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We link to the original sources below. Sections labelled “Sandycroft analysis” contain our interpretation and practical suggestions. Product and service links are commercial suggestions from Sandycroft, separate from the source reporting.

SANDYCROFT ANALYSIS

The afternoon update

A Treasury statement on 16 October says the UK Carbon Border Adjustment Mechanism will begin on 1 January 2027. It covers specified imported goods in aluminium, cement, fertiliser, hydrogen, iron and steel. Today’s publication adds default emissions values for 2027 and 2028, plus illustrative rates and a worked example for the first quarter of 2027.

The rates published today are preliminary guidance only and do not create a tax liability. Official rates for the first quarter are due before the end of 2026 and will then be set at the start of each quarter. The default values include a 10% markup in every covered sector except fertiliser; country-specific defaults are planned from 2029.

SANDYCROFT ANALYSIS

Find out whether your business is the importer

Sandycroft analysis: start with customs records, not a supplier’s broad product description. HMRC says the liable person is normally the importer in whose name the customs declaration is made, or the person on whose behalf it is made. The detailed commodity code decides whether a good is in scope; the presence of metal somewhere in a finished product is not enough to answer that question.

List direct imports expected from January, the supplier, country of origin, commodity code, customs value and net weight. Ask a customs adviser where classification or the identity of the importer is uncertain. Do not assume a freight forwarder, marketplace or buying agent carries the liability without checking the declaration and contract.

SANDYCROFT ANALYSIS

Watch both £50,000 registration tests

The policy uses a £50,000 minimum registration threshold. A forward-looking test asks whether covered imports are expected to meet or exceed that value over the next 30 days. A backward-looking test is applied on the first day of each month using the preceding 12 months, with the first-year look-back starting on 1 January 2027.

Registration is scheduled to open on 1 January 2028, and businesses liable during 2027 have until 31 January 2028 to register. That delay is not a record-keeping holiday: HMRC says liable importers must retain the information needed to register, complete returns and calculate the charge from the point liability begins.

SANDYCROFT ANALYSIS

Ask suppliers for evidence before the first shipment

For each covered import, prepare to retain the commodity code, import date, customs value, net weight, origin and emissions information. Actual emissions data must be properly verified; where actual data is unavailable, the published default value can be used. HMRC’s policy says relevant records generally need to be kept for six years after the accounting period.

Build the request into purchasing now: name the person responsible, agree the format with the supplier and test whether the evidence can be matched to an individual shipment. Separate confirmed data from assumptions and keep the source document with the calculation. An illustrative rate is useful for a scenario budget, but it should not be treated as the final quarterly rate.

SANDYCROFT ANALYSIS

Keep branded purchasing precise

Businesses buying decorated workwear, signs or promotional merchandise should keep the product specification, supplier and import route visible. A metal bottle, garment fastening or display fitting is not automatically a CBAM good; classification depends on the exact imported product and commodity code. Ask the seller who imports the item and record the answer instead of inferring liability from the material.

Sandycroft Workwear and Sandycroft Promo can discuss branded product specifications, while Flintshire Printing can help keep approved purchasing or staff information clear. Those services do not determine customs classification or CBAM liability. Use HMRC guidance and appropriate professional advice for that decision, then reflect any confirmed compliance cost in the quotation rather than adding a vague contingency to every order.

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Sources & dates