UK importers have another important compliance deadline approaching.
From 1 January 2027, the United Kingdom’s Carbon Border Adjustment Mechanism (CBAM) will apply to specified carbon-intensive imported goods. HM Revenue & Customs updated its CBAM information on 9 September 2026, including additional legislation and policy information. You can review the latest GOV.UK guidance on the Carbon Border Adjustment Mechanism.
For businesses importing commercial cargo, however, CBAM should not be viewed in isolation. Correct commodity classification, customs declarations, origin, valuation, safety and security information, and supporting documentation remain fundamental to moving goods smoothly through the UK border.
The months remaining in 2026 provide businesses with an opportunity to review these processes before the new regime begins.
What Is Changing for UK Importers in 2027?
The most significant upcoming change for certain industrial importers is UK CBAM. The mechanism begins on 1 January 2027 and will apply to specified products from five sectors:
- Aluminium
- Cement
- Fertiliser
- Hydrogen
- Iron and steel
CBAM is intended to ensure that qualifying carbon-intensive imports face a carbon price comparable with that applying to domestic production under the UK emissions framework, as detailed in the GOV.UK introduction to CBAM.
Not every product within a broadly related industry will automatically be covered. The actual commodity code matters, making accurate classification one of the first areas businesses should review.
Who Could Need to Register for UK CBAM?
HMRC has established a £50,000 registration threshold. From 1 January 2027, an importer may become liable to register if it expects to import £50,000 or more of CBAM goods within the next 30 days.
Importers will also need to assess, on the first day of each month, whether their qualifying imports during the applicable previous 12 months have reached this threshold. You can use the GOV.UK guidance to work out your CBAM registration date.
Businesses should not simply wait until total imports obviously exceed £50,000. The forward-looking test means planned imports can also create a registration obligation.
When Does CBAM Registration Open?
This is an important detail. The tax applies from 1 January 2027, but HMRC states that registration for CBAM will open on 1 January 2028. You can verify this timeline in the official GOV.UK CBAM collections.
That does not mean businesses can ignore their 2027 imports. Companies still need to monitor liability and retain the required information from the start of the regime. Businesses expecting affected imports should establish their compliance process before January 2027 rather than waiting for the registration service to open.
What CBAM Records Must Importers Keep?
HMRC requires businesses importing CBAM goods to retain specified records. These records must generally be kept in written or electronic form for six years from the applicable date. Required information includes details such as:
- Eight-digit commodity code
- Description of the CBAM good
- Import information
- Relevant emissions information
HMRC also states that failure to keep required records may result in a fixed £500 penalty, with separate penalties potentially applying when requested information or documents are not supplied. Refer to the GOV.UK guidance on keeping records for CBAM for full details.
This makes supplier data quality increasingly important, as UK importers may need information that sits further upstream in their international supply chain.
Why Are Commodity Codes So Important?
Commodity codes influence several parts of an import. They can determine:
- Applicable customs duty
- Trade policy measures
- Import restrictions
- Preferential tariff eligibility
- Licensing requirements
- Whether a product falls within CBAM
Using a code simply because it has been used historically does not guarantee that it is correct. Product specifications, materials, and intended use should support the classification. For businesses importing large product ranges, a classification audit before 2027 can reduce both customs and CBAM risk.
Does CBAM Replace CDS Customs Declarations?
No. CBAM creates an additional compliance layer. UK import and export customs declarations continue to be processed through the Customs Declaration Service (CDS).
Businesses still need to provide the information required for an accurate customs declaration. NKR Freight states that its in-house customs operation handles CDS entries, HS-code classification, duty and VAT calculations, and HMRC compliance for international freight movements.
What About Safety and Security Declarations?
Safety and security requirements should not be confused with the customs declaration itself. Entry Summary Declarations, commonly called ENS, are required before applicable goods arrive in Great Britain.
Since 31 January 2025, these requirements have also applied to EU imports into Great Britain. You can read more about getting ready for safety and security declaration requirements.
HMRC states that the carrier or haulier is legally responsible for the safety and security declaration. Another party, including an importer or intermediary, can submit it on the carrier’s behalf, but the legal responsibility remains with the carrier. See the GOV.UK information for importers regarding safety and security.
For importers, the practical lesson is straightforward: agree on who is providing and submitting each part of the data before the shipment departs.
What Information Should UK Importers Check Before Shipping?
A strong customs process begins before cargo reaches the port or airport.
- Commodity Code: Confirm the correct classification for each product.
- Country of Origin: Origin can affect tariff treatment and eligibility for preferential duty rates.
- Customs Value: Ensure the declared customs value follows the applicable valuation rules.
- Commercial Invoice: The invoice should clearly identify the buyer, seller, goods, values, and other required commercial information.
- Packing List: Quantities, weights, packaging, and shipment details should correspond with the actual cargo.
- EORI Number: Businesses involved in UK customs movements may require the appropriate Economic Operators Registration and Identification number.
