For the producer outside the United Kingdom

What the UK law does not do

It imposes no obligation on you. Section 146(1) of the Finance Act 2026 places the liability on the importer, and no provision of Part 5 or the regulations requires an operator outside the United Kingdom to monitor, report, be verified or register. There is no UK registry of installations and nothing to file with HMRC. What you do, you do because your customer asks and because your contract requires it.

What the money is

From 1 January 2027 your UK customer pays a tax on every tonne of carbon dioxide equivalent embodied in the covered goods it imports, at a price per tonne the Treasury publishes each quarter for each sector. If the customer has no verified data from you, the tonnes are the weight multiplied by a default value that the Treasury may set high enough that no importer gains by using it. If the customer has verified data, the tonnes are the weight multiplied by your installation's verified intensity. The difference, multiplied by the tonnes your customer buys and the published price, is what your data is worth to your customer.

What the customer needs

One number per commodity code, with a document behind it. The number is the emissions intensity under step 7 of regulation 5 of SI 2026/995: the tonnes of carbon dioxide equivalent per tonne of the type of good, for a calendar year, rounded to five decimal places. The document is a verification report under regulation 14 from a verifier who meets regulation 12. Producing the number means identifying your installation's emissions within the system boundary the System Boundaries Document sets for your category, the precursors you used with their verified data or the UK default value, and the tonnes of each type of good you produced in the functional unit the document sets.

The monitoring period

The period is a calendar year under regulation 9(1). For goods your customer imports before 1 January 2028 it may use the import year or the preceding year with verified data, or the year of production; from 2028, the most recent of the two preceding years with verified data, or the year of production. A producer that wants its 2027 shipments to carry its own figure needs a verified 2026 year or a 2027 year monitored from 1 January; one that starts monitoring in the middle of 2027 has its first usable year in 2028.

The verifier

Regulation 12 requires the verifier to be independent of your customer, of your installation and of every precursor installation, accredited for the type of good by a body that is a full member of the Global Accreditation Cooperation Incorporated, and compliant with a Commissioners' notice. HMRC's policy summary, as guidance, names ISO/IEC 17029:2019 and ISO 14065:2020, and the draft notice of 9 September 2026 names the same two standards. Regulation 14 fixes what the verifier gives you: a report naming the installation, the operator and the verifier, the accreditation number, the monitoring period and an opinion statement. Your customer keeps it for six years.

The carbon price you already pay

If your jurisdiction's scheme meets regulation 6 of SI 2026/809, your customer can claim carbon price relief, and it needs form CarbonVP1 completed by a verifier meeting regulation 8 and provided to you. A producer in a carbon-priced jurisdiction that supplies the form is offering its UK customer a direct reduction in tax, and should say so when it quotes.

Three practical points

The figure is a plant-wide annual average per commodity code, not a batch figure. The figure attaches to the installation, so a trader selling on your goods needs a mill document naming your installation with each consignment. And a report that arrives after your customer's deadline is worth nothing for that period, because paragraph 8(2) of Schedule 17 forbids the customer from amending a return filed on a default value; the first return, for the whole of 2027, is due before the end of 31 May 2028. An unverified figure, however careful, is not one the customer may enter, though an expected intensity clearly labelled as unverified helps the customer plan.

The report you made for the EU

The UK request is a different request under a different law. The UK mechanism is a tax under the Finance Act 2026 with its own calculation, its own system boundaries, its own verifier rules and its own monitoring periods; the EU mechanism under Regulation (EU) 2023/956 has its own. Whether data gathered for an EU customer can serve a UK customer depends on whether it was gathered within the UK boundaries and whether your verifier can report against the UK requirements. The safe assumption is that an EU report is a starting point and not a substitute, and the question to put to your verifier is whether it will issue a report against the UK regulations from the data it has already verified.

The producer's list

Which UK commodity codes do your goods fall under, and which category does the document map each to. From which calendar year will you have a full year of monitoring within the UK boundary, with precursors recorded. Which verifier, accredited by which body for which type of good, will report, and when. Does your jurisdiction's carbon price meet regulation 6, and can a verifier complete form CarbonVP1. And by what date has each UK customer said it needs the report.