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ARTICLE · 20 JANUARY 2026

CBAM-Boozled? Navigating The UK CBAM Policy Updates

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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Herbert Smith Freehills Kramer LLP

Herbert Smith Freehills Kramer LLP

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The UK CBAM has been under development since the UK Government announced its intention to introduce a CBAM in December 2023.

United KingdomEnergy and Natural Resources
Silke Goldberg
Silke Goldberg
Jannis Bille
Jannis Bille
Zoe Asher
Zoe Asher
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Background

The UK CBAM has been under development since the UK Government announced its intention to introduce a CBAM in December 2023.

In April 2025, the UK Government published draft primary legislation for the UK CBAM (for more detail on this, see our blog post here). This was reviewed in a technical consultation which closed in July 2025, and to which a response was published on 26 November 2025 (the Consultation Response). As part of the Government's 2025 Budget announcement, it confirmed that it will legislate in the Finance Bill 2025-2026 to implement the UK CBAM on 1 January 2027. For more detail on the Budget and its overall impact on infrastructure investment, read our update here.

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