UK CBAM and EU CBAM: what is in scope where

Published 14 September 2026

A producer selling into both markets, or an importer with a UK and an EU entity, asks one question first: is this code in scope there too? The answer is usually yes, and the exceptions are few enough to list. This guide sets the two lists side by side and says where each side's answer comes from.

Where each answer comes from

The EU list is Annex I to Regulation (EU) 2023/956, which applies the mechanism to goods under the CN codes it sets out, grouped under cement, electricity, fertilisers, iron and steel, aluminium and chemicals. We read it from the consolidated act as held.

The UK list is set by Schedule 16 to the Finance Act 2026, the enacted text, and published by HMRC as the list of goods in scope of the UK CBAM, dated 16 July 2026. We read both on 11 August 2026 and encoded them as a rule table, not as a list of answers, because the UK publishes scope at heading level with "Except" carve-outs and states the reading rule itself: a code not listed is in scope if it falls under a listed heading, the example being 7601 1090 00 under 7601, and products carved out are listed starting with the word "Except". The two UK authorities agree entry for entry, forty-one entries in scope and thirteen carve-outs. UK CBAM applies from 1 January 2027.

The five sectors both lists cover

• Iron and steel. Both lists take agglomerated iron ores and concentrates other than roasted iron pyrites (2601 12) and the whole of chapter 72, and both carve out 7204, ferrous waste and scrap, along with the ferro-alloys 7202 30, 7202 50, 7202 70, 7202 80, 7202 91, 7202 92, 7202 93 and 7202 99 10, 7202 99 30, 7202 99 80. One carve-out differs: the EU excepts 7202 2, ferro-silicon, as a whole, while our rule table records the UK carve-out at 7202 21, so 7202 29 sits outside the EU list and inside the UK one as we hold it. Both then list 7301 to 7311, 7318 and 7326.
• Aluminium. Both list 7601 and 7603 to 7614 and 7616. Neither lists 7602, aluminium waste and scrap, or 7615.
• Fertilisers. Both list 2808 00, 2814, 2834 21, 3102 and 3105, and both carve out 3105 60.
• Cement. Both list 2507 00 80 and the 2523 headings: 2523 10, 2523 21, 2523 29, 2523 30 and 2523 90. On the EU side the 2507 entry is an "ex" code, kaolinic clays other than non-calcined, following the amendment to Annex I.
• Hydrogen. Both list 2804 10.

Set beside each other, then, the two lists name the same headings in the five sectors they share, and the same carve-outs but one. Apart from ferro-silicon, a code in scope on one side is, on the lists as read, in scope on the other.

The one sector the EU lists and the UK does not

The EU list has an electricity section, 2716 00 00, electrical energy. The UK list has no electricity sector. An electricity importer into the EU is inside the mechanism; the UK list as published does not reach electricity at all.

What this comparison does not say

It is a comparison of scope, nothing more. It says nothing about rates, benchmarks, default values, prices or procedures on the UK side, because we hold no UK authority for any of those and will not state a figure without one. Our guide to the EU calendar and our guides to the EU rules are EU-only for the same reason.

It is also proven in one direction only. Every one of the five hundred and seventy CN codes our tools hold resolves to UK scope under the rule table, none outside and none ambiguous. We have not proven the converse, that we hold every code the UK covers, because the UK covers whole headings and establishing that needs the full nomenclature, which we do not hold. So our lookup answers for the codes it holds and does not present itself as a UK scope checker for codes outside them.

Where to check a code

Our CN lookup shows both regimes for any code it holds: the EU answer from Annex I, the UK answer from the rule table with the heading or carve-out that decided it, and the two UK authorities with the date we read them beside it. If the UK list changes, the lookup's answer changes with the rule table, and the read date tells you how current it is.

Sources: Regulation (EU) 2023/956 Annex I, as consolidated. UK scope: Finance Act 2026 (c. 11), Schedule 16, as enacted, and HMRC, "Check which goods are in scope of Carbon Border Adjustment Mechanism (CBAM)", published 16 July 2026, both read on 11 August 2026 and encoded in our rule table; the UK texts are not reproduced here.