Updates

Every change in the law, dated and sourced.

Each entry names its source and the date it was read, is labelled law, draft or guidance, names the chapters of UK CBAM for Importers it touches, and answers three questions: what changed, who is affected, and what an importer should do now. Corrections to the book are kept on the errata page. Where a change needs working through rather than recording, the briefings take it up.

law

The sources were re-read on 21 September 2026 and nothing had changed

What changed. Nothing changed. This entry records a review rather than a movement in the law. Schedule 16 to the Finance Act 2026 stands unamended, and its Table still excepts 7202 21 within the ferro-silicon subheadings without excepting 7202 29, so the position this site takes on 7202 29 is unchanged. The list of 2026 statutory instruments whose title contains the words Carbon Border still holds five instruments, being SI 2026/802, SI 2026/809, SI 2026/830, SI 2026/994 and SI 2026/995, and no sixth instrument has been made. SI 2026/802 and SI 2026/809 were both made on 13 July 2026 and laid before the House of Commons on 14 July 2026, and both come into force on 1 January 2027. On GOV.UK the collection Prepare for the Carbon Border Adjustment Mechanism (CBAM) still carries the date 9 September 2026, the policy summary is still the version updated on 9 September 2026, the registration collection and the keeping records guidance still carry 16 July 2026, and the force of law notices page still carries the two notices in draft. The Treasury notice of default values remains unpublished, and no sectoral domestic price and no illustrative example have been published.

Who is affected. Every importer of aluminium, cement, fertilisers, hydrogen, or iron and steel goods under a commodity code in Schedule 16, and every supplier abroad that will be asked for emissions data. Nobody needs to act on this entry, and anybody who acted on the position recorded on 13 September 2026 can rely on it still.

What an importer should do now. Treat the two force of law notices as drafts, because neither has been commenced and neither currently has force of law. Hold the tonnage, the commodity code and the named installation for every covered consignment, so that the calculation can be run on the day the default values notice appears. Watch for the illustrative sectoral domestic price, which HMRC’s policy summary places in the autumn of 2026 and which no source had published on this date.

Source
Finance Act 2026, Schedule 16; the list of 2026 statutory instruments whose title contains Carbon Border; SI 2026/802 and SI 2026/809 as made; all read on legislation.gov.uk on 21 September 2026. Prepare for the Carbon Border Adjustment Mechanism (CBAM), the registration collection, the keeping records guidance, the policy summary and the force of law notices page, all read on GOV.UK on 21 September 2026
Chapters
1, 4, 5, 16, 18

law

The law as at 13 September 2026 was reviewed

What changed. Nothing new was published on this date; this entry records the position from which the site and the book proceed. The book states the law as it stood on 13 September 2026. Part 5 of the Finance Act 2026, which received Royal Assent on 18 March 2026, has effect for goods imported into the United Kingdom on or after 1 January 2027. Five statutory instruments made under it come into force on the same day: the Administrative Provisions Regulations, SI 2026/802, made on 13 July 2026; the Calculation of CBAM Rate and Determination of Carbon Price Relief Regulations, SI 2026/809, made on 13 July 2026; the Transitory Provision Regulations, SI 2026/830, made on 14 July 2026; the Emissions and Verification Regulations, SI 2026/995, made on 8 September 2026; and the Interest Appointed Day Order, SI 2026/994, made on 8 September 2026. The System Boundaries Document, version 1.00, dated 10 July 2026, is incorporated by the regulations. Two Commissioners’ notices exist only in draft, published on 14 July and 9 September 2026; a draft notice does not currently have force of law and is due to take effect when commenced on 1 January 2027. The Treasury’s default values had not been published in any form on that date.

Who is affected. Every importer of aluminium, cement, fertilisers, hydrogen, or iron and steel goods under a commodity code in Schedule 16, and every supplier abroad that will be asked for emissions data.

What an importer should do now. Run the check on the front page against every commodity code on the last twelve months of customs declarations, add up the customs value of the covered lines against the £50,000 threshold, and name the installation behind every covered line. Where a position on this site rests on a draft notice, treat it as the draft’s position until the notice is commenced.

Source
Finance Act 2026, Part 5; SI 2026/802; SI 2026/809; SI 2026/830; SI 2026/994; SI 2026/995; System Boundaries Document, version 1.00; the two draft force of law notices on GOV.UK; all read on legislation.gov.uk and GOV.UK on 13 September 2026
Chapters
1, 4, 5, 16, 18

law

The Emissions and Verification Regulations were made, and the second notice was published in draft

What changed. The Carbon Border Adjustment Mechanism (Emissions and Verification) Regulations 2026, SI 2026/995, were made on 8 September 2026 and laid before the House of Commons on 9 September 2026, and they come into force on 1 January 2027. They provide for the calculation of embodied emissions, for default values and the eight-step calculation from verified data, for the global warming potentials, for monitoring periods, for verified emissions data and verifiers, for the verification report and for accreditation bodies, and regulation 17 amends SI 2026/802. On the same day the Treasury made SI 2026/994, which appoints 1 January 2027 as the day on which late payment interest and repayment interest under the Finance Act 2009 apply to the tax. HMRC published the Emissions and Verification Force of Law Notice in draft, running to 118 pages, and updated its policy summary. The draft notice does not currently have force of law and is due to take effect when commenced on 1 January 2027.

