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ARTICLE · 09 MAY 2025

The UK's Carbon Border Adjustment Mechanism Continues To Take Shape

A&O Shearman
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Ahead of the commencement of the UK Carbon Border Adjustment Mechanism (CBAM), key building blocks for its regulatory framework are moving into place.

United KingdomEnvironment
Charles Yorke
Charles Yorke
Matthew Townsend
Matthew Townsend
Brin Rajathurai
Brin Rajathurai
Tom d'Ardenne
Tom d'Ardenne
Ying-Peng Chin
Ying-Peng Chin
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Ahead of the commencement of the UK Carbon Border Adjustment Mechanism (CBAM), key building blocks for its regulatory framework are moving into place. Following consultations in 2023 and 2024, draft legislation and a policy update have now been published which provide further detail on how the CBAM will apply to imports of certain carbon intensive goods into the UK from 2027.

As the government has previously confirmed, from January 1, 2027, the CBAM will be charged on emissions embodied in certain goods when they are imported into the UK. On April 24, 2025, HMRC published draft legislation on the UK's CBAM. This has been published for technical consultation and is not a further policy design consultation but is focused on ensuring the legislation meets the policy intent. The consultation was published alongside a policy update (the "Policy Update") which provides an update on decisions taken by ministers since the October 2024 government response to the March 2024 c

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