UK CBAM guidance
UK CBAM for importers: a practical checklist
If your business is named on import declarations for selected goods, CBAM is likely a data and governance task before it becomes a tax-return task.
Last updated: 13 August 2026
First, establish whether you are the liable importer
Where customs duty is payable, HMRC generally treats the individual or organisation named on the import declaration as the importer for CBAM—even where a broker submits the declaration. There are special situations, so confirm the position for your actual customs arrangements.
Your CBAM preparation checklist
| Workstream | Action now | Useful evidence |
|---|---|---|
| Scope | Map each import code to HMRC’s list. | CDS/broker data; classification notes. |
| Threshold | Build a rolling £50,000 view of in-scope imports and forward orders. | Values and tax-point dates. |
| Emissions | Ask suppliers about verified product-level emissions data. | Verification report or summary. |
| Records | Store value, weight, origin and exemption evidence by consignment. | Declarations, invoices, bills of lading. |
| Ownership | Agree what your broker provides and what your finance/tax team owns. | Written operating procedure. |
Do not leave suppliers until the final quarter
Actual emissions data needs independent verification. That is likely to be the slowest part of preparation because it depends on a producer’s data, methodology and verifier. If it is unavailable, HMRC says a default emissions value must be used; that gives a practical fallback, but not a reason to postpone the conversation.
Records start before registration
From 1 January 2027, keep records of all CBAM goods imported into the UK. Retain declarations and commercial documents that support code, value, weight and tax-point date. Where actual emissions are reported, retain the relevant verification evidence for six years.
Useful division of labour: brokers can surface declaration data; procurement can obtain supplier information; tax/finance can own threshold monitoring and eventual returns. One accountable importer should connect the pieces.