UK CBAM: importing steel, aluminium and cement from China
The UK Carbon Border Adjustment Mechanism (CBAM) applies to imports of iron and steel, aluminium, cement, fertiliser and hydrogen goods from 1 January 2027. An importer who expects £50,000 or more of CBAM goods within 30 days, or has imported that much in 12 months, must register, and records must be kept for 6 years.
UK CBAM starts on 1 January 2027 for steel, aluminium, cement, fertiliser and hydrogen imports. Which codes, the £50,000 threshold and records.
What CBAM is and when it starts
CBAM is a UK tax on the carbon emitted in making certain imported goods. HMRC guidance says it applies to CBAM goods imported from 1 January 2027, in five sectors: aluminium, cement, fertiliser, hydrogen, and iron and steel. It sits on top of customs duty and import VAT, and it applies to goods from China as from anywhere else outside the UK.
Many of the goods UK businesses buy from China fall in scope: steel sections, tubes, wire, fasteners of heading 7318, other steel articles of 7326, and a long list of aluminium products including extrusions, sheet, foil, tubes and other articles of aluminium.
| Sector | Commodity codes in scope | Main exceptions |
|---|---|---|
| Iron and steel | 2601 12; chapter 72; 7301 to 7311; 7318; 7326 | Listed ferro-alloys in 7202; 7204 ferrous waste and scrap |
| Aluminium | 7601; 7603 to 7614; 7616 | None listed |
| Cement | 2507 00 80; 2523 10, 21, 29, 30 and 90 | None listed |
| Fertiliser | 2808 00; 2814; 2834 21; 3102; 3105 | 3105 60 |
| Hydrogen | See the GOV.UK hydrogen sector list | See the list |
Who pays and when you must register
The liable person is the importer. Where customs duty is due, that is the person named on the import declaration, even if a freight forwarder or customs broker makes the declaration for you.
You must register if you expect to import CBAM goods worth £50,000 or more within the next 30 days. From 1 January 2027 you must also check, on the first day of each month, whether you have imported £50,000 or more of CBAM goods in the previous 12 months; if so, you may be liable from the date the threshold was met. Imports before 1 January 2027 do not count. Goods for private use, goods of UK origin, and goods under returned goods relief, temporary admission or certain special procedures do not count towards the threshold.
Records and emissions data
From 1 January 2027 importers of CBAM goods must keep, for 6 years, the 8-digit commodity code and description, the date each good passed the tax point, its value and weight, and evidence for any exemption. HMRC can charge a fixed £500 penalty for not keeping records. If you choose to report actual emissions rather than default values, you also need a verification report or summary from the supplier.
Chinese suppliers of steel and aluminium should start collecting installation-level emissions data now. The government's provisional list of qualifying carbon pricing schemes, updated 27 August 2026, includes the China National Emissions Trading System, which is relevant to claiming relief for a carbon price already paid. Ask your supplier whether their plant is covered and what evidence they can provide.
What to do now
List every commodity code you import and mark those in scope; our commodity code guide helps. Add up the value of in-scope imports over 12 months against the £50,000 threshold, ask suppliers for emissions data and verification plans, and build the likely CBAM cost into 2027 pricing alongside duty and VAT.
Product guides cover each category, for example our aluminium extrusions guide, steel beams guide and nitrogen fertilisers guide. If you need help getting data from factories, see our supplier problems service.
Frequently asked questions
When does UK CBAM start?
HMRC guidance says CBAM applies to CBAM goods imported from 1 January 2027.
Which goods from China are in scope of UK CBAM?
Goods in the aluminium, cement, fertiliser, hydrogen, and iron and steel sectors, listed by commodity code on GOV.UK, including many steel and aluminium products.
Do I need to register for CBAM?
If you expect to import £50,000 or more of CBAM goods within 30 days, or have imported that much in the previous 12 months from 1 January 2027.
Who is the importer for CBAM if my forwarder declares the goods?
Where duty is due, the person named on the import declaration is the importer, even if an agent makes the declaration.
Does China's carbon market count for CBAM relief?
The provisional GOV.UK list of qualifying carbon pricing schemes, updated 27 August 2026, includes the China National Emissions Trading System.