Which CBAM regime applies to me?

If you import CBAM-covered goods into the EU (including Ireland, Germany, Netherlands, Belgium, or any other member state), the EU CBAM applies. If you import CBAM-covered goods into the UK, the UK CBAM applies. If you import into both, you need to manage parallel compliance programmes. MyCustomsInfo® supports both from a single platform.

We import steel but our supplier is in Turkey. Does CBAM apply?

Yes. CBAM applies based on the country of origin of the goods, not the country of the supplier. Turkish steel imported into the EU is subject to EU CBAM. Turkey does not currently have a carbon pricing mechanism that qualifies for a CBAM offset.

Our supplier cannot provide embedded carbon data. What do we do?

Where actual data is unavailable, default values apply. Under the EU definitive regime, CIR 2025/2621 sets country-specific and product-specific defaults with a progressive markup (10% in 2026, 20% in 2027, 30% from 2028). UK CBAM default values have not yet been published. Using defaults is compliant but increasingly expensive. Pursuing actual supplier data is both a compliance improvement and a cost reduction.

How does the UK CBAM differ from the EU CBAM?

The UK CBAM is a direct tax (Finance Act 2025), not a certificate system. It is administered by HMRC, priced against UK ETS (not EU ETS), and has no transitional period. Financial obligations start from day one on 1 January 2027.

What are the penalties for non-compliance?

EU CBAM penalties are aligned with the EU ETS penalty regime, calculated per tonne of CO₂ equivalent. Non-compliance also triggers increased customs risk profiling. UK CBAM penalties will be defined in secondary legislation. Both regimes treat non-compliance as a customs compliance risk indicator.

Can MyCustomsInfo® handle both regimes simultaneously?

Yes. MyCustomsInfo® maps your import flows across both jurisdictions, identifies which goods fall under each regime, tracks supplier emissions data against both sets of default values, and produces declaration-ready outputs for both EU and UK authorities.

Do I need to register as a CBAM declarant?

Under the EU regime, importers must register as authorised CBAM declarants with their national competent authority before purchasing certificates. Under the UK regime, businesses importing CBAM-covered goods above £50,000 annually must register with HMRC via Government Gateway by 31 January following the first liability year.

EU CBAM definitive regime live since 1 Jan 2026 · UK CBAM starts 1 Jan 2027 with no transitional period

EU & UK CBAM Compliance Audit Scope

Two CBAM regimes. One audit platform.
Know which applies and what it costs.

The EU CBAM definitive regime is in force. The UK CBAM starts January 2027 with no transitional period. If you import CBAM-covered goods into either jurisdiction, your obligations are live or imminent. MyCustomsInfo® maps both regimes, identifies your exposure, and produces declaration-ready outputs — from a single platform.

Book a CBAM compliance review

£2.5MCBAM exposure identified for a FTSE 250 metals importer across EU and UK regimes

6Covered sectors audited across both jurisdictions — steel, aluminium, cement, fertilisers, hydrogen, ceramics

2Parallel regimes mapped — EU certificate system and UK direct tax — with one data collection process

The Problem

Two carbon border regimes, two compliance frameworks, one supply chain

The EU and UK have implemented separate CBAM regimes with different legal bases, pricing mechanisms, reporting timelines, and enforcement bodies. Importers trading into both jurisdictions face parallel compliance obligations that share a common data requirement — embedded emissions — but diverge on everything else.

EU CBAM

Certificate system under Regulation 2023/956. Quarterly reporting since Oct 2023. Certificate surrender from Sep 2027. Default values via CIR 2025/2621 with rising markup (10% → 20% → 30%).

UK CBAM

Direct tax under Finance Act 2025. No transitional period. Starts 1 Jan 2027. HMRC administered. Priced against UK ETS. £50,000 annual import threshold. Default values not yet published.

Shared challenge

Both regimes require embedded emissions data from overseas suppliers. Where supplier data is unavailable, increasingly expensive default values apply. The compliance cost of inaction rises every year.

