The UK CBAM has no transitional period. Financial obligations start 1 January 2027.
The preparation window is closing. UK importers who ignore this until December 2026 will face a worse position than EU importers who had a two-year transition. MyCustomsInfo® brings hands-on EU CBAM experience since October 2023 directly to your UK compliance preparation.
Why the UK CBAM is fundamentally different from the EU version
The UK CBAM is not a copy of the EU regime. It is a direct tax, not a certificate system. Administered by HMRC, not a registry. Priced against UK ETS, not EU ETS. And critically, it has no transitional period.
| Feature | UK CBAM | EU CBAM |
|---|---|---|
| Mechanism | Direct tax (Finance Act 2025) | Certificate purchase and surrender |
| Administering body | HMRC | EU CBAM registry |
| Carbon price reference | UK ETS auction clearing prices | EU ETS auction clearing prices |
| Transitional period | None | 2 years (Oct 2023 – Dec 2025) |
| Start date | 1 January 2027 | 1 January 2026 (definitive) |
| Registration | HMRC via Government Gateway | EU CBAM registry |
| Indirect emissions | Included from day one | Phased approach |
| Electricity | Not covered | Covered |
| Ceramics and glass | Covered from day one | Expanded scope |
Who is liable under the UK CBAM?
UK CBAM liability is determined by import value, EORI/VAT registration, and a look-back test. If you meet the criteria, you are liable from the first day of the regime.
£50,000 import threshold
UK CBAM applies to importers whose total value of CBAM-covered goods exceeds £50,000 per year. Below this threshold, you are not liable.
EORI/VAT registration required
You must be registered for both EORI and VAT purposes. Unregistered importers of CBAM-covered goods will need to register before the regime starts.
The look-back test
HMRC will use a look-back test to determine whether the £50,000 threshold was met in the previous year. If you met the threshold in 2026, you are liable from 1 January 2027.
UK CBAM sector coverage
The UK CBAM covers similar core sectors to the EU regime, with notable differences: electricity is not covered, but ceramics and glass are included from day one. Indirect emissions coverage also applies from the start.
The registration and reporting obligations
The UK CBAM requires HMRC registration via Government Gateway. The first payment covers the full 2027 calendar year. Quarterly reporting begins from 2028.
Key steps
EU CBAM experience since October 2023 transfers directly to UK CBAM preparation
We have been operating under the EU CBAM since the transitional period began. The supplier data workflows, default value management, and carbon data gap analysis we perform for EU clients are the same challenges UK importers are about to face. One platform covers both.
Supplier data workflows
The biggest practical challenge in CBAM compliance is collecting embedded emissions data from suppliers who have never heard of CBAM. We provide structured data request templates, track response rates, and prioritise engagement based on volume and cost impact.
Default value management
UK CBAM default values have not yet been published. When they are, MyCustomsInfo® will apply them automatically, just as we already apply the EU CIR 2025/2621 defaults. We monitor HMRC secondary legislation and update the platform as guidance is issued.
Carbon data gap analysis
We audit your import declarations to identify which goods fall under UK CBAM scope, which suppliers need to be engaged, and where your data gaps are. This gives you a prioritised action plan before the regime starts.
Parallel EU and UK CBAM compliance
If you import into both the EU and the UK, you need to manage two parallel compliance programmes with distinct registration, reporting, and payment frameworks. MyCustomsInfo® supports both from a single platform with shared supplier data.
How UK CBAM interacts with EU CBAM
Some businesses face CBAM obligations in both directions. Understanding which regime applies to which trade flow is essential to avoiding duplication and gaps.
Importing into the UK
You face the UK CBAM. Embedded emissions on goods entering the UK are subject to UK ETS-linked charges, payable to HMRC.
Exporting from the UK into the EU
You face the EU CBAM. Goods produced in or re-exported from the UK into the EU are subject to EU CBAM certificate obligations on the EU importer.
Doing both
You need two parallel compliance programmes with distinct registration, reporting, pricing, and payment frameworks. MyCustomsInfo® manages both from a single platform.
Secondary legislation caveat
As of May 2026, the UK CBAM benchmark and default values for embedded emissions have not yet been published in secondary legislation. HMRC has confirmed that these will be issued before the January 2027 start date. MyCustomsInfo® monitors all HMRC guidance and secondary legislation as it is published and updates the platform accordingly. This is part of the service.
UK CBAM key dates
UK CBAM takes effect. Financial obligations begin. No transitional reporting period.
Deadline to register with HMRC via Government Gateway as a liable person.
First UK CBAM payment due, covering the full calendar year 2027.
Quarterly reporting and payment cycle begins for ongoing compliance.
The UK CBAM starts in less than eight months. Preparation starts now.
There is no transitional period. No practice run. The UK importer who has not identified their CBAM-covered goods, engaged their suppliers, and established their data infrastructure before January 2027 will face financial obligations they are not ready for.
+44 151 808 0103 • [email protected]
Also importing into the EU? The EU CBAM definitive regime is already in force.
Read the EU CBAM page