UK CBAM 2027 Explained for China Importers

What is UK CBAM, and why does it affect buying from China?

The UK Carbon Border Adjustment Mechanism places a carbon price on direct emissions embodied in specified imported goods. Its purpose is to make imported carbon-intensive products face a carbon price comparable to UK production and reduce carbon leakage.

It is not specific to China. For a China purchase, begin with the goods’ commodity codes, who is importing them and whether the registration tests apply.

Which goods are covered from 1 January 2027?

HMRC identifies covered goods by commodity code. A sector name or material description alone does not establish whether your order is covered.

Electricity imports are outside the UK scheme. At commencement, the tax covers direct embodied emissions; indirect emissions associated with electricity used in production are excluded.

Does the £50,000 threshold apply to my order or my business?

The registration threshold concerns the importer’s aggregate value of relevant CBAM goods, rather than each order or supplier separately.

Forward-looking test: from 1 January 2027, check on any day whether you expect to import £50,000 or more of relevant CBAM goods passing the tax point within the next 30 days.

Backward-looking test: on the first day of each month, check whether relevant CBAM goods imported and passing the tax point in the preceding 12 months total £50,000 or more. Do not include imports before 1 January 2027.

Check applicable exclusions before adding values. Small businesses must apply these tests too; being a small business is not itself an exemption.

Who pays: the UK buyer, Chinese supplier or customs agent?

The liable person is the importer. HMRC’s guidance covers individuals and organisations established inside or outside the UK.

Using a freight forwarder or customs broker to declare goods on your behalf does not transfer your importer responsibility to them. Where customs duties are payable, HMRC identifies the importer by the individual or organisation named on the import declaration. Where no customs duties are payable, it is the individual or organisation importing the goods, including where someone acts on their behalf.

Private individuals importing for non-commercial purposes are not liable. Individuals importing in the course of a business must assess the relevant tests.

What should I ask my Chinese supplier to provide?

To report actual emissions, obtain data monitored under UK CBAM requirements and verified by an eligible independent accredited verifier. You must retain the full verification report or the verification summary for the imported good.

Ask which production installation and goods the data covers, its calendar-year monitoring period, and the relevant verified emissions intensity. A general statement that a factory is environmentally friendly does not supply the required verification evidence.

If the producer does not monitor emissions in line with UK requirements, HMRC says the importer will need to use its default values.

For possible Carbon Price Relief, ask whether the goods’ embodied emissions have been subject to a qualifying carbon pricing scheme. Obtain the carbon pricing verification form through the producer or supply chain and check that an independent verifier meeting HMRC’s standards has completed it.

Also obtain the required publicly available pricing information, including applicable compensation. A supplier saying it has paid a carbon charge does not automatically establish entitlement to relief.

When do registration, returns and payment happen?

The tax starts before the registration service opens. Keep relevant import and emissions evidence during the first year.

How much will it cost, and is it the same as EU CBAM?

UK rates depend on the sector and import quarter. HMRC says applicable rates will be published by the beginning of each quarter from 1 January 2027. Do not treat illustrative rates as a confirmed charge for your shipment.

Broadly, multiply the relevant embodied emissions by the applicable UK rate, then subtract any eligible Carbon Price Relief.

The schemes have different scopes. The government’s consultation response identifies electricity imports as an example of a difference between the UK and EU schemes. This guide does not apply EU procedures to UK imports.

What should I do before placing a China order?

Confirm the commodity code, identify the importer, monitor relevant import values and agree how the producer will supply emissions and carbon-pricing evidence.

For the narrower purchasing checks, read UK CBAM when importing steel, aluminium and cement from China.

Primary legislation is in the Finance Act 2026. HMRC’s policy summary says details may change. Check the latest legislation, notices and guidance on GOV.UK before relying on a deadline or calculation.