UK CBAM 2027: what Moroccan and African exporters must prepare

What is the UK CBAM and what changes on 1 January 2027?

The UK CBAM is a UK tax on the direct emissions embodied in certain imported goods. It was created by Part 5 of the Finance Act 2026, which received Royal Assent on 18 March 2026, and it applies to goods imported from 1 January 2027. The rate, published by the government at the start of each quarter, reflects the carbon price paid by UK manufacturers under the UK Emissions Trading Scheme (UK ETS), adjusted for free allowances.

The rules for calculating and verifying emissions sit in the Carbon Border Adjustment Mechanism (Emissions and Verification) Regulations 2026 (SI 2026/995), made on 8 September 2026 and in force on 1 January 2027. If you already supply EU buyers under the EU CBAM definitive period, the logic will feel familiar; the mechanics differ.

Which goods and commodity codes does the UK CBAM cover?

Five sectors are in scope: aluminium, cement, fertiliser, hydrogen, and iron and steel. Within each, only goods whose commodity code appears on HMRC’s lists are taxed; aluminium and iron and steel scrap are excluded. The importer’s return uses the 8-digit commodity code in force at the time of import.

For a fertiliser producer in Morocco or elsewhere in Africa, HMRC’s list covers ammonia (2814), nitrogenous fertilisers (3102) and fertilisers containing two or three of nitrogen, phosphorus and potassium (3105), except subheading 3105 60, which contains only phosphorus and potassium. For cement and fertilisers, emissions intensity is calculated per tonne of clinker or per tonne of nitrogen contained, then converted per tonne of imported product. The scope may still grow: a consultation on adding refinery products is open until 20 January 2027.

Who is affected in Morocco, Africa and among UK buyers?

The person liable is the importer: the person in whose name the import declaration is made, whether established in the UK or elsewhere. If you sell delivered duty paid and the declaration is made in your name, that is you. Otherwise your UK buyer pays, and you only enter the system if you choose to send it your emissions.

The threshold is measured by value, not tonnage. An importer is in scope if it expects to import £50,000 or more of in-scope goods in the next 30 days, or has reached that amount over the previous 12 months. It keeps records from 1 January 2027, registers with HMRC from 1 January 2028, by 31 January 2028 for the first year, and files its first annual return, with payment, by 31 May 2028 for its 2027 imports. Periods then become quarterly.

For cement, fertiliser, steel and aluminium producers in Morocco and across Africa that sell to UK buyers, the question mirrors the EU CBAM: will your buyers report your actual emissions or a default value? Carbon price relief requires a recognised scheme. HMRC’s provisional list, published on 27 August 2026 and not exhaustive, includes the South Africa Carbon Tax but no Moroccan scheme; even for a listed scheme, relief depends on the effective carbon price paid, after free allowances and rebates. No jurisdiction is currently exempt.

Default values or actual emissions: what will your buyer report?

Without verified actual emissions, your buyer uses the default values HMRC published on 16 October 2026. Unlike the EU CBAM, there is no table per country: each good has a single value, whatever its origin, in tonnes of CO2 equivalent per tonne. Timing matters: a return filed with default values cannot later be amended with actual emissions.

To use your actual emissions, your buyer reports a verified emissions intensity based on one calendar year:

• for goods imported in 2027: your verified 2027 data or, failing that, your verified 2026 data;
• for goods imported from 2028: the most recent verified data from the two preceding calendar years;
• in all cases, the buyer may instead use the year in which the good was produced.

You give the buyer either the full verification report or the summary for the good it imported; the buyer keeps it for 6 years.

Is an EU CBAM verification report enough for the UK CBAM?

No, not as it stands. SI 2026/995 requires a verifier independent of the importer, of your installation and of the installations producing your precursors, accredited for the type of good by an accreditation body that is a full member of the Global Accreditation Cooperation Incorporated. The verifier issues a report for each monitoring period, with an opinion on whether the data are accurate enough.

According to HMRC’s policy summary, updated on 2 November 2026, accreditation covers ISO 14065:2020 among other requirements, the verifier makes a physical site visit, and the materiality threshold is 5% of the good’s emissions intensity. The UK methods are designed to support interoperability with the EU CBAM, so one data collection can serve both, but plan a separate UK CBAM report and ask your verifier whether it is accredited for both schemes.

What should you do before 1 January 2027 and during 2027?

1. Now: map your UK sales. List goods by commodity code, match them against HMRC’s lists and identify, for each flow, who the importer is.
2. Before 1 January 2027: ask each UK buyer. Will it exceed £50,000? Does it want your actual emissions or the default value, and by when?
3. Throughout 2027: monitor under UK rules. Define the installation and processes using HMRC’s system boundaries document, which follows the UK ETS, and link every figure to its evidence.
4. In the first quarter of 2027: choose the verifier. Check its UK CBAM accreditation for your goods and schedule the site visit.
5. Before 31 May 2028: deliver the report or summary. Your buyer files its first return by that date; without your verified data, it will report the default value, with no way back.