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ARTICLE · 28 SEPTEMBER 2026

Why CBAM Matters For University Estates

Mills & Reeve LLP
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The UK Carbon Border Adjustment Mechanism (CBAM) will impose import levies on carbon-intensive construction materials from January 2027, potentially affecting project costs and supply chains. Higher education institutions planning major estate developments must evaluate whether their budgets, procurement processes, and contractual arrangements adequately address CBAM-related risks and opportunities.

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While the direct obligations under UK Carbon Border Adjustment Mechanism (CBAM) will fall primarily on importers of construction products, the effects are likely to be widespread. Higher education institutions planning major estate projects should therefore consider now whether their budgets, supply chains, sustainability objectives, procurement processes and contractual arrangements are prepared for the changes that CBAM may bring from 1 January 2027.

Background

CBAM will come into force on 1 January 2027 and will apply to certain imported goods, namely aluminium, cement, fertiliser, hydrogen, and iron and steel. It forms part of the UK's wider strategy to support decarbonisation and prevent carbon leakage; where production of carbon-intensive goods shifts to countries with less stringent carbon pricing requirements compared to that borne by UK manufacturers. As many of the products within scope are commonly used in construction projects, the introduction of CBAM may have

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