Summary of UK CBAM Secondary Legislation
HM Revenue and Customs (HMRC) has confirmed that the Carbon Border Adjustment Mechanism (CBAM) secondary legislation is designed to embed CBAM within existing UK tax and customs frameworks, aligning it as closely as possible with standard HMRC administrative, compliance and enforcement procedures.
Taken together, the Regulations focus on establishing familiar processes for registration, reporting, calculation of dues, payment, reimbursement and recovery of funds, rather than creating a standalone or bespoke regime. This approach mirrors established tax administration principles, ensuring that CBAM liabilities are assessed, collected and enforced in line with existing customs valuation rules, accounting periods, record‑keeping requirements and compliance powers.
Further detail can be found in the draft Regulations themselves, including:
• CBAM Transitory Provision Regulations 2026
• CBAM Calculation and Carbon Price Relief Regulations 2026
While this provides clarity on how CBAM will be administered and enforced, it does not resolve the outstanding technical issues industry needs in order to calculate and model CBAM liabilities in practice, notably the emissions metrics, default values and free allowance adjustments that underpin the calculation of dues.
Author
Jo Gilbertson
Jo Gilbertson is AIC’s Head of Fertiliser and is based at our Head Office in Peterborough.
Jo is responsible for the management and co-ordination of all matters relating to the production and distribution of fertilisers on behalf of Members.
Graduating with a BSc (Hons) in Environmental Health, he has additional post graduate qualifications in air pollution control, health and safety, advanced negotiation skills, and quality assurance management.
