CBAMReturn

UK CBAM guide

Which goods does UK CBAM cover? The five sectors in detail

The statutory commodity-code list sector by sector — including the products importers miss (fasteners, aluminium structures, nitric acid) and what's excluded (scrap, most ferro-alloys).

Last reviewed 4 July 202611 min readRules basis: Finance Act 2026 (enacted) plus HMRC draft regulations (Feb–Apr 2026)

UK CBAM applies to a statutory list of commodity codes, not to sectors in the abstract. Whether you are caught — and whether a given import line counts towards the £50,000 threshold — comes down to the 8-digit codes on your customs entries. This guide walks the list sector by sector, with particular attention to the edges: the downstream products importers don't expect to be covered, and the exclusions that genuinely help.

Iron & steel — the widest net

The list covers essentially the whole of tariff chapter 72 (iron and steel — pig iron, ingots, bar, rod, sheet, plate, coil, wire, sections, rail) plus a long run of chapter 73 products: tubes and pipes (7301–7311), and — the ones that surprise people — screws, bolts, nuts, washers and other fasteners (7318) and other articles of iron or steel (7326), a residual heading that sweeps in a huge range of fabricated items. Agglomerated iron ores and concentrates (2601 12) are also listed as precursor material.

Excluded, by name: ferrous waste and scrap and remelting scrap ingots (7204), and most ferro-alloys (ferro-silicon, ferro-silico-manganese and others under 7202). If your metal imports are genuinely scrap, CBAM likely isn't your problem — but check the codes, because remelt products and downstream goods still count.

Who gets caught here: steel stockholders, fabricators, construction-products distributors, engineering firms importing components — and any manufacturer whose bill of materials includes imported fasteners. A fastener importer doing £60,000 a year is in scope; many have no idea.

Aluminium — watch the finished articles

Unwrought aluminium (7601), and wrought products across 7603–7614: powders, bars, profiles, wire, plates, sheets, foil, tubes, pipes and fittings. Then the downstream sweep: aluminium structures and parts — doors, windows, frames (7610) — reservoirs and tanks (7611–7612), containers, stranded wire and cables (7614), and other articles of aluminium (7616), another broad residual heading.

Excluded: aluminium scrap (7602) is simply not on the list.

Who gets caught: glazing and curtain-walling firms, shopfitters, distributors of profiles and sheet, packaging businesses importing foil, electrical wholesalers importing cable with aluminium conductors.

Cement — including the inputs

Portland cement, aluminous cement and other hydraulic cements, cement clinker (2523 group), and — easy to miss — calcined or sintered kaolinic clays (2507 00 80). Clinker's inclusion matters: it is the emissions-intensive core of cement, and it is a listed precursor of the cement made from it.

Who gets caught: builders' merchants and construction-materials importers buying bagged or bulk cement from outside the UK.

Fertilisers — the chemistry chain

Nitric acid (2808 00), ammonia (2814), potassium nitrates (2834 21), mineral or chemical nitrogenous fertilisers (3102), and mixed fertilisers under 3105except 3105 60, the purely potassic (PK) fertilisers, which are excluded because the carbon intensity sits in the nitrogen chain, not the potash.

Who gets caught: agricultural merchants and buying groups, horticultural suppliers, chemicals distributors importing ammonia or nitric acid as industrial inputs — not just "fertiliser companies".

Hydrogen — small but listed

Imported hydrogen (2804 10). A thin trade today, but the code is on the list from day one and matters to anyone developing hydrogen supply chains.

Three rules for reading the list

  1. The code decides, not the description. "It's just brackets" is not an answer; 7326 probably covers it anyway. Match your customs entries at 8-digit level against the statutory table — CBAM returns will themselves be filed at 8-digit level.
  2. Precursors count inside complex goods. The charge on a covered good includes emissions from covered precursor materials used to make it (the clinker in cement, the crude steel in your fasteners, ammonia in nitric acid) — that is how emissions arrive embodied in downstream articles. UK-produced precursor content is carved out, so it isn't double-charged.
  3. Electricity is not covered — and glass and ceramics aren't either. Both were considered and left out (glass and ceramics explicitly flagged for possible future inclusion). The EU list differs — it includes electricity — so don't read across from EU CBAM. Scope is reviewed over time; the sensible posture for borderline sectors is watchful, not anxious.

What to do with this

Pull your import data, filter to these chapters, and put a customs value against the covered lines for the last 12 months. That number against £50,000 is your answer — or use the threshold checker for a fast first pass. If you are in scope, the next constraint is time-sensitive: supplier emissions data for 2027 has to be collected during 2027.

Sources

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This guide is general information, not tax or legal advice. It reflects the rules as at the review date shown above — primary legislation is enacted (Finance Act 2026 (enacted)), but HMRC's secondary legislation is still in draft and details may change before 1 January 2027. We track every change and refresh our guides; for decisions about your own liability, take professional advice.