UK CBAM · From 1 January 2027
UK CBAM arrives 1 January 2027. The data requirement comes with it.
The UK Carbon Border Adjustment Mechanism applies from 1 January 2027 to imports of aluminium, cement, fertiliser, hydrogen, and iron and steel. A separate instrument from EU CBAM, a separate filing — the same emissions data discipline. Carbon Mandate prepares the embodied-emissions evidence the charge is computed on. HMRC has not published a data schema for the UK return.
EU CBAM vs UK CBAM
- Six sectors, including electricity
- Definitive regime applies from 1 January 2026
- Registers and files with the EU Registry
- Five sectors, electricity excluded
- Applies from 1 January 2027
- Registers and files with HMRC
The headline difference: electricity is in scope for EU CBAM but excluded from UK CBAM. Indirect emissions are delayed until 2029 at the earliest under the UK regime.
Who carries the obligation
UK CBAM obligations fall on the UK importer of the relevant goods. That is usually the person named on the customs declaration, or the person on whose behalf the goods are imported. Registration is triggered on the first day of a month where, during the preceding 12 months, the importer brought CBAM goods into the United Kingdom with an aggregate value of £50,000 or more in the course of a business. Registration is also triggered where an importer expects to import £50,000 or more of CBAM goods within the next 30 days.
Carbon Mandate prepares the embodied-emissions evidence. The UK importer registers and files with HMRC themselves.
The same underlying pipeline
UK CBAM is a new instrument, but the data problem is the one Carbon Mandate already solves: turning unstructured supplier emissions data into a structured, cited emissions record. SI 2026/802 prescribes what a UK return must contain; HMRC has not yet published a data schema for it. As it does, the same specialist preparation, the same preparer-not-filer posture, and the same audit-ready output carry across to the UK regime.
UK CBAM · JANUARY 2027
Get the UK CBAM rules as they land.
HMRC has not published the data requirements yet. When it does, we will send you what changed and what it means for your imports. UK CBAM only — nothing on the EU regime, and no more than that.