CBAM or UK CBAM: which one applies to you?
The EU and UK carbon border mechanisms share a name and a concept but differ in sectors, thresholds, dates and authorities. An importer into both markets runs two separate compliance exercises; reusing the EU scope assessment for the UK will get the answer wrong.
The EU CBAM covers six sectors including electricity and entered its definitive period on 1 January 2026, with certificate sales from 1 February 2027 and a 50-tonne annual de minimis. The UK CBAM covers five sectors — no electricity — starts on 1 January 2027 under Finance Act 2026, with a £50,000 rolling twelve-month registration threshold and HMRC registration opening on 1 January 2028. Importing into both requires compliance with both, separately.
Five operational differences
Sectors: the EU covers cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. The UK covers aluminium, cement, fertilisers, hydrogen, and iron and steel — no electricity, and no glass or ceramics.
Threshold basis: the EU tests mass, at 50 tonnes of CBAM goods per calendar year, excluding hydrogen and electricity. The UK tests value, at £50,000 over a rolling twelve months.
Dates: EU definitive period from 1 January 2026 with certificate sales from 1 February 2027; UK from 1 January 2027 with registration opening 1 January 2028.
Authority: national competent authorities in the EU; HMRC in the UK.
Benchmark price: the EU ETS price for the EU mechanism, the UK ETS price for the UK one.
What transfers and what does not
Supplier data transfers. Embedded emissions for a given consignment are a property of the goods, so upstream work to obtain producer measurements and declarations is reusable.
Scope determination does not transfer, nor do threshold tests, calculation mechanics, or treatment of carbon already paid abroad. One data programme can feed two separate compliance exercises.
Questions people actually ask
- Does the EU CBAM cover electricity?
- Yes. The UK CBAM does not — it covers aluminium, cement, fertilisers, hydrogen, and iron and steel only.
- Are the CBAM thresholds the same?
- No, and they use different measures. The EU applies a 50-tonne mass threshold per calendar year, excluding hydrogen and electricity; the UK applies a £50,000 value threshold over a rolling twelve months.
- If I comply with the EU CBAM, am I covered for the UK?
- No. Supplier emissions data is reusable, but the scope test, thresholds, calculation and authority all differ. They are two compliance exercises sharing one data programme.
Still not sure what binds you?
XG tracks obligations like these across 119 jurisdictions.