UK businesses importing steel, aluminium, cement, fertiliser or hydrogen products face a new compliance burden from 1 January 2027, when record-keeping requirements for the UK’s Carbon Border Adjustment Mechanism (CBAM) take effect. And in a detail that will catch many smaller firms off guard, using a customs broker or freight forwarder does not pass the responsibility on.
CBAM is a new tax designed to tackle so-called carbon leakage, ensuring that certain highly traded, carbon-intensive goods imported into the UK face a comparable carbon price to equivalent goods produced here. The mechanism, already a sticking point in the UK’s trade negotiations with India, is part of the government’s push towards net zero by 2050.
For the thousands of SMEs that import components, materials or finished goods in the five affected sectors, the practical impact starts well before any tax is due.
Records first, tax later
From 1 January 2027, any business importing CBAM goods must keep records relating to those imports, and keep them for six years. Businesses that fail to keep adequate records may be liable for penalties, so HMRC’s message is clear: find out what you need to do beforehand and get it right.
Crucially, outsourcing your imports offers no escape. If a customs broker, freight forwarder, haulier or tax agent completes the import declaration on your behalf, you may still be classed as the importer and therefore responsible for meeting CBAM obligations.
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