UK CBAM Exemptions: Which Imports Are Not Covered

Individual consignments with a customs value under £500 are exempt from CBAM entirely. This is the de minimis threshold designed to prevent low-value parcels from creating disproportionate compliance costs for both importers and HMRC.

The de minimis exemption applies per consignment, not per item within a shipment. If a single consignment contains multiple items, the total customs value of the consignment is tested against the £500 limit. If the consignment value exceeds £500, all items in that consignment are subject to CBAM.

Goods covered by the de minimis exemption do not count toward the £50,000 annual threshold. This means you can import an unlimited number of sub-£500 consignments without triggering CBAM obligations, but only if each individual consignment stays under £500.

CBAM does not apply to goods imported for private or personal use, as opposed to commercial purposes. This exemption covers goods brought into the UK by individuals for their own consumption, such as a personal import of aluminium cookware or steel garden tools for private use.

The exemption is not available for imports made by a business, even if the goods will be consumed by the business rather than sold. If a construction company imports steel beams for its own building project, those beams are imported for business purposes and are subject to CBAM.

HMRC has indicated it will apply a "business purpose" test. Factors include the quantity imported, the frequency of imports, and whether the goods are of a type typically used in a commercial context. Importing 50 tonnes of cement is self-evidently commercial regardless of the stated purpose.

Goods of UK origin that are exported and subsequently re-imported are exempt from CBAM if they qualify for Returned Goods Relief (RGR). RGR applies to goods that were originally exported from the UK and are being returned within three years of export, in the same condition, by the same person.

This exemption is important for UK manufacturers who send goods overseas for processing (e.g., coating, heat treatment) and re-import them. If the goods retain their UK origin and qualify for RGR, no CBAM liability arises on re-importation.

However, if the goods undergo substantial processing overseas that changes their classification or origin, they may no longer qualify as UK goods. The distinction between "processing" and "manufacturing" is critical, and customs advice should be sought before relying on the RGR exemption for processed goods.

Goods imported under temporary admission (temporary importation with intended re-export) are not subject to CBAM as long as they remain under the temporary admission regime. This covers goods imported for exhibitions, testing, repair, or temporary use that will be re-exported within set time limits.

Similarly, goods placed into customs warehousing are not subject to CBAM until they are released into free circulation. This allows importers to store goods in an HMRC-authorised warehouse without triggering CBAM until the goods enter the UK market.

If goods are held in a customs warehouse and subsequently released into free circulation in multiple partial withdrawals, CBAM applies at the point each partial withdrawal is made. The value of each withdrawal is its proportionate share of the total consignment value, tested against the £50,000 annual threshold at that time.