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UK CBAM · liability starts 1 January 2027

Get your suppliers’ emissions data before UK CBAM defaults cost you.

From 1 January 2027, UK importers of iron and steel, aluminium, fertiliser, cement and hydrogen pay a carbon tax on the emissions embedded in those goods. Oremly reads your import ledger, chases every overseas supplier for verified emissions data, extracts it from whatever they send, and shows your liability, actual data against default values, through 2027.

Free until 1 January 2027 · £149/month locked until 2029 · No card required

Built against Part 5 of the Finance Act 2026 and the CBAM regulations made July–September 2026 · Verified 28 Sep 2026

02 · Your dashboard

Oremly dashboard showing compliance overview with import lines, supplier status, and liability estimates

Dashboard with demo data showing threshold status, estimated liability, import lines, and supplier data collection progress.

03 · Key dates

DateWhat happensWhat it means for you
1 January 2027CBAM liability starts on covered importsEvery covered import from this date needs records and, if you are caught, carries tax.
31 January 2028Registration deadline for anyone first caught during 2027After 2027, you normally have 30 days from the date you are caught.
31 May 2028First return and payment, covering all of 2027Built entirely from data collected during 2027.
From 2028Returns and payments move to quarterlySupplier data becomes a rolling, every-quarter task.

HMRC’s registration service opens by 1 January 2028. Until then, HMRC’s instruction is to keep records.

04 · What changes on 1 January 2027

Verified 28 Sep 2026 · GOV.UK

01 It is scoped by commodity code, not by industry. Screws, bolts and nuts (7318), steel and aluminium doors and windows (7308, 7610), tanks and containers, and "other articles" of iron, steel and aluminium (7326, 7616) are all in scope. Plenty of importers who have never thought of themselves as carbon-intensive are caught.

Matches every line of your import ledger against HMRC’s in-scope list and flags each CBAM line by code and sector. Learn more

02 The £50,000 threshold is tested every month, and looking forward. A rolling 12-month look-back on the first day of each month, plus any 30-day window you expect to reach £50,000.

Re-tests your ledger every month, runs the forward test on expected shipments, and records the exact date you crossed. Learn more

03 The tax is on emissions your suppliers hold. The charge is based on the emissions from producing the goods, including precursor materials, at the installation that made them. Actual figures must be independently verified.

Sends each supplier a request with a no-login upload link, chases automatically, and tracks every installation against your cutoff date. Learn more

04 Suppliers send anything except what you need. Mill certificates as PDFs, scanned reports, spreadsheets in other languages, or nothing at all.

AI reads whatever arrives, extracts the emissions figures and units, and puts them in front of you to confirm. Nothing enters your records until you approve it. Learn more

05 Default values are a one-way door. Without verified data you must use a single government default per good, set so there is no advantage over real data. A return filed on defaults cannot be amended later with data you never collected.

Shows the cost of defaulting supplier by supplier, while there is still time to get the data. Learn more

06 Carbon already paid abroad can cut your bill, if you can prove it. Carbon Price Relief applies where goods were subject to a qualifying carbon pricing scheme, backed by verified evidence.

Records the scheme, the price paid and the evidence for each supplier, and applies the relief in your liability. Learn more

07 HMRC expects six years of records, even below the threshold. Commodity code, date, value and net mass for every covered import, plus exemption and verification evidence. Failing to keep records can mean a £500 fixed penalty.

Stores every document with a SHA-256 checksum in an evidence vault, with an append-only audit trail. Learn more

08 You still file through HMRC’s own service. There is no software filing route. Returns go through HMRC’s CBAM service using your Government Gateway account.

Produces a return-ready summary in HMRC’s field order, so filing is transcription rather than research. Learn more

05 · Is this you?

UK CBAM covers specific goods in five sectors, defined by commodity code: sometimes a whole chapter, sometimes a heading or sub-heading, with named exceptions.

