Does SECR cover goods bought from China?

Check whether your organisation must report

SECR covers UK quoted companies, large UK unquoted companies and large limited liability partnerships. Buying goods from China is not itself the eligibility test. Ask your accountant to confirm your status for the reporting year, including group arrangements and any applicable exemption.

Separate an independent supplier from your operations

The environmental reporting guidance distinguishes organisational operations from supply-chain impacts. For an independent factory outside your reporting boundary, manufacturing emissions associated with your purchases belong to other indirect emissions. Purchased-goods reporting is voluntary under SECR.

If you own or control the manufacturing operation, assess the boundary before treating it as an independent supplier. Quoted companies have global reporting obligations, whereas the mandatory energy disclosures for large unquoted companies and partnerships focus on UK energy use. Ask your reporting adviser to document how the factory is treated.

Prepare the mandatory disclosures separately

Quoted companies report global energy use and relevant emissions, with the UK proportion identified. Large unquoted companies and partnerships report UK energy use and associated emissions, including electricity, gas and transport. Required supporting disclosures include an intensity ratio, calculation methods, energy-efficiency actions and previous-year comparisons, except in the initial reporting year.

Do not assume every indirect emission is voluntary. Large unquoted companies and partnerships must include business travel in rental or employee-owned vehicles where they are responsible for purchasing the fuel. That specific duty does not make purchased-goods manufacturing emissions mandatory.

Make a useful factory data request

For voluntary purchased-goods reporting, agree the calculation boundary with your reporting adviser before requesting documents. Ask the factory for the production site, reporting period, materials, output, energy records and how shared factory consumption was allocated to your goods.

Keep measured data, estimates and missing information visibly separate. A factory-wide total needs an allocation method before it can support a product calculation. Put the agreed data deliverables into your product specification, alongside the product and material requirements. Cambridge China Bridge can use its own staff in China to coordinate requests with factories.

Keep CBAM and customer requests separate

Check with HMRC or your customs broker whether UK CBAM will apply to your imports and what supplier evidence will be needed. Our UK CBAM guide covers scope and preparation. A voluntary purchased-goods calculation should not be assumed to satisfy that separate process.

When a customer asks for emissions data, ask which products, reporting period and calculation boundary they need. Label the response as a product estimate, supplier inventory or organisational disclosure, as appropriate. Keep the underlying records so your reporting adviser can check what the figures actually represent.