CBAM is a carbon charge on goods imported into the UK. It starts on 1 January 2027, covers aluminium, cement, fertiliser, hydrogen, and iron and steel, and the importer pays it.
Who pays. The importer: the business in whose name, or on whose behalf, the customs declaration is made. That may differ from the business that placed the order, so it is the first thing to confirm.
What is covered. Scope is set by commodity code. The list goes beyond raw metal and includes tubes and pipes, steel and aluminium structures, and screws, bolts and nuts.
When you must register. Once your in-scope imports reach £50,000 in value. The test counts imports from 1 January 2027, looking back over 12 months and ahead over the next 30 days.
Goods imported in January 2027 are paid for in May 2028, so the cost needs to be in your prices long before the bill arrives. Dates from HMRC's CBAM policy summary and record-keeping guidance, checked 8 October 2026.
CBAM starts. Record keeping begins with your first in-scope import.
The first accounting period runs for the full calendar year.
Registration deadline for importers who passed the threshold in 2027.
First return and payment are due. Returns are quarterly from 2028.
The work follows the importer's path in four stages: 1 Find out and training, 2 Get ready, 3 Run it, 4 Briefings and training. Most businesses start with the scope check.
Available for staff who need more depth. Ask for details.
I screen 12 months of your import data against the in-scope commodity codes, confirm who the importer is on each flow and apply both £50,000 tests. A short report says whether you are in scope, the likely registration date and the imports that drive it.
A figure for the liability by product and supplier, with a cost per tonne that sales and purchasing can use in quotes. It shows the cash due on 31 May 2028 and each quarter after.
A check that the cost sits with the right party: who is named as importer, what the delivery terms say and whether CBAM is in your prices. You get a list of contract points for your solicitor. This is commercial guidance and does not replace legal advice.
A written procedure, a record template and a compliance calendar, in place before 1 January 2027. Importers below the threshold get a lighter version that shows why they are not liable.
Supplier by supplier: whether to use the government default value or ask for actual emissions data, and whether the evidence you receive can be used on a return. I do not prepare or verify the supplier's data.
A lower bill where a carbon price has already been paid in the country of origin, such as the EU, with the evidence file assembled.
Preparation for registration and for the first return, which covers all of 2027. I prepare each return and check it against your records. Quarterly returns follow from 2028.
A monthly arrangement between returns: the threshold check, rate updates, a refreshed forecast and a named contact for questions.
60 to 90 minutes for directors and finance: what CBAM is, whether you are caught and the likely cost.
Half a day for finance, purchasing and logistics, working through your own import data.
I am an Ambassador for IACBAM and an accredited CBAM trainer. Before consultancy I spent 30 years in the supply chain, so I know how imported goods are bought, priced and sold on. CBAM work is an Auditel service, delivered by me.
What is still to come from government. Default emissions values and the first CBAM rates have yet to be published, and an illustrative rate is due in autumn 2026. Until the figures arrive, the cost forecast runs on stated assumptions and is updated as they are published.
Book a 20-minute call and tell me what you import and where it comes from. I will explain how the scope check works and what data it needs.
Book a scope check →