UK CBAM — Schedule, Registration and Obligations for Polish Exporters

What Is UK CBAM and How Does It Differ from EU CBAM?

The UK and EU have developed separate CBAM frameworks. Understanding the difference is essential for Polish businesses that trade in both directions.

UK CBAM — enacted through the Finance Act 2026, in force from 1 January 2027

UK CBAM was enacted through the Finance Act 2026 and comes into force on 1 January 2027. The mechanism places a carbon price on imports into Great Britain (England, Scotland, Wales) of carbon-intensive goods from countries where producers do not face a carbon cost equivalent to the UK Emissions Trading Scheme (UK ETS). HMRC implementing regulations specifying the exact scope, rates, registration procedures and default emission values will be published in 2026. Polish exporters should monitor the official collection page for updates: gov.uk/government/collections/carbon-border-adjustment-mechanism. Source: Finance Act 2026; gov.uk/government/collections/carbon-border-adjustment-mechanism (dateModified 2026-04-09).

EU CBAM — already enacted (Regulation (EU) 2023/956)

For completeness: the EU CBAM (Regulation (EU) 2023/956) is already enacted and creates obligations for importers bringing goods into the EU from third countries — including from the UK. CBAM certificates will be required from 1 January 2026 for imports of covered goods. This affects Polish companies importing from the UK in sectors including steel, iron, aluminium, cement, fertilisers, electricity and hydrogen. Polish importers already have reporting obligations since the transitional phase began in October 2023. This article does not cover EU CBAM in detail — see our separate article on EU CBAM vs UK CBAM comparison.

Sectors covered by the proposed UK CBAM

The proposed UK CBAM covers the following sectors (based on the published policy framework — subject to change before enactment):

• Iron and steel (HS Chapters 72–73)
• Aluminium (HS Chapter 76)
• Fertilisers (HS Chapter 31)
• Cement (HS Chapter 25)
• Ceramics
• Glass
• Hydrogen

The exact commodity codes and thresholds will be specified in secondary legislation. Note that the UK sector list is broadly similar to but not identical to the EU CBAM sector list — in particular, the proposed UK CBAM includes ceramics and glass, which the EU CBAM covers only partially. Monitor gov.uk for the final list once the enabling act is passed.

What Polish Exporters Need to Do Now

Given that the UK CBAM is proposed but not yet enacted, the appropriate response for Polish exporters is to monitor and prepare — not to register or report.

Phase 1 (now until HMRC implementing regulations are published): assess and prepare

UK CBAM has been enacted through the Finance Act 2026. Polish companies exporting goods in the covered CBAM sectors to the UK should now: (1) confirm whether your products fall within the sector scope based on HS codes; (2) calculate or estimate the embedded carbon content of your exported goods — this will be required for UK CBAM declarations from 1 January 2027; (3) familiarise your team with the UK ETS carbon price (updated weekly on gov.uk) as this will be the reference price for UK CBAM charges; (4) monitor HMRC's implementing regulations at gov.uk/government/collections/carbon-border-adjustment-mechanism for registration procedures and technical details. Preparation — not merely monitoring — is now appropriate.

Phase 2 (once HMRC implementing regulations are published): registration

Under the Finance Act 2026, importers of covered goods into the UK (not the Polish exporters themselves, but their UK buyers or UK customs representatives) will need to register as CBAM declarants with HMRC before 1 January 2027. The registration process is expected to be similar to VAT registration — online, through the Government Gateway. Polish exporters will need to provide embedded carbon data to their UK buyers so that the UK importer can complete CBAM declarations accurately. This data preparation should begin now. HMRC has indicated it will publish guidance and calculation tools before the mechanism goes live. Implementing regulations are evolving — contact a customs broker before taking any action.

Embedded carbon calculation — what will be required

Under the proposed UK CBAM framework (modelled broadly on the EU CBAM approach), importers will need to declare the tonnes of CO2 equivalent embedded in each shipment of covered goods. For Polish exporters, this means: (1) calculating the direct emissions from production processes (Scope 1); (2) for some sectors, also calculating indirect emissions (electricity used in production — Scope 2); (3) providing this data to your UK buyer via a product-level carbon declaration. If you have already begun this process for EU CBAM compliance, much of the methodology will transfer to the UK framework — though the exact calculation methods will be confirmed in the UK secondary legislation. This article reflects the legal position as of 2026-04-18. Contact a customs broker before taking any action.

