Sector Expertise

CBAM Compliance for UK Importers

EU CBAM definitive phase is live. UK CBAM starts January 2027. We help importers of steel, aluminium, cement, fertilisers, chemicals, and hydrogen navigate dual CBAM regimes, embedded emissions calculations, and declaration obligations.

Advisory services only. RSustain does not provide statutory assurance or verification.

Book an Importer CBAM Review Call +44 7876 096 717
6
CBAM product categories
(steel, aluminium, cement, fertilisers, chemicals, hydrogen)
Jan 2026
EU CBAM definitive phase
live — certificates required
Jan 2027
UK CBAM commences
(Finance Act No.2 2025)
31 May 2027
First EU CBAM annual
declaration deadline
Regulatory Landscape

Every Regulation Affecting UK Importers of CBAM Goods

A comprehensive map of current and incoming obligations. Status as of October 2026.

Mandatory (Definitive Live)

EU CBAM Reg 2023/956

Carbon Border Adjustment Mechanism for imports into the EU. Transitional reporting ended December 2025. Definitive phase live from January 2026 — authorised declarants must purchase and surrender CBAM certificates matching the embedded emissions of imported goods. Covers steel, aluminium, cement, fertilisers, chemicals (including hydrogen).

6 product categories Certificates required
From Jan 2027

UK CBAM (Finance Act No.2 2025)

The UK’s own carbon border adjustment mechanism. Importers of CBAM-covered goods into the UK must register, report embedded emissions, and pay the UK CBAM charge. Operates independently from the EU scheme but covers similar product categories. First reporting period begins January 2027.

UK imports Charge payable
Mandatory

EU ETS (Linked to CBAM)

CBAM certificate prices are linked to the EU ETS allowance price. As free allocation to EU producers phases down (linear reduction 2026–2034, reaching 0% by 2034), CBAM charges rise proportionally. Understanding the EU ETS price trajectory is essential for forecasting import costs.

Price linkage Free allocation phase-down
Mandatory

SECR

Streamlined Energy and Carbon Reporting in directors' report. UK energy use (kWh), Scope 1/2 (tCO2e), intensity ratio, methodology. Applies to companies meeting 2 of 3 size thresholds (250+ employees, £36m+ turnover, £18m+ balance sheet). Import-heavy businesses often have significant Scope 3 upstream emissions.

Qualifying companies Annual reporting
From Jan 2027

UK SRS S1 & S2

Mandatory sustainability and climate disclosure for UK-listed companies. Scope 1-3, climate risk/opportunity analysis, transition plans, governance. CBAM-exposed importers must disclose carbon cost as a material financial risk under S2 climate scenarios.

UK-listed companies Scope 3 comply-or-explain
Quick Diagnostic

Is Your Business Exposed to CBAM?

1

Do you import steel, aluminium, cement, fertilisers, chemicals, or hydrogen into the EU or UK?

Yes → You are directly exposed to EU CBAM (live now) and/or UK CBAM (from January 2027). Both schemes require embedded emissions reporting and carbon cost payments.

2

Have you identified the CN codes (Combined Nomenclature) for your imported products?

Not yet → CN code classification is the first step to determining which imports fall within CBAM scope. Some products at the boundary of categories require expert classification.

3

Can your overseas suppliers provide actual installation-level emissions data?

No → Without actual data, default values apply — typically higher than actual emissions, inflating your CBAM costs. A structured supplier data request programme is essential.

4

Are you registered (or preparing to register) as an authorised CBAM declarant?

Not yet → Under EU CBAM, only authorised declarants may import CBAM goods from January 2026. UK CBAM will require similar registration from January 2027.

5

Have you modelled the financial impact of both EU and UK CBAM on your import costs?

No → Carbon costs will rise as free allocation phases down linearly to 0% by 2034. Cost modelling under multiple ETS price scenarios is critical for procurement strategy and margin protection.

Not Sure? Book a Free CBAM Scoping Call
The Challenge

Why Importers Can’t Afford to Wait

EU CBAM is already live. UK CBAM is months away. Importers face dual compliance regimes, rising carbon costs, and supplier data gaps that directly erode margins.

Embedded Emissions Calculation

CBAM requires product-level embedded emissions data covering direct (Scope 1) and, for some goods, indirect (Scope 2) emissions at the overseas installation. Calculating these correctly — distinguishing between specific and complex goods, applying correct system boundaries — is technically demanding and error-prone without specialist support.

Supplier Data Collection

Obtaining actual emissions data from overseas producers is the single biggest operational challenge. Suppliers in jurisdictions without carbon pricing have little incentive to respond. Without actual data, you fall back to default values — which are set conservatively and inflate your CBAM costs significantly.

