In brief
UK CBAM is scheduled to commence on 1 January 2027.
The initial covered sectors are aluminium, cement, fertiliser, hydrogen, and iron and steel.
CBAM applies to specified goods identified through commodity-code scope, not automatically to every product within those broad sectors.
Who needs to prepare
Preparation may involve UK importers, groups using customs intermediaries, finance and tax teams, procurement functions, customs and trade teams, overseas manufacturers and suppliers providing embedded-emissions information.
Data model required
| Data field | Purpose |
|---|---|
| import date | period attribution |
| importer | responsible entity |
| supplier | commercial source |
| producer or installation | emissions source |
| country of origin | origin evidence |
| commodity code | scope screening |
| goods description | classification support |
| imported weight | quantity basis |
| embedded direct emissions | calculation input |
| applicable indirect emissions where required | calculation input |
| methodology | calculation evidence |
| verification or supporting evidence | audit trail |
| overseas carbon price | relief assessment |
| relief evidence | tax calculation support |
| customs declaration reference | transaction matching |
| calculation version | control history |
| approval status | governance |
Internal responsibilities
- customs team: product and import data
- procurement: supplier-data requests
- sustainability or technical team: emissions methodology
- tax and finance: liability and return process
- legal or compliance: controls and evidence
- management: approval and accountability
Actions to consider
- Screen imported goods by commodity code.
- Identify covered suppliers and production installations.
- Map customs and purchase data.
- Issue embedded-emissions data requests.
- Define calculation and evidence rules.
- Establish overseas carbon-price evidence requirements.
- Create a central CBAM transaction register.
- Assign tax-return and approval ownership.
- Test missing-data escalation.
- Complete a dry-run calculation before January 2027.
How SustainZone supports preparation
- commodity-code screening support
- CBAM applicability assessment
- supplier-data templates
- embedded-emissions data models
- transaction registers
- evidence-gap review
- reporting dashboards
- responsibility mapping
- pre-implementation dry runs
Customs classification and tax positions may require advice from appropriately qualified customs or tax professionals.
Request a UK CBAM readiness assessment