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ARTICLE · 11 AUGUST 2025

HMRC Publishes Draft Primary Legislation For UK CBAM

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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On 24 April 2025, HM Revenue & Customs (HMRC) published draft primary legislation for the UK Carbon Adjustment Mechanism (CBAM), alongside a policy update and a technical consultation.

United KingdomEnergy and Natural Resources
Silke Goldberg
Silke Goldberg
Jannis Bille
Jannis Bille
Zoe Asher
Zoe Asher
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On 24 April 2025, HM Revenue & Customs (HMRC) published draft primary legislation for the UK Carbon Adjustment Mechanism (CBAM), alongside a policy update and a technical consultation. In this briefing, we summarise the key provisions of the draft UK CBAM.

Background

On 18 December 2023, the UK Government announced its intention to implement a UK CBAM by 2027 as part of its response to a consultation on "addressing carbon leakage risk to support decarbonisation" (Carbon Leakage Consultation). A further consultation in relation to the specific mechanics and proposals for the UK CBAM ran from March to June 2024 (CBAM Consultation) with the response published on 30 October 2024. The Carbon Leakage Consultation and CBAM Consultation both followed in the wake of the EU CBAM, which entered into application in its transitional phase on 1 October 2023 (see our previous post for further background). On 26 February 2025, the EU Commission proposed significant changes to the

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