SectorIn scope (HMRC headings)Who typically imports it
Iron and steelChapter 72 (except certain ferro-alloys and 7204 ferrous scrap); agglomerated iron ore (2601 12); sheet piling, railway material, tubes, pipes and fittings (7301–7307); structures including doors and windows (7308); tanks and containers (7309–7311); screws, bolts, nuts and washers (7318); other articles (7326)Steel stockholders, fabricators, fastener and fixings distributors, builders’ merchants, engineering firms
AluminiumUnwrought aluminium (7601); powders, bars, profiles, wire, plate, foil, tubes and fittings (7603–7609); structures including doors and windows (7610); containers (7611–7613); stranded wire (7614); other articles (7616)Aluminium distributors, window and door fabricators, packaging buyers
FertiliserNitric acid (2808 00); ammonia (2814); potassium nitrate (2834 21); nitrogenous fertilisers (3102); compound fertilisers (3105, except PK fertilisers 3105 60)Agricultural merchants, fertiliser importers and blenders
CementCement clinker and Portland, aluminous and other hydraulic cements (2523 10, 21, 29, 30 and 90); certain kaolinic clays (2507 00 80)Cement importers, builders’ merchants, construction suppliers
HydrogenHydrogen (2804 10)Chemical and industrial users

Quick check

Which sectors do you import from outside the UK?

Check your goods

06 · How it works

1

Upload your import ledger

Your CDS export or your broker’s spreadsheet. AI proposes the column mapping and you confirm it.

2

We chase your suppliers

Requests with a no-login upload link, automatic reminders, and a clear cutoff date for each supplier.

3

We calculate your liability

Actual data against default values, with Carbon Price Relief, by quarter.

4

You file with confidence

A return-ready summary in HMRC’s field order, with the evidence behind every line.

07 · Whatever your supplier sends

Suppliers send

scanned-mill-certificate.pdf

emissions_data_2027.xlsx

ProduktMengeCO2

verification-summary.pdf

... 3 pages · scanned

Oremly extracts

Installation
Overseas steel mill
Production period
Q3 2027
Good
Hot-rolled coil (7208)
Emissions intensity
High confidence
2.14 tCO₂e/t
Unit
tCO₂e per tonne
Verifier
TÜV SÜD

AI proposes; you confirm. Nothing enters your records without your approval.

08 · Cost of defaulting

Illustrative

Based on a year of imported hot-rolled coil and fasteners from two suppliers, using provisional CBAM rates and default values.

Liability on verified data

£18,400

Liability on default values

£26,200

Cost of defaulting

£7,800

42% more than verified data

09 · What’s final and what’s still coming

Verified 28 Sep 2026

Final

  • ✓Part 5 of the Finance Act 2026, Royal Assent 18 March 2026
  • ✓CBAM (Administrative Provisions) Regulations, S.I. 2026/802
  • ✓CBAM (Rate and Carbon Price Relief) Regulations, S.I. 2026/809
  • ✓CBAM (Emissions and Verification) Regulations, S.I. 2026/995
  • ✓HMRC guidance: scope, records, registration (16 July 2026)

Still to come

  • –Default emissions values (HM Treasury notice, due before 1 Jan 2027)
  • –First quarterly CBAM rates (expected start of January 2027)
  • –HMRC guidance on monitoring, reporting and verifying emissions
  • –HMRC CBAM registration service (opens by 1 January 2028)

10 · A system of record

✓

SHA-256 checksum on every stored file, verified on retrieval

✓

Append-only audit trail that no user can edit or delete

✓

Full export of the organisation in one click; no lock-in

✓

Roles (owner, editor, viewer) so finance, operations and a broker can share one account

✓

Two-step verification with an authenticator app

✓

Paused accounts are never deleted: the records are the customer’s compliance evidence

11 · For customs brokers

Your importer clients will ask you about CBAM from 2027. Invite Oremly into their accounts today and register for the multi-client broker workspace.

12 · Pricing

Until 31 December 2026

Founding Access

£0

until 1 January 2027

  • ✓ Full product access
  • ✓ £149/month locked until 1 January 2029
  • ✓ No card required
Start free founding access

Standard

£149

per month from January 2027

  • ✓ All features included
  • ✓ Single importing entity
  • ✓ Annual plan: £1,609.20/year (10% off)
View full pricing →

13 · Questions importers ask

14 · Get started

Your 2027 records start on 1 January. Set them up while it’s free.

Free until 1 January 2027 · £149/month locked until 2029 · No card required

Start free founding access

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