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With 3 months before UK-CBAM comes into force, the HMRC has published more detailed guidance as set out below to help you prepare. The official GOV. uk webpage that collects together a range of detailed pages in one place can be found here: https:// www. gov. uk / government / collections / carbon-borderadjustment-mechanism
The main 44-page policy summary is here: https:// www. gov. uk / government / publications / carbonborder-adjustment-mechanismcbam-policy-summary
The parameters that define which production processes are included must be established for both( a) actual verified emissions data and( b) default emissions values. They are called‘ systems boundaries’ and a 28- page explanatory document is here: https:// www. gov. uk / government / publications / carbon-borderadjustment-mechanism-force-oflaw-notice-and-reference-document
Several legal notices made under the Finance Act 2026 and subsequent regulations have the full force of law- and are also here: https:// www. gov. uk / government / publications / carbonborder-adjustment-mechanism-
force-of-law-notice-and-reference- document
Manufacturers and importers can claim tax relief on carbon prices that embodied emissions in such goods have been subject to in the country of export. Guidance on:
• checking the eligibility of your goods;
• what you need to calculate the carbon relief price and how to do it;
• obtaining a carbon pricing verification form from the exporter; is here: https:// www. gov. uk / government / collections / claimingcarbon-price-relief-for-carbonborder-adjustment-mechanismcbam
You are required to keep certain records in written form( inc. electronic) for 6 years. To find out what records you must keep, guidance is here: https:// www. gov. uk / guidance / keeping-records-for-carbon-borderadjustment-mechanism-cbam
There are several outstanding issues the HMRC has yet to resolve and announce that have serious implications for BMF members- notably:
• the secondary legislation that will
Policy – UK
confirm this tax policy in regulations;
• the default emissions values;
• the CBAM tax rate itself;
• the methodology for calculating and verifying the carbon price;
• the necessary currency exchange rates;
• how to register and submit tax returns online.
Conclusion Any new taxes, tariffs or quotas that cause extra specification, familiarisation & conformity costs to be put on BMF members( especially SMEs) is never welcome. But especially not at a time when the cost of doing business is already high for various reasons- not least, the ongoing USA & Iran Middle East Crisis. It ought to be in the best interests of exporting manufacturers in( among others) China, Vietnam & South Korea to help their British customers by providing you with what you need- especially the carbon emissions data.
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