Locate the records
Identify the systems and people holding import dates, values, product descriptions and commodity codes. Record the source of each data set.
UK CBAM / EXPLAINED
Know what is changing.
Organise what you need.
A plain-language starting point for UK import teams. Use current HMRC guidance and professional judgement for the rules that apply to your organisation.
THE HEADLINES
What is UK CBAM?
The UK Carbon Border Adjustment Mechanism is a tax on embodied emissions in specified carbon-intensive goods imported into the UK. It is intended to address differences in carbon prices between domestic production and imports.
1 January 2027UK CBAM takes effect
1 January 2028Registration opens, according to HMRC
These dates describe different events. An importer can become liable from 2027 even though registration opens in 2028. Check the applicable timing rules rather than treating registration opening as the start of your preparation work.
Which goods and importers need attention?
Specified goods in aluminium, cement, fertiliser, hydrogen, and iron and steel are covered initially. Check the commodity code against the official list; a product or sector name alone does not settle scope.
HMRC’s registration timing guidance uses £50,000 or more in relevant goods: expected imports over the next 30 days, or a review of imports over the previous 12 months. Goods imported before 1 January 2027 are excluded from that backward-looking check. Circumstances, exclusions and timing still require individual review.
Records can be needed even where registration is not required, including to support why the importer is not liable.
Start with a usable information set.
Identify the gaps
Establish what product and emissions information is available, where it came from and which questions need supplier follow-up.
Assign the decisions
Agree who reviews unclear classifications, assumptions and missing fields across customs, finance, compliance and advisers.
Keep a traceable record
Retain the sources and reasoning used in each review, with dates and unresolved questions visible.
CBAM Orbit is being developed to support this information and review workflow. Statutory liability calculation, formal return preparation and HMRC filing are outside the current product offer.
Explore the intended platform ↗Use the primary sources.
HMRC: Prepare for CBAM ↗Start date, registration opening and links to current guidance.HMRC: Work out the registration date ↗Forward and backward-looking threshold conditions.HMRC: Policy summary and commodity-code annex ↗Check the precise goods and current policy detail.HMRC: Keeping records ↗Evidence and record-keeping guidance.
Content reviewed 27 September 2026. Recheck immediately before publication and when guidance changes. This page is general information, not legal or tax advice.
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