CBAM: What importers and businesses need to know

Arne Mielken
Managing Director, Customs Manager Ltd., United Kingdom of Great Britain and Northern Ireland
Published 09 Sep 2025

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The UK is introducing its own Carbon Border Adjustment Mechanism (CBAM), closely modelled on the EU system but with important differences in scope, calculation and compliance. This recording is essential viewing for customs and trade compliance professionals handling imports of carbon-intensive goods into the UK or EU.

Topics covered:

  • The current state of UK CBAM draft legislation and its 2027 entry into force, compared with the EU CBAM
  • Product and sector scope (aluminium, cement, fertilisers, hydrogen, iron and steel; electricity excluded; glass considered but not included for now), and CN/commodity codes
  • Emission calculation methods: actual emission data versus UK default values, and the treatment of PFC gases for aluminium
  • The UK CBAM liability formula, including the CBAM rate and Carbon Price Relief (CPR) for carbon costs already paid abroad
  • Why the UK treats CBAM as a tax due at importation, registration thresholds (£50,000 customs value), and liable-person obligations (registration with HMRC, record-keeping, returns via the government gateway)
  • The CBAM "tax point" concept and how special customs procedures (inward processing, storage, authorised use) affect it
  • Northern Ireland-specific provisions
  • Reporting frequency under UK CBAM (quarterly from 2028, after an initial longer transition period) versus the EU's approach
  • HMRC's compliance and penalties approach

For a broader overview of the topic, please watch the full recording. The slides are available in the Resources section.

Please note that this summary was generated using AI, based on the recording and available slides.

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