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UK CBAM: Our Briefing

The UK plans to introduce a UK Carbon Border Adjustment Mechanism (UK CBAM) by 2027. Here is what we know and what businesses can do. Unlocking Insights: Navigating the UK Carbon Border Adjustment Mechanism (CBAM) for Customs Leaders

Executive Summary

Embark on a journey of discovery as we delve into the intricacies of the UK Carbon Border Adjustment Mechanism (CBAM). This article serves as your guide to understanding the nuances of CBAM implementation, implications for customs operations, and strategic recommendations for effective compliance. We succinctly summarize the key insights into the UK CBAM, providing clarity on its scope, mechanism of action, transitional measures, sectoral coverage, emission estimation and pricing, and integration with the UK ETS. Dive into our comprehensive analysis to unlock valuable insights and strategic foresight.

Table of Content

1. Executive Summary

2. Introduction

3. Background

4. Key Insights on UK CBAM

5. Conclusion and Recommendations

6. Links and Further Information


As the UK Government unveils its plans for the Carbon Border Adjustment Mechanism (CBAM), customs leaders and professionals face a pivotal moment in navigating the complexities of international trade. This article aims to provide a deep dive into the UK CBAM, offering strategic insights and actionable recommendations to ensure seamless compliance and strategic alignment with regulatory requirements.


The concept of CBAM, aimed at addressing carbon leakage and ensuring a level playing field for domestic and imported goods, has gained prominence on the global stage. With the UK set to implement its own CBAM by 2027, stakeholders must understand the rationale, objectives, and implications of this regulatory framework.

Key Insights on UK CBAM (as far as we know and subject to change)

Why CBAM in the UK, too?

  • The implementation of the Carbon Border Adjustment Mechanism (CBAM) by the United Kingdom government in 2027 is anticipated to revolutionize carbon pricing.

  • The CBAM aims to ensure that highly traded, carbon-intensive products imported into the UK face a comparable carbon price to domestically produced goods, mitigating the risk of "carbon leakage."

Scope of Application

  • Products included in the UK CBAM are those with high carbon intensity.

  • The UK CBAM covers sectors such as iron, steel, aluminium, fertiliser, hydrogen, ceramics, and cement.

  • In addition to sectors covered by the EU CBAM, the UK CBAM extends its purview to include glass and ceramics, excluding electricity.

  • Certain products like scrap aluminium, scrap glass, and scrap iron and steel are excluded from the UK CBAM due to their environmental benefits.

Overview of CBAM Operation

  • The CBAM operates by imposing a tax on imported high-emission commodities based on their embodied emissions.

  • Importers are responsible for compliance with CBAM regulations under the jurisdiction of the UK's HMRC / border force and environmental bodies.

  • It is yet to be seen if UK CBAM may not require the acquisition and submission of CBAM certificates like in the EU.

Mechanism of Action

  • The UK CBAM calculates embedded emissions using a methodology that considers both direct and indirect emissions.

  • Importers have the option to use default values or actual emissions data for emission calculation.

  • Carbon pricing under the UK CBAM is determined based on the quantity of carbon emitted during the manufacturing process.

Transitional Measures:

  • The UK CBAM is scheduled for implementation by 2027.

  • Transitional arrangements for the UK CBAM are yet to be fully disclosed.

  • Transitional measures may impact businesses' compliance strategies and supply chain management.

Emission Estimation and Pricing:

  • Emissions under the UK CBAM are estimated using a defined methodology.

  • Carbon pricing under the UK CBAM considers factors such as global standards and overseas carbon pricing disparities.

  • Emission estimation and pricing mechanisms influence businesses' compliance obligations and strategic decision-making.

Integration with UK ETS:

  • The UK CBAM is expected to integrate with the UK Emissions Trading Scheme (ETS).

  • Integration with the UK ETS may result in synergies and challenges for businesses.

  • Compliance requirements and strategic planning are impacted by the integration of the UK CBAM with the UK ETS.

Preparation for Businesses

  • Businesses can leverage insights from the EU CBAM to initiate preparatory measures for the UK CBAM, including internal control assignments and active engagement with government consultations.

  • Harmonizing data collection procedures between the EU and UK regimes is essential for businesses preparing for the UK CBAM's implementation.


As the consultation period for the UK CBAM progresses, it presents a distinct opportunity for customs leaders and professionals to influence the trajectory of international trade. Embracing proactive engagement, strategic planning, and collaboration will be essential to ensure smooth compliance and strategic alignment with regulatory mandates. Our team is poised to offer assistance in making a substantial contribution to the consultation process, drawing on our expertise and insights to navigate the intricacies of the UK CBAM.


  1. Engage Proactively: Stay actively involved in the consultation process for the UK CBAM, providing valuable input and feedback to shape its implementation.

  2. Strategize Effectively: Develop comprehensive strategies to ensure compliance with CBAM regulations while aligning with broader business objectives.

  3. Foster Collaboration: Foster collaboration among stakeholders within your organization and across the industry to address challenges and maximize opportunities presented by the UK CBAM.

  4. Leverage Expertise: Take advantage of expert guidance and insights, such as those offered by our team, to navigate the complexities of the UK CBAM effectively.

  5. Stay Informed: Stay abreast of developments and updates related to the UK CBAM and related regulatory frameworks to adapt your strategies accordingly and ensure compliance. Drop you email at to get started.

Links and Further Information

For additional resources, training programs, and expert consultations on the UK CBAM and its implications for customs operations, please visit our website or contact our team directly. We are delighted to offer our support and expertise to help you navigate the intricacies of the UK CBAM and make a meaningful contribution to the consultation process. If you are concerned by EU CBAM, please get in touch as we can help you.get it right. We can even submit the CBAM report for you.


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