UK Publishes CBAM Rules for China Exporters Ahead of 2027
UK CBAM Policy Update
The UK government published an updated Carbon Border Adjustment Mechanism policy summary on July 16. The document follows secondary regulations laid on July 13 and gives importers and overseas manufacturers more detail on registration, returns, record-keeping, carbon price relief and CBAM rate calculations.
The UK CBAM will start on January 1, 2027. It is separate from the EU CBAM and will apply across the United Kingdom, including Northern Ireland.
Products and Importers in Scope
The mechanism covers specified commodity codes in aluminium, cement, fertiliser, hydrogen, iron and steel. Some products, including identified aluminium and iron or steel scrap codes, are excluded at launch.
The person named as the importer on the customs declaration is generally liable for CBAM. A minimum registration threshold of £50,000 applies to the value of relevant CBAM goods. Importers can appoint tax agents to submit returns, but the tax agent does not assume the liability.
How the CBAM Charge Is Calculated
The CBAM charge is based on imported embodied emissions multiplied by the applicable CBAM rate. Eligible carbon price relief can then reduce the final liability when an effective carbon price has already been paid.
Importers may use verified actual emissions data or UK government default values. Actual data must come from the producer and be verified by a qualifying verifier. Weight, emissions intensity and supporting records will therefore become part of the commercial information needed for covered imports.
What China Exporters Should Prepare
Chinese manufacturers selling covered goods to the UK should confirm commodity codes, non-preferential origin and product weight before shipping. They should also determine whether they can provide verified facility-level emissions data to the UK importer.
Shipping documents alone will not establish the carbon liability. Exporters, importers, customs brokers and logistics providers need consistent product and weight data, while the manufacturer and verifier supply the emissions evidence. Using default values may be simpler, but it can weaken price competitiveness if the defaults exceed the producer’s actual emissions.
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