UK CBAM · GOODS IN SCOPE
Five sectors. One question that matters: your commodity code.
UK CBAM applies to goods in five sectors, but sector is not the test. The return HMRC requires is built around the 8-digit commodity code on each import. If your code sits inside the scope list, the goods are CBAM goods, whatever the sector heading says.
SECTORS IN SCOPE
In scope.
FA 2026 s.143(3), Sch 16In scope.
FA 2026 s.143(3), Sch 16In scope.
FA 2026 s.143(3), Sch 16In scope.
FA 2026 s.143(3), Sch 16In scope.
FA 2026 s.143(3), Sch 16Not in scope. UK CBAM does not cover imported electricity.
FA 2026 s.143(3), Sch 16The electricity exclusion is the first divergence from the EU measure, which does cover it. If you import electricity and nothing else, UK CBAM does not apply to you.
THE CODE IS THE TEST
The return content is prescribed, and the commodity code is the first field on it. Weight, place of origin, any overseas carbon price relief and a declaration of truth complete it.
SI 2026/802 reg 10The prescribed return content does not include an emissions figure. The charge is calculated from tonnes of CO2e embodied in the goods, but that calculation sits outside the list of things the return itself must contain.
SI 2026/802 reg 10; FA 2026 s.149(1)Getting the code wrong is not a rounding error. It decides whether a consignment is in scope at all, and it is the field HMRC reads first.SI 2026/802 reg 10
WHERE THE LIABILITY SITS
The UK importer. Not the overseas producer, not the freight forwarder.
FA 2026 s.146(1),(2)£50,000 of CBAM goods, on either of two statutory triggers.
Both triggers in fullThe sectoral domestic price, multiplied by the tonnes of CO2e embodied in the goods.
FA 2026 s.149(1)THE EU LIST IS NOT THE UK LIST
The two measures are close but not identical, and treating one list as the other is how consignments get mis-scoped. The EU covers imported electricity; the UK does not. The EU measure counts indirect emissions in its definition, but for Annex II goods — iron and steel, aluminium and chemicals — it takes direct emissions only. Those are precisely the sectors UK CBAM covers, so "the EU counts indirect" is the wrong summary for exactly the goods most UK importers move.
Reg (EU) 2023/956 Art. 3(22), Art. 7(1)FROM CODE TO RETURN
Carbon Mandate takes the commodity code, the weight and the origin for every consignment and prepares the return content HMRC prescribes, with each figure traced to its source. HMRC has not published a data schema for UK CBAM. When it does, the same engine gains an output adapter — the preparation work does not restart.
SI 2026/802 reg 10You remain the person who registers, files and pays. We prepare what you file.
FA 2026 s.146(1),(2)UK CBAM · JANUARY 2027
Find out which of your codes are in scope.
Bring a line of your import data. We will show you what the return needs against it.