Dual EU + UK CBAM Compliance

Importers trading into both the EU and the UK face two independent CBAM regimes with different timelines, different registration processes, and potentially different default values. Managing dual compliance without a unified data architecture wastes resources and creates inconsistency risk.

Certificate Cost Forecasting

CBAM certificate prices are linked to EU ETS allowance prices, which fluctuate. As free allocation phases down linearly to zero by 2034, your effective carbon cost per tonne of imported goods will rise substantially. Procurement and finance teams need reliable multi-scenario forecasts to protect margins and inform sourcing decisions.

Free Tool

CBAM Compass — Check Your Exposure in 5 Minutes

Enter your CN codes and import volumes. CBAM Compass identifies which products fall within EU and UK CBAM scope, estimates your embedded emissions exposure, and flags supplier data gaps — so you know exactly where you stand before your first declaration.

Launch CBAM Compass →

No login required. Results delivered instantly.

What We Deliver

Importer CBAM Services

End-to-end CBAM advisory from CN code classification to annual declaration support, designed specifically for UK importers facing dual EU and UK regimes.

CBAM Scope Assessment

We classify your import portfolio against CBAM-covered CN codes, quantify exposed volumes and values, identify boundary products requiring expert classification, and produce a clear exposure register covering both EU and UK CBAM obligations.

CN Codes · Product Classification · Exposure Register

Embedded Emissions Calculation

Product-level embedded emissions calculations using actual supplier data where available and compliant default values where not. Covering direct and indirect emissions, precursor materials, and system boundary definitions per EU Implementing Regulation 2023/1773.

Direct + Indirect · Precursors · Default Values

Supplier Data Request Templates

Ready-to-send, regulation-aligned data request templates for your overseas suppliers. Covering installation details, production processes, fuel inputs, emission factors, and verification status. Designed to maximise response rates and minimise back-and-forth cycles.

Supplier Engagement · Data Templates · Response Tracking

Cost Modelling (3 ETS Price Scenarios)

Financial impact modelling under three EU ETS price scenarios (conservative, central, high) projecting CBAM certificate costs through to 2034 as free allocation phases down. Helps procurement and finance teams understand margin impact, evaluate supplier switching, and build budgets.

3 Scenarios · Free Allocation Phase-Down · Margin Impact

Declarant Registration Support

Guidance through the authorised CBAM declarant registration process for the EU (via CBAM Registry) and preparation for the UK registration scheme. Ensuring your customs representatives, EORI numbers, and internal processes are aligned for compliant declarations.

EU Registry · UK Registration · Customs Alignment

Compliance Programme Design

Design and implementation of an ongoing CBAM compliance programme covering quarterly data collection cycles, annual declaration preparation, certificate purchasing strategy, supplier performance monitoring, and regulatory change tracking across both EU and UK schemes.

Ongoing Programme · Declaration Prep · Regulatory Monitoring
Key Dates

CBAM Regulatory Timeline

October 2023 – December 2025 (Ended)
EU CBAM Transitional Phase Ended
Quarterly reporting of embedded emissions was required but no certificates were purchased. This phase has concluded — the definitive phase is now in effect.
January 2026 (Live)
EU CBAM Definitive Phase Live
Authorised declarants must purchase CBAM certificates to cover embedded emissions of imported goods. Certificate prices linked to EU ETS allowance price. Only authorised declarants may import CBAM goods.
January 2027
UK CBAM Commences
The UK’s own CBAM begins under the Finance Act (No. 2) 2025. Importers must register, report embedded emissions, and pay the UK CBAM charge on covered goods imported into the UK.
31 May 2027
First EU CBAM Annual Declaration Due
Authorised declarants must submit their first annual CBAM declaration covering goods imported during the 2026 calendar year. Certificates must be surrendered to match declared embedded emissions.
2026 – 2034
Free Allocation Linear Phase-Down (0% by 2034)
EU ETS free allocation to domestic producers reduces linearly each year, reaching zero by 2034. As free allocation falls, the CBAM charge on imports rises proportionally — meaning import costs will increase year on year through to 2034.
Our Approach

Why Importers Choose RSustain

We bring 26+ years of environmental advisory experience, including deep expertise in carbon pricing mechanisms and international emissions accounting, to importer CBAM challenges. Our approach unifies EU and UK CBAM obligations into a single data architecture — one supplier data request, one emissions calculation, two declarations. We design for the dual-regime reality UK importers face, not one scheme at a time.