Covered sectors

Sector	EU CBAM	UK CBAM	Key consideration
Iron & steel	✓	✓	Largest volume sector. Multiple CN codes across primary, semi-finished, and finished goods.
Aluminium	✓	✓	Includes unwrought aluminium and aluminium products. High carbon intensity from smelting.
Cement	✓	✓	Process emissions dominant. Clinker ratio is the key data point.
Fertilisers	✓	✓	Nitrogen-based fertilisers covered. Ammonia is a precursor good.
Hydrogen	✓	✓	Newly covered. Production method determines emissions intensity.
Electricity	✓	✗	EU only. Relevant for electricity imports from non-EU countries.
Ceramics & glass	✓	✓	Added under definitive regime expansion. Both jurisdictions cover these.

Regime-Specific Audit Scope

Choose your jurisdiction

Each CBAM regime has its own registration, reporting, pricing, and payment framework. Select the jurisdiction that matches your import flows, or review both if you import into both the EU and UK.

Live now

EU CBAM — full audit scope

Definitive regime in force since 1 January 2026. Certificate price published at €75.36/tonne (Q1 2026). Default values set by CIR 2025/2621 with progressive markup. First certificate surrender September 2027.

Quarterly reporting obligations
Certificate budgeting and procurement
Supplier emissions data collection
Default value impact modelling

View EU CBAM audit scope

January 2027

UK CBAM — full audit scope

Direct tax under Finance Act 2025. No transitional period — financial obligations begin from day one on 1 January 2027. HMRC registration required. £50,000 annual import threshold. Default values not yet published.

HMRC registration guidance
Tax liability calculation
UK ETS price tracking
Threshold monitoring

View UK CBAM audit scope

Audit Scope

Three audit layers — applied to both regimes

Regardless of whether you import into the EU, the UK, or both, MyCustomsInfo® applies the same three-layer audit methodology to ensure complete coverage.

Import Classification Audit

We verify that your CBAM-covered goods are correctly classified at CN/HS code level and that in-scope imports are identified. Misclassification is the most common source of both over-reporting and under-reporting.

Emissions Data Audit

We assess the quality and completeness of your supplier emissions data against regime-specific requirements. Where actual data is unavailable, we model the financial impact of default values and identify supplier engagement priorities.

Declaration & Reporting Readiness

We verify that your reporting workflows, registration status, and internal processes are aligned with the declaration and payment timelines of each regime.

The MyCustomsInfo® Method

Six-source methodology for CBAM compliance

CBAM compliance requires data from multiple sources. MyCustomsInfo® cross-references all six to build a complete picture of your CBAM obligations across both regimes.

Import declarations

CHIEF/CDS records (UK) and customs declarations (EU) to identify in-scope goods by CN/HS code.

Supplier emissions data

Installation-level embedded emissions data collected via standardised questionnaires aligned with both EU and UK requirements.

Default value registers

CIR 2025/2621 (EU) country-specific and product-specific defaults. UK defaults when published. Markup schedules tracked.

Carbon pricing data

EU ETS weekly average prices for certificate costing. UK ETS prices for UK CBAM liability calculation. Third-country carbon pricing for offset claims.

Registration records

EU authorised declarant status. UK HMRC Government Gateway registration. Competent authority correspondence.

Regime legislation tracker

Implementing regulations, delegated acts, secondary legislation, and guidance updates from both EU and UK authorities.

Data We Need From You

CBAM audit data inventory

To conduct a CBAM compliance audit, we need the following documents. Most clients provide these within five business days.

Document	Purpose	Typical source
12 months of import declarations	Identify CBAM-covered goods by CN/HS code, origin, and volume	Customs broker or freight forwarder
Supplier list with country of origin	Map installations to covered goods and identify data collection targets	Procurement / supply chain team
Existing supplier emissions data	Assess data quality and completeness against regime requirements	Suppliers or sustainability team
EU CBAM transitional reports (if filed)	Baseline current reporting against definitive requirements	Compliance or finance team
UK import values by commodity code	Determine whether UK CBAM £50,000 threshold is triggered	HMRC records or customs broker
Third-country carbon pricing evidence	Identify potential offsets against CBAM liability	Suppliers or carbon accounting team

Key Dates

Combined CBAM compliance timeline

Both regimes have distinct deadlines. Missing any of these creates enforcement risk. MyCustomsInfo® tracks all dates and alerts you before each obligation falls due.

