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United KingdomGOV.UK

CBAM importers must keep records from 1 January 2027

Anyone importing CBAM goods must keep records from 1 January 2027 even if not liable; registration opens 1 January 2028 and late registration risks a failure-to-notify penalty.

By Taxxa AI OyPublished 10 November 2026

Tax

From 1 January 2027GOV, anyone who has imported Carbon Border Adjustment Mechanism (CBAM) goods into the United Kingdom must keep records of those importsGOV, even where they are not liable for the taxGOV. CBAM comes into effect on that dateGOV and charges on the embodied emissions in specified carbon-intensive goods in five sectors: aluminium, cement, fertiliser, hydrogen, and iron and steelGOV.

For each CBAM good the records must show the 8-digit commodity code and description, the date it passed the tax point when it first entered the United Kingdom or cleared customs, its value, its weight, and evidence supporting any exemption claimed. Records must show the weight excluding packaging (net mass) in kilograms at import. Import declarations, commercial invoices and supplier or manufacturer documents can serve as records where they hold the required information. An importer who reports actual emissions must keep the verification report or verification summary evidencing the reported emissions intensity; where actual data or verified evidence is unavailable a default value applies.

Records must be kept in written form, including electronically, for 6 yearsGOV from the later of the date they were created and the end of the accounting period they relate to. Failure to keep CBAM records carries a fixed penalty of £500GOV, and separate penalties can apply for failing to provide information or documents when HMRC requires them.

Registration for CBAM opens on 1 January 2028GOV. An importer must register where it expects to import CBAM goods worth £50,000 or more within the next 30 days on or after 1 January 2027, or where it has imported CBAM goods worth £50,000 or more in the previous 12 months, tested on the first day of each month from 1 January 2027GOV GOV with pre-2027 imports excludedGOV; where both tests are met the earliest date governs. An importer that needs to register but does not, or that registers late, is treated as a failure to notify and HMRC may charge a penaltyGOV.

The CBAM framework is set through primary legislation in the Finance Act 2026, with detail in draft secondary legislation and notices.

If you import CBAM goods into the United Kingdom, put record-keeping in place for imports from 1 January 2027 and check whether you must register once registration opens on 1 January 2028.

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