UK CBAM vs EU CBAM: Key Differences
UK CBAM and EU CBAM are different regimes. Different thresholds, different goods, different rates and a separate registration. Why your EU tool will not cover UK CBAM.
On this page
Separate regimes, separate obligations
UK CBAM and EU CBAM are distinct legal regimes. They share the same policy goal (preventing carbon leakage) and the same basic structure (carbon price on imports), but differ in almost every practical detail.
If you import goods into both the UK and the EU, you must comply with both regimes separately. Compliance with one does not satisfy the other.
Key differences
- Threshold: UK tests £50,000 by customs value; EU tests 50 tonnes by net mass per importer per year
- Covered goods: UK covers aluminium, cement, fertiliser, hydrogen, iron and steel; EU covers the same sectors plus electricity
- Default values: UK sets a single default value per good; EU uses average values per country of origin
- Carbon Price Relief: UK allows relief for carbon prices paid in the country of production; EU uses a certificate system where the price of EU ETS allowances is deducted
- Indirect emissions: UK excludes indirect emissions until 2029 at the earliest; EU includes indirect emissions from 2026
- Return frequency: UK starts annual (2027–2029) then quarterly; EU is quarterly from the start
Can you use the same tool for both?
No. EU CBAM tools are designed for the EU regime and cannot produce a UK CBAM return. The commodity code lists are different, the calculation methodology differs, the relief mechanism is different, and the return format is different.
Oremly is designed for UK CBAM only. If you also need EU CBAM compliance, you will need a separate tool for that regime.
From the UK CBAM guide
Read the full UK CBAM guideRelated guides
Frequently asked questions
Ready to simplify your CBAM compliance?
Free until 1 January 2027 · £149/month locked until 2029 · No card required
Start free founding access