Who is affected. Every importer that intends to use verified actual data rather than the default value, and every installation abroad that intends to supply it, now has the regulation that governs the calculation and the verification. The draft notice carries the monitoring methodology, the attribution rules, the conversion equations for clinker and nitrogen content, the operator’s emissions report and the verifier’s report, and a cement or fertiliser importer should read the conversion equations as the draft’s position only.

What an importer should do now. Send appendix D of UK CBAM for Importers, the supplier question sheet, to every supplier of a covered good, and ask which installation will hold a verification report under regulation 14 for the 2027 monitoring period. Hold the clinker content or the nitrogen content of every grade imported, since the conversion equations will need it. Treat every position in the draft notice as provisional until it is commenced.

Source
SI 2026/995, made 8 September 2026 and laid 9 September 2026; SI 2026/994 (C. 81), made 8 September 2026; the Emissions and Verification Force of Law Notice, published in draft on 9 September 2026; HMRC policy summary, updated 9 September 2026; all read on legislation.gov.uk and GOV.UK on 13 September 2026
Chapters
5, 7, 14, 15, 16, 25, 26

guidance

HMRC published its list of qualifying carbon pricing schemes

What changed. HMRC published, as guidance, a list of current qualifying carbon pricing schemes, based on information available as of 19 June 2026, which it describes as not exhaustive and as a draft list to be kept under review. It names sixteen schemes: the Australia Safeguard Mechanism, the Canada Federal Output-Based Pricing System, the Chile Carbon Tax, the China National Emissions Trading System, the EU Emissions Trading System, the Indian Carbon Credit Trading Scheme, the Japan GX-ETS, the Kazakhstan Emissions Trading System, the Korea Emissions Trading System, the Montenegro Emissions Trading Scheme, the New Zealand Emissions Trading Scheme, the Serbia Carbon Tax, the Singapore Carbon Tax, the South Africa Carbon Tax, the Swiss Emissions Trading System and the Taiwan Carbon Fee.

Who is affected. Any importer whose supplier’s installation sits in a jurisdiction with a carbon price, and any installation abroad that pays one, since carbon price relief under SI 2026/809 reduces the tax by the effective carbon price already paid under a qualifying scheme. The list is guidance and regulation 6 of SI 2026/809 is the test; a listed scheme ceases to qualify if it later fails the criteria, an unlisted scheme may still qualify if it meets them, and the liable person remains responsible for determining eligibility.

What an importer should do now. Match every supplier installation to the list, and for those on it ask whether form CarbonVP1 can be completed for the installation and, where a precursor came from another jurisdiction, for that installation as well. For a supplier under an unlisted scheme, apply the four conditions in regulation 6(1) before assuming that relief is available. The full list, with the test, is on the qualifying carbon pricing schemes page.

Source
UK CBAM: current qualifying carbon pricing schemes, HMRC, 27 August 2026, based on information as of 19 June 2026; read on GOV.UK on 13 September 2026
Chapters
18

law

The first three statutory instruments were made and the first notice was published in draft

What changed. The Commissioners made the Administrative Provisions Regulations, SI 2026/802, on 13 July 2026, and the Treasury and the Commissioners made the Calculation of CBAM Rate and Determination of Carbon Price Relief Regulations, SI 2026/809, on the same day; both were laid on 14 July 2026 and come into force on 1 January 2027. The Treasury made the Transitory Provision Regulations, SI 2026/830, on 14 July 2026. The System Boundaries Document, version 1.00, dated 10 July 2026 and incorporated by regulation 2 of SI 2026/809, appeared on GOV.UK on 13 July 2026. HMRC published the Administrative Provisions and Determination of Carbon Price Relief Force of Law Notice in draft; the draft notice does not currently have force of law and is due to take effect when commenced on 1 January 2027.

Who is affected. Every importer of a covered good. SI 2026/802 fixes the value and weight of goods, the records, the information given on registration and the content of the return. SI 2026/809 sets out how the sectoral domestic price is built, what a qualifying carbon pricing scheme is, and how carbon price relief is calculated. SI 2026/830 provides that a person who triggers registration in 2027 must register by 31 January 2028, that the accounting period for 2027 is the calendar year, and that the returns and payments for 2027 and the first half of 2028 fall due before the end of 31 May 2028, 31 July 2028 and 29 September 2028.

What an importer should do now. Put the three 2028 dates in the diary. Check that customs entries carry the net weight of the goods excluding packing, as regulation 4 of SI 2026/802 requires. Read the System Boundaries Document for each sector imported, since it fixes which emissions and which precursors count, and start the records that regulation 6 of SI 2026/802 requires to be kept for six years.

Source
SI 2026/802 and SI 2026/809, made 13 July 2026 and laid 14 July 2026; SI 2026/830, made 14 July 2026; System Boundaries Document version 1.00, dated 10 July 2026; the Administrative Provisions and Determination of Carbon Price Relief Force of Law Notice, published in draft 14 July 2026; all read on legislation.gov.uk and GOV.UK on 13 September 2026
Chapters
4, 6, 9, 10, 11, 12, 18, 23