What importers need to know for 2027

The goods that are caught

Section 143 of the Finance Act 2026 defines a CBAM good as a good within a commodity code set out in the Table in Schedule 16, other than one the Table excepts. The Table has five headings, which section 149(4) makes the five sectors: aluminium goods, cement, fertilisers, hydrogen, and iron and steel goods. Whether a consignment is caught is decided by the eight-digit commodity code on the customs declaration and nothing else, and the checker on the front page applies the Table to any code. The sector pages give the codes, the exceptions and the boundary for each sector.

The person who pays

Section 146(1) makes the importer the person liable, and the importer is identified from the customs declaration: the person in whose name the declaration was made or, where an agent declared on someone's behalf, the person on whose behalf it was made. A freight forwarder who clears goods for you does not take the tax; a seller who declares in its own name under a delivered duty paid contract does. The guide on who is the importer works through the cases.

The date

Part 5 has effect for goods imported on or after 1 January 2027, under section 158(1), and a good is imported when the customs declaration is accepted. A declaration accepted on 31 December 2026 is outside the tax and one accepted on 1 January 2027 is inside it, whatever the date of shipment or invoice. The dates guide lists every date in the instruments.

The threshold

Paragraph 2 of Schedule 17 makes a person register on the first day of a month if the covered goods imported in the preceding twelve months reached £50,000 in customs value, or on any day the person expects to import £50,000 of covered goods within thirty days. From the day the test is met every covered import is charged, even though a person who triggers in 2027 has until 31 January 2028 to register under SI 2026/830. Goods of UK origin and returned goods are left out of the count. The calculator applies both tests.

The records from day one

Regulation 5 of SI 2026/802 requires every person who imports a covered good in the course of a business, registered or not, to keep a record of the eight-digit code, the date of import, the customs value and the net weight, and regulation 6 keeps it for six years. That record is what proves where a business stands against the threshold. The records guide lists every duty.

The amount

Section 149(1) charges the tax as the sectoral domestic price, published by the Treasury for the sector and the quarter of import, multiplied by the tonnes of carbon dioxide equivalent embodied in the good. The tonnes come either from a default value multiplied by the net weight, under regulation 4 of SI 2026/995, or from a supplier's verified emissions intensity multiplied by the weight, under regulation 5. A return filed on a default value cannot afterwards be changed to actual data. The worked example runs one consignment through both routes, and the guide on the two routes explains the choice.

The first return

The first accounting period is the whole of 2027, and the return and the payment for it are due before the end of 31 May 2028; the two quarters that follow are due before the end of 31 July 2028 and 29 September 2028, and the ordinary quarterly rule applies from then on. HMRC guidance states that registration opens by 1 January 2028. Between now and the first return, the work is to find the installation behind every covered line, to ask it for verified data, and to hold the weight, the code and the value for every consignment.