October 2023EU

EU CBAM transitional period begins. Quarterly reports required.

31 December 2025EU

CIR 2025/2621 published. Definitive country-specific and product-specific default values.

1 January 2026EU

EU CBAM definitive regime in force. 10% default-value markup applies.

7 April 2026EU

First CBAM certificate price published: €75.36/tonne CO₂ (Q1 2026).

1 January 2027Both

UK CBAM takes effect (Finance Act 2025). No transitional period. EU CBAM default-value markup rises to 20%.

1 February 2027EU

CBAM certificate purchases open for EU declarants.

31 May 2027EU

First annual EU CBAM declaration due (covering 2026 imports).

30 September 2027EU

First EU CBAM certificate surrender deadline.

31 January 2028UK

UK CBAM HMRC registration deadline (via Government Gateway).

31 May 2028UK

First UK CBAM payment due (covering full 2027 calendar year).

1 January 2028EU

EU CBAM default-value markup rises to 30%.

Regime Comparison

EU CBAM vs UK CBAM — side by side

Dimension	EU CBAM	UK CBAM
Legal basis	Regulation 2023/956	Finance Act 2025
Mechanism	Certificate purchase and surrender	Direct tax
Administering body	National competent authorities	HMRC
Pricing reference	EU ETS weekly average	UK ETS
Start date	1 Jan 2026 (definitive)	1 Jan 2027 (no transition)
Threshold	No de minimis threshold	£50,000 annual import value
Default values	CIR 2025/2621 with rising markup	Not yet published
First payment	Sep 2027 (certificate surrender)	May 2028 (tax payment)
Electricity	Covered	Not covered
Registration	Authorised declarant with NCA	Government Gateway with HMRC

Compliance Boundary

What MyCustomsInfo® does — and does not do

What we do

Identify CBAM-covered goods across your import portfolio
Audit supplier emissions data quality and completeness
Model financial exposure under both EU and UK regimes
Produce declaration-ready data packages
Track all compliance deadlines and alert before each falls due
Map third-country carbon pricing offsets

What we do not do

We do not file CBAM declarations on your behalf
We do not purchase CBAM certificates
We do not register you as an authorised declarant
We do not provide carbon accounting or life cycle assessment services
We do not negotiate directly with customs authorities

We identify. Your compliance team or appointed declarant acts. This boundary is non-negotiable and ensures our audit outputs remain independent.

Deliverables

What you receive

CBAM coverage report

Complete mapping of which goods, suppliers, and trade flows fall under EU CBAM, UK CBAM, or both.

Financial exposure model

Projected CBAM costs under actual vs default emissions data, broken down by regime, sector, and supplier.

Supplier data gap analysis

Supplier-by-supplier assessment of emissions data availability, quality, and priority for engagement.

Declaration readiness assessment

Gap analysis of your current processes against declaration and reporting requirements for each regime.

Compliance calendar

All registration, reporting, payment, and surrender deadlines mapped with alert thresholds.

Offset opportunity register

Identification of third-country carbon pricing mechanisms that may reduce your CBAM liability.

Investment

CBAM audit pricing framework

£6,000£40,000

Scoped to your import volume, number of covered sectors, supplier count, and whether you trade into one or both jurisdictions. Dual-regime audits are priced as a single engagement, not two separate projects.

2–4%Industry benchmark — compliance audit cost as a percentage of identified CBAM exposure. Our clients typically fall within this range.

Next Step

Book a 30-minute CBAM compliance review

We will review your import portfolio, confirm which CBAM regime(s) apply, and outline the audit scope before any commitment. No sales pitch — just a compliance assessment.

Book a compliance review

Prefer to see a sample audit first? Request a sample under NDA

Questions

CBAM compliance questions

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Two CBAM regimes. One audit platform.Know which applies and what it costs.