UK CBAM: new guidance for imported steel, cement and aluminium before 2027

1. Identify the importer and the product before estimating a charge

CBAM covers selected commodity codes in aluminium, cement, fertilisers, hydrogen, and iron and steel. It does not make every construction purchase subject to the same additional tax. The relevant questions are whether the imported item is in scope and whether your business is classed as the importer. Buying from a UK merchant and importing directly are different situations.

HMRC’s registration collection sets out the £50,000 threshold and the steps for assessing liability, including exclusions and the date from which registration is required. Check the linked rules for the actual import pattern rather than testing only one invoice against the threshold. This article concerns the United Kingdom, including Northern Ireland; it is not a guide to the separate EU CBAM.

HMRC — CBAM policy summary

HMRC — Check whether you will need to register for CBAM

2. Start a record for each relevant import in 2027

HMRC requires records for CBAM goods imported from 1 January 2027. Record the commodity code, description, import date or tax point, value, net weight and relevant exemption information. Keep the documentation capable of supporting a return where required. The retention period is six years from the later of record creation or the end of the accounting period concerned.

For practical project control, connect the import reference to the supplier order and the material allocated to each job. A purchase ledger that records only “metal materials” and the invoice total is difficult to reconcile later. Keep the original unit of measure and the conversion you use; kilograms, tonnes and square metres describe different things.

HMRC — Keeping records for CBAM

3. Ask for emissions evidence, not a marketing label

The new guidance allows verified actual emissions intensity or the relevant official default value. A supplier statement that a product is environmentally friendly is not the same as the evidence required for verified actual data. Ask who produced the emissions report, which installation and products it covers, the period involved and the verification supporting it.

The guidance describes production-year and import-date approaches to selecting actual data. For the import-date approach in 2027, the most recent verified report is sought for 2027, or 2026 if the newer report is unavailable. Follow the actual HMRC rules for your choice. Store the report with the product reference so that a document for one steel grade is not silently reused for another product.

HMRC — Getting the emissions intensity for CBAM goods

4. Keep default values and rates distinct

A default value describes emissions intensity, expressed in tonnes of carbon dioxide equivalent per tonne of product. A CBAM rate is the carbon price applied to the relevant embodied emissions. They are different inputs. HMRC has published sector-specific default-value pages; select the one matching the goods rather than applying an average from another sector.

Rates vary by sector and quarter. The 16 October illustrative-rate document expressly says its preliminary figures do not establish a tax liability. Do not put those examples into a customer quotation as a confirmed final tax rate. Use them only for clearly identified planning scenarios, and replace assumptions with the published applicable figures when known.

HMRC — CBAM default values

HMRC — CBAM rates

HMRC — Illustrative CBAM rates and worked example

5. Turn uncertainty into a traceable purchasing decision

Consider a fictional steel fabricator preparing a 2027 installation quote. Its buyer first confirms whether the supplier or fabricator will import the sections. If the fabricator is the importer, it records the product code, intended quantity, expected import period and emissions-data route. The estimator can then identify what remains unknown without claiming an invented carbon cost per metre.

Ask the supplier whether the proposed price includes any costs it expects to incur and how long that offer remains valid. Keep the supplier’s commercial terms separate from your own statutory liability. A quotation should explain relevant assumptions and its validity rather than promising an unverified exemption or automatically passing a guessed tax amount to the customer.

6. Review the file before the delivery and before the return

Use a small exception list: missing product code, missing net mass, unclear importer, unavailable verified report or changed import date. Assign an owner and a next check to each exception. A change of supplier or product can change several inputs at once, so revisit the calculation rather than changing only the purchase price.

Vocalys can help you dictate material lines, units and outstanding purchasing questions while preparing your quotation. Review those notes against the customs and supplier records. A voice-generated document does not establish the commodity classification or discharge the importer’s tax obligations.

Reusable job sheet

• Check the commodity code
• Identify the importer
• Assess registration rules and threshold
• Record net mass and import date
• Choose the documented emissions-data route
• Distinguish illustrative from applicable rates
• Review price assumptions before sharing

Product and code: […]
Importer: […]
Import date / net mass / value: […]
Actual verified data or official default: […]
Rate status and quarter: […]
Supplier price validity: […]
Unresolved item / owner / date: […]

To reduce time spent assembling quotations and invoices, discover Vocalys at vocalys.pro. Keep tax classification and the final figures under professional review.