- Preference Evidence: Where preferential tariff treatment is claimed, ensure the required origin evidence is available and valid.
- Licences and Certificates: Certain products require additional approvals or documents.
- CBAM Status: For 2027 shipments, establish whether the commodity code falls within CBAM and whether the shipment contributes towards the registration threshold.
Have Any Other UK Trade Rules Recently Changed?
Yes. Compliance requirements vary by product. For example, a new UK steel trade measure took effect on 1 July 2026. The government reduced overall tariff-free steel quota volumes by 51% compared with the previous safeguard measure, while qualifying imports above the relevant quota levels face a 50% tariff. You can review the official GOV.UK guidance on the UK steel trade measure.
This is another reason businesses should not treat a commodity code as merely an administrative field. Classification can directly affect landed cost.
What Should Importers Do Before January 2027?
Businesses do not need to redesign their entire supply chains, but they do need to know where their compliance risks sit. A practical review should include:
- Audit your imported products: Confirm commodity codes and identify possible CBAM goods.
- Forecast qualifying imports: Estimate the value of affected goods expected during 2027.
- Review suppliers: Determine whether overseas manufacturers can provide the information required for compliance.
- Review documentation: Check commercial invoices, packing lists, origin evidence, and product descriptions.
- Define responsibilities: Establish who handles CDS declarations, ENS submissions, and other border formalities.
- Improve record retention: Ensure CBAM and customs records can be retrieved if HMRC requests them.
- Review landed costs: Consider duties, taxes, trade measures, and new compliance costs alongside the freight rate.
How NKR Freight Supports UK Customs Clearance
NKR Freight combines international transportation with customs support rather than treating clearance as a separate final-stage activity. Across its freight services, NKR describes an in-house customs operation covering:
- CDS customs declarations
- HS-code classification
- Import duty calculations
- VAT handling
- EORI support
- Customs documentation
- Cargo release
- UK final delivery
This is particularly useful for businesses importing from markets such as China, Pakistan, India, Turkey, and other international sourcing locations where customs planning needs to connect directly with the freight movement itself. For example, learn more about our dedicated air freight services from Pakistan to the UK.
Customs Compliance Starts Before the Border
One of the most expensive customs problems is discovering missing or inaccurate information after cargo has already arrived. Storage, demurrage, missed delivery slots, and supply chain disruption can turn a documentation problem into a major operational cost.
The better approach is to review compliance before the shipment leaves its origin. With CBAM approaching on 1 January 2027, UK importers have an additional reason to understand exactly what they import, how those goods are classified, and what information their suppliers can provide.
Importing Commercial Cargo Into the UK?
NKR Freight provides international air, sea, road, and multimodal freight together with in-house UK customs support.
Speak to NKR Freight before your next shipment to review the freight movement and customs requirements together.
Frequently Asked Questions
01. What is UK CBAM?
The UK Carbon Border Adjustment Mechanism is a new tax on embodied emissions in specified carbon-intensive goods imported into the UK. It starts on 1 January 2027 and initially covers specified products in the aluminium, cement, fertiliser, hydrogen, iron, and steel sectors. See the GOV.UK CBAM collections for official details.
02. What is the UK CBAM registration threshold?
HMRC uses a £50,000 threshold for qualifying CBAM goods. Both expected imports within the next 30 days and qualifying imports over the applicable previous 12 months can determine when a business becomes liable to register. Check the GOV.UK guidance on CBAM registration dates.
03. Do I need to keep CBAM records from January 2027?
Yes. Businesses importing CBAM goods need to retain required records relating to qualifying imports from 1 January 2027, generally for six years. Refer to the GOV.UK guidance on keeping CBAM records.
04. Does CBAM replace normal customs clearance?
No. CBAM is an additional tax and compliance requirement. Normal customs declarations, commodity classification, valuation, origin, and other import requirements continue to apply.
05. Do EU imports into Great Britain need an Entry Summary Declaration?
Yes. Entry Summary Declaration requirements have applied to EU imports into Great Britain since 31 January 2025, unless a specific waiver applies. Read more about what safety and security declarations are and why we have them.
06. Who is responsible for an Entry Summary Declaration?
HMRC states that the carrier or haulier is legally responsible. Another party may submit the declaration on its behalf, but the carrier retains responsibility for ensuring it is submitted. See the GOV.UK guidance for importers on safety and security.
07. Does NKR Freight handle UK customs clearance?
Yes. NKR Freight states that its in-house customs team handles CDS declarations, commodity classification, and other UK import formalities across its international freight services. Explore our air freight from Pakistan to the UK to see how we integrate customs support with freight.
08. When should importers start preparing for CBAM?
Businesses importing potentially affected products should begin reviewing commodity codes, import values, supplier information, and record-keeping processes during 2026, before CBAM takes effect on 1 January 2027. Review the latest GOV.UK CBAM guidance to stay updated.