UK CBAM Price and Financial Impact — Preliminary Assessment

Although UK CBAM is not yet in force, a preliminary financial assessment helps exporters understand the potential impact on competitiveness and pricing.

UK ETS carbon price — the reference for CBAM charges

The UK CBAM charge will be based on the UK Emissions Trading Scheme (UK ETS) carbon price, minus any carbon cost already paid in the country of production. The UK ETS price has fluctuated significantly — it was approximately £35–£45 per tonne of CO2 equivalent in early 2026. Check the current price at: gov.uk/guidance/uk-ets. For a Polish steel exporter with an embedded carbon intensity of 1.8 tonnes CO2/tonne of steel: if the EU ETS carbon cost already paid is equivalent to or greater than the UK ETS price, no CBAM charge would apply (the mechanism is designed to prevent double-charging). For exports from Poland where the EU ETS cost is demonstrably lower than the UK ETS price, a top-up charge would apply. Once the enabling act specifies the exact calculation methodology, we will update this analysis.

Impact on pricing and contracts

Polish exporters in CBAM sectors who sell to UK buyers should review long-term contracts now. If a contract fixes the price in GBP for deliveries after 1 January 2027 without a CBAM adjustment clause, the exporter may absorb the CBAM cost without the ability to pass it on. Recommended action: include a CBAM price adjustment clause in new contracts referencing the UK ETS price and the final CBAM rate. This is a standard commercial risk management step already adopted by exporters managing EU CBAM exposure. Easy Clearance can provide guidance on customs documentation requirements once UK CBAM is enacted. Contact us: WhatsApp +44 7404 091503 | tel +44 7404 091503. This article reflects the legal position as of 2026-04-18. Contact a customs broker before taking any action.

What the current rules say

UK CBAM was enacted through the Finance Act 2026 and comes into force on 1 January 2027. It targets imports of carbon-intensive goods (steel, aluminium, fertilisers, cement, ceramics, glass, hydrogen) into Great Britain. HMRC implementing regulations specifying registration procedures, default values and technical details will be published in 2026. Polish exporters should now confirm their sector scope, calculate embedded carbon data, and prepare for registration through their UK buyers. The EU CBAM (Regulation (EU) 2023/956) is already enacted and separately affects imports into Poland from the UK. This article reflects the legal position as of 2026-04-18. Implementing regulations are evolving — contact a customs broker before taking any action.

FAQ — frequently asked questions

Is the UK CBAM already enacted?

Yes. UK CBAM was enacted through the Finance Act 2026 and comes into force on 1 January 2027. HMRC implementing regulations specifying registration procedures, default emission values and technical details will be published in 2026. Monitor: gov.uk/government/collections/carbon-border-adjustment-mechanism.

Which sectors does the proposed UK CBAM cover?

The proposed UK CBAM covers: iron and steel, aluminium, fertilisers, cement, ceramics, glass, and hydrogen. The exact commodity codes will be confirmed in secondary legislation once the enabling act passes.

What should Polish exporters do now to prepare for UK CBAM?

UK CBAM has been enacted through the Finance Act 2026 (in force 1 January 2027). Confirm whether your products fall in the covered sector list. Begin calculating the embedded carbon content of your exports — this data will be required for CBAM declarations. Include CBAM price adjustment clauses in new contracts for deliveries after 1 January 2027. Monitor HMRC implementing regulations at gov.uk/government/collections/carbon-border-adjustment-mechanism.

Is UK CBAM the same as EU CBAM?

No — they are separate mechanisms. The EU CBAM (Regulation (EU) 2023/956) is already enacted and covers imports into the EU from third countries including the UK. The UK CBAM was enacted through the Finance Act 2026 and covers imports into Great Britain from third countries including Poland/EU, from 1 January 2027. Both can apply to the same goods traded in opposite directions.

Who pays the UK CBAM charge — the Polish exporter or the UK buyer?

The UK CBAM obligation will fall on the importer (the UK buyer or their customs representative), not the Polish exporter directly. However, the UK importer will need embedded carbon data from the Polish exporter to complete their CBAM declaration. In practice, exporters whose carbon intensity exceeds the threshold will face commercial pressure to lower prices or improve their carbon credentials.

Official sources

• UK Carbon Border Adjustment Mechanism — GOV.UK guidance — GOV.UK
• EU CBAM — Regulation (EU) 2023/956 — EUR-Lex
• UK ETS — carbon price and market data — GOV.UK