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ARTICLE · 26 FEBRUARY 2026

Getting Ready For UK CBAM: Further 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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HMRC last week published a policy summary and technical consultations on draft secondary legislation in respect of the upcoming UK CBAM mechanism, due to come into effect on 1 January 2027.

United KingdomEnergy and Natural Resources
Silke Goldberg
Silke Goldberg
Elizabeth Gadsby
Elizabeth Gadsby
Jannis Bille
Jannis Bille
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HMRC last week published a policy summary and technical consultations on draft secondary legislation in respect of the upcoming UK CBAM mechanism, due to come into effect on 1 January 2027. For more details on the UK CBAM proposals please see our previous blog posts here and here.

These recent publications largely reflect the details previously shared in government consultations and the draft Finance Bill (which will implement the UK CBAM mechanism and is currently making its way through the UK parliament) although the policy summary provides a helpful consolidation of key HMRC positions.

The draft secondary legislation published to date are:

  • The Carbon Border Adjustment Mechanism (Calculation of CBAM Rate and Determination of Carbon Price Relief) Regulations 2026– this sets out further details of the calculation of the average ETS price for the purposes of the CBAM rate for a sector and of the proposed carbon price relief mechanism. In respect of the latter,

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