The UK has set out further requirements for calculating and verifying embodied emissions ahead of the launch of its Carbon Border Adjustment Mechanism (CBAM) on 1 January 2027, giving aluminium suppliers a defined framework for preparing production and emissions records.
HM Revenue & Customs (HMRC) updated its policy summary on 9 September, when the latest regulations were laid. The rules cover embodied-emissions calculations, monitoring, verification and supporting documentation for goods within the UK mechanism.
The UK framework applies to specified commodity codes, rather than to every product containing aluminium. Importers using actual emissions must meet the applicable verification requirements, while default emissions values provide an alternative. The methodology also covers emissions embedded in relevant precursor materials.
UK and EU reporting systems retain different requirements
The UK framework is intended to be practically compatible with European emissions reporting, but this does not mean that EU calculations or verification documents can automatically be transferred into the UK system without modification.
Product coverage, reporting procedures and the requirements applying to an individual transaction remain relevant. Suppliers therefore need to assess the evidence required under each regime rather than assume that comparable emissions methodologies create identical compliance obligations.
The difference is also reflected in the financial structure of the two mechanisms. The UK CBAM will operate as a tax, whereas the EU system requires importers to purchase and surrender CBAM certificates.
Registration and liability dates follow separate timetables
The beginning of UK CBAM liability in 2027 is separate from the registration timetable. Official guidance schedules the opening of registration for 1 January 2028.
For producers supplying both the UK and EU markets, the regulatory differences create a requirement to maintain consistent underlying production and emissions information while reconciling that evidence against the requirements of each jurisdiction.
Using entirely separate datasets for the two markets could result in the same production being recorded differently. The September regulations provide greater clarity over the emissions information that must be measured, while suppliers still need to ensure that the resulting records can support compliance under both systems.