26+
Years advisory experience
Dual
EU + UK CBAM integrated
6
CBAM product categories covered

CBAM Compliance: Frequently Asked Questions

What products are covered by EU and UK CBAM?+
EU CBAM covers six product categories: iron and steel, aluminium, cement, fertilisers, chemicals (including hydrogen), and electricity. Coverage is defined by specific CN (Combined Nomenclature) codes listed in Annex I of Regulation 2023/956. UK CBAM covers similar categories under the Finance Act (No. 2) 2025, though the exact product scope may differ in detail. Both schemes cover not just raw materials but also certain processed and semi-finished goods within these categories.
What happens if I cannot get actual emissions data from my suppliers?+
Where actual installation-level emissions data is not available, default values must be used. Under EU CBAM, default values are set by the European Commission and are typically based on the average emission intensity of the worst-performing 10% of EU installations for each product type, or on country-specific data where available. These defaults are generally higher than actual emissions from efficient producers, meaning your CBAM costs will be inflated. A structured supplier engagement programme to obtain actual data is the most direct way to reduce your CBAM liability.
How is the CBAM certificate price determined?+
EU CBAM certificate prices are calculated weekly based on the average closing price of EU ETS allowances on the common auction platform. Each certificate covers one tonne of CO2 equivalent. As EU ETS free allocation to domestic producers phases down linearly from 2026 to 2034 (reaching 0%), the effective CBAM charge rises proportionally. Importers can deduct any carbon price already paid in the country of origin. The UK CBAM will use its own pricing mechanism, details of which are being finalised by HMRC.
Do I need to register as a CBAM declarant?+
Under EU CBAM, from the definitive phase (January 2026 onwards), only authorised CBAM declarants may import CBAM-covered goods into the EU. You must apply for authorisation through the CBAM Registry in the Member State where you are established. Customs authorities will not release CBAM goods without a valid declarant authorisation number. For UK CBAM (from January 2027), a similar registration requirement will apply. Importers must prepare for both registrations if they trade into both jurisdictions.
Can carbon prices paid in the country of origin be deducted?+
Yes. Under EU CBAM, if a carbon price has been effectively paid in the country where the goods were produced (for example, under a national emissions trading scheme or carbon tax), this amount can be deducted from the number of CBAM certificates that must be surrendered. The deduction must be supported by verified evidence of the carbon price paid. This is important for imports from countries with their own carbon pricing, such as the UK ETS for goods produced in the UK and exported to the EU.
What is the difference between EU CBAM and UK CBAM?+
EU CBAM and UK CBAM are independent schemes operated by different jurisdictions. Key differences: EU CBAM definitive phase is live from January 2026, while UK CBAM starts January 2027. EU CBAM uses a certificate system priced weekly against EU ETS; UK CBAM pricing details are being finalised. Product scope is similar but not identical. Registration, reporting formats, and declaration processes differ. Importers trading into both jurisdictions need to comply with both schemes independently. RSustain designs unified compliance programmes that satisfy both from a single data collection process.
Does RSustain provide CBAM verification or act as a declarant?+
No. RSustain provides advisory services only. We do not act as an authorised CBAM declarant on your behalf, nor do we provide accredited verification of emissions data. We help importers prepare for CBAM compliance by conducting scope assessments, calculating embedded emissions, designing supplier data collection programmes, modelling costs, supporting declarant registration, and building ongoing compliance systems. Verification of actual emissions data, where required, must be performed by an accredited verifier.

CBAM & Carbon Regulation Insights

Latest regulatory analysis relevant to UK importers.

Carbon Markets

CBAM Downstream Extension: What UK Manufacturers Must Prepare For

Sep 2026 Carbon Regulation

UK CBAM Secondary Legislation Published: Detailed Rules for Carbon Border Adjustment from January 2027

Sep 2026 Carbon Regulation

UK ETS Maritime Launch: Shipping Compliance Obligations from July 2026

Jul 2026
View All Insights →
RSustain Academy

Upskill Your Import & Procurement Team

EU CBAM Compliance

Master CBAM obligations, embedded emissions calculations, supplier data requirements, and declaration processes under the definitive phase.

View Course →

Carbon Accounting Fundamentals

Understand GHG Protocol scopes, emission factors, and carbon accounting principles essential for embedded emissions calculations and SECR reporting.

View Course →

UK Sustainability Reporting Standards

Prepare for UK SRS S1/S2 mandatory disclosure from January 2027, including climate risk scenarios and Scope 3 reporting for import-heavy businesses.

View Course →

Book a CBAM Briefing

Free 30-minute Importer CBAM Review. We’ll assess your import exposure, identify which CN codes are in scope, and outline a practical compliance roadmap for both EU and UK CBAM.

Book an Importer CBAM Review WhatsApp Us

No obligation. Typically responds within 24 hours.