- UK CBAM to start on 1 January 2027, first levy for 2027 imports due by 31 May 2028
- Sectoral scope narrower than in the EU: no inclusion of electricity
- Pricing logic: sector-specific UK CBAM rates, adjusted quarterly
- Thresholds: UK £50,000 goods value per year
- Crediting of third-country CO₂ prices more restrictive in the UK (only explicit levies)
- Verification: UKAS/IAF-accredited auditors
The United Kingdom will introduce its own tax-based CBAM from 1 January 2027. The focus will be on aluminium, cement, fertilisers, hydrogen, iron and steel. Electricity imports will be excluded for the time being – unlike in the EU CBAM, which will also cover electricity from 2026. While the EU is establishing a uniform certificate system with weekly price references on the EU ETS, the UK is relying on sector-specific levy rates that are adjusted quarterly and derived from the UK ETS and Carbon Price Support.
Thresholds and reporting requirements
In the UK, the obligation applies to goods with a value of £50,000 per year or more. The minimum threshold is therefore based on financial criteria, while the EU is planning a de minimis limit of 50 tonnes of CO₂ emissions per year. For 2027, an initial annual report is scheduled for 31 May 2028. From 2028 onwards, the levy will be paid quarterly with a two-month deadline. In the EU, on the other hand, the annual deadline for payment is 31 August of the following year.
Crediting of foreign CO₂ prices
The UK only recognises explicit CO₂ levies (e.g. ETS or CO₂ tax in the country of origin). The EU provides for a broader crediting model: in addition to proof of actual payments, default carbon prices for third countries can also be used in future.
Verification and emissions data
Both systems require emissions data – either as actual values or default values. In the UK, IAF-accredited verifiers such as UKAS must verify actual emissions. The EU will make verification mandatory from 2026, but will facilitate the use of default values without external verification.
International dimension
The UK CBAM will add another independent standard from 2027. Together with systems in Turkey, India and China, as well as WTO proceedings against the EU, it is clear that companies with global supply chains must adapt to heterogeneous requirements.
Recommended action
With a view to the launch of the UK CBAM on 1 January 2027, companies should check at an early stage whether their imports exceed the value threshold of £50,000 per year. If so, registration with HMRC is mandatory. In addition, internal processes must be adapted so that the first annual declaration for 2027 can be submitted on time by 31 May 2028 and, from 2028 onwards, quarterly reports can be reliably submitted within two months. Companies should also ensure that emissions data is reliable and, if actual values are used, verified by an IAF-accredited body such as UKAS.
