UK CBAM: New HMRC Guidance Helps Importers Prepare for 2027

Businesses importing carbon-intensive goods into the UK are being encouraged to start preparing for the introduction of the UK Carbon Border Adjustment Mechanism (CBAM), following the publication of new guidance from HM Revenue & Customs (HMRC).

Due to come into effect on 1st January 2027, UK CBAM will introduce a carbon charge on certain imported goods to ensure they face a carbon cost comparable to similar products manufactured in the UK. The measure is designed to prevent “carbon leakage”, where production shifts to countries with lower environmental standards.

Which products will be affected?
The new rules will apply to specified products within the following sectors:
• Aluminium
• Cement
• Fertilisisers
• Hydrogen
• Iron and steel

Not all products within these sectors will be covered, so businesses should review the official commodity code list to determine whether their imports fall within scope. The rules will apply to qualifying imports into both Great Britain and Northern Ireland.

What’s included in the latest HMRC guidance?
The newly published guidance provides businesses with greater clarity on how CBAM will operate and what steps importers should be taking now.

Default emissions values published
Importers can use government-issued default emissions values to calculate the carbon content of imported goods where supplier-specific emissions data is unavailable. Alternatively, businesses may use verified emissions data provided by overseas manufacturers.

Indicative CBAM rates released
HMRC has also published illustrative CBAM rates, giving businesses an early indication of potential future costs. Final rates will vary by sector and will be reviewed quarterly, with the first official rates expected before the end of 2026.

Record-keeping requirements clarified
Businesses importing affected goods will need to maintain detailed records from 1st January 2027, even if they do not meet the threshold requiring CBAM registration. Required information will include details of imported goods, emissions calculations and supporting documentation.

Five steps businesses should take now
With implementation just over a year away, importers should begin preparing by:
1. Checking whether imported products are affected by reviewing commodity codes against the UK CBAM product list.
2. Assessing import values to understand whether the £50,000 registration threshold may be exceeded.
3. Engaging with suppliers to determine whether verified emissions data can be provided.
4. Reviewing internal systems and record-keeping processes to ensure relevant data can be captured and retained.
5. Planning for future registration and reporting obligations, including the first reporting periods.

HMRC has confirmed that CBAM registration will open on 1st January 2028. Businesses that meet the registration threshold during 2027 will need to register by 31st January 2028, with the first CBAM return and payment due by 31st May 2028.

Preparing for the changes
While some technical guidance remains in draft form, the latest publications provide businesses with a much clearer picture of how CBAM will work in practice. Early preparation will help importers identify potential exposure, engage with suppliers and ensure they can meet future compliance requirements.

Need support?
Our International Trade team can help businesses understand the implications of CBAM, review affected imports and prepare for the new reporting and record-keeping requirements. Get in touch to discuss how these changes may impact your organisation.

For further information join us at our Global Xchange event on 26th November 2026 at AMRC Samlesbury, more details on the following link – Business Events Lancashire | N&W Lancashire Chamber