CBAM Made Clear

From 1 January 2027, steel has a carbon price at the UK border.

UK CBAM taxes the carbon embodied in imported goods, including stainless steel fasteners. Get the essentials below, then join one of our free live CBAM Made Clear webinars to find out what's in scope, who pays and how the cost is worked out.

UK CBAM goes live in
77
Days to go
£50k
Threshold
2028
First return
Starts 1 January 2027Registration opens by Jan 2028
35 years in stainless EcoVadis Platinum ISO 9001:2015 · LRQA BSSA member BIAFD member
What it means for you

Pick your situation

UK CBAM lands differently depending on who imports the goods.

Apex is the importer

Apex holds the UK CBAM liability

The importer named on the customs declaration is responsible for UK CBAM. When you buy from Apex, that importer is Apex.

  1. TodayKeep ordering as normalNothing changes in how you buy from us.
  2. From 2027Understand the cost driversCBAM cost depends on weight, embodied emissions and the UK CBAM rate, not on price.
  3. Any timeAsk our teamWe can explain how we're preparing and what it means for your orders.
You are the importer

UK CBAM applies to you from 1 January 2027

If you're the importer on the customs declaration and import over £50,000 of CBAM goods in a rolling 12 months, you hold the liability.

  1. 2027Keep recordsKeep records for the full 2027 calendar year: weight and embodied emissions.
  2. By 1 Jan 2028RegisterRegistration for UK CBAM will open by 1 January 2028.
  3. 31 May 2028First return and paymentCovering imports from 1 January to 31 December 2027.
Check two things

It depends who is named on the declaration

The importer on the customs declaration is liable once they import over £50,000 of CBAM goods in a rolling 12-month period.

  1. Step 1Check your declarationsWho is named as the importer on the customs declaration?
  2. Step 2Total your CBAM importsIs it over £50,000 in a rolling 12-month period?
  3. Step 3Talk to usOur team can help you work it out.
Which products are in scope?

The facts that matter

Commodity code in scope
7318

Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel.

NutsScrewsWashersAerotight nuts
Also in scope
7326

Other articles of iron or steel. Greenhouse gas: carbon dioxide.

Threshold
£50k

Of CBAM goods imported in a rolling 12-month period.

Sectors in scope
AluminiumCementFertiliserHydrogenIron and steel

Our common CBAM items include, but are not limited to, nuts, bolts, washers and Aerotight nuts. Full list: UK CBAM policy summary.

How is the cost calculated?

Not based on purchase price

UK CBAM is driven by weight, embodied emissions, the UK CBAM rate and any eligible carbon price already paid abroad.

TonnesImported weightTonnes of CBAM goods imported in the accounting period.
tCO₂e per tonneEmissions intensityActual verified data or UK default values.
£ per tCO₂eUK CBAM ratePublished by the government at the start of each quarter.
£ paid overseasCarbon price reliefDeduction for a comparable carbon price already paid on the same goods.
£ per periodCBAM liabilityNet amount payable on the CBAM goods for the accounting period.
UK CBAM rate: published by the government at the beginning of each quarter from 1 January 2027.
Threshold: UK CBAM applies once you import over £50,000 of CBAM goods in a rolling 12-month period.
When does it start?

UK CBAM: major timeline

  1. Jul 2026Policy updateSecondary legislation laid; policy summary updated.
  2. 2027First reporting yearKeep records for the full 2027 calendar year.
  3. By 1 Jan 2028Registration opensRegistration for UK CBAM will open.
  4. 31 May 2028First return and paymentCovering imports from 1 Jan to 31 Dec 2027.
  5. 2028Quarterly cycleAccounting periods move to quarterly returns and payments.
  6. 28 Feb 2029Q4 2028 deadlineFinal quarterly deadline for 2028 accounting periods.

Reporting periods

The first accounting period covers the whole of 2027. From 2028, returns and payments are due quarterly.

Accounting periodReturn and payment deadline
1 Jan 2027 to 31 Dec 202731 May 2028
1 Jan 2028 to 31 Mar 202831 Jul 2028
1 Apr 2028 to 30 Jun 202829 Sep 2028
1 Jul 2028 to 30 Sep 202830 Nov 2028
1 Oct 2028 to 31 Dec 202828 Feb 2029
HMRC CBAM updates

Latest from HMRC

The key UK CBAM publications from HMRC and HM Treasury, in brief.

  1. Force of law notices publishedHMRC has published the CBAM force of law notices and the reference document that goes with them.Read on GOV.UK →
  2. Policy summary updated and new guidance collectionThe CBAM policy summary has been updated, alongside a collection of guidance on what to do if you import CBAM goods into the UK from 1 January 2027.Read on GOV.UK →
  3. Qualifying carbon pricing schemesNew guidance on checking whether the embodied emissions in your goods have been subject to a qualifying carbon pricing scheme, plus a provisional list of current schemes.Read on GOV.UK →
  4. Registration and carbon price relief guidanceGuidance on whether you'll need to register for CBAM, how to claim carbon price relief and how to get a carbon pricing verification form.Read on GOV.UK →

Source: GOV.UK · Last checked 14 Oct 2026

Embodied emissions

Why does a stainless steel bolt carry carbon emissions?

The emissions come from making the product, not from the product itself. They arise along the production chain, from steel production through rolling, wire drawing, forming and thread rolling to heat and surface treatment.

Emissions intensity is the amount of CO₂e embodied in each tonne of goods, measured in tCO₂e per tonne. The higher it is, the higher the potential CBAM cost.

Can a laboratory measure it?

No. CO₂e can't be found by testing the finished bolt.

A test can tell you about the bolt itself:

  • Material grade
  • Carbon content
  • Chromium, nickel and other alloying elements

It can't tell you the emissions released while it was made:

  • Emissions must be calculated from production and emissions data
Free live webinar series

CBAM Made Clear webinars

Concise, free sessions for anyone purchasing, importing or supplying stainless steel fasteners: from what CBAM is and how it could affect pricing, sourcing and supply chains, to the latest UK and EU developments.

Webinar 1 · Thu 12 Nov · 10:30–11:10CBAM explained for fastener buyers
  1. 01What is CBAM?
  2. 02How CBAM affects buying stainless steel fasteners
  3. 03The potential impact on fastener pricing
  4. 04Key considerations for procurement and supply chain teams
Webinar 2 · Thu 10 Dec · 10:30–11:10Latest updates: UK and EU CBAM compared
  1. 01Recent CBAM changes and updates
  2. 02Key differences between UK and EU CBAM requirements
  3. 03Potential implications for businesses and supply chains
  4. 04Guest speaker session (to be announced)
Webinar 3 · Thu 21 Jan · 10:30–11:10CBAM is live: industry reaction and early lessons
  1. 01Latest CBAM changes and updates
  2. 02Industry reaction since implementation
  3. 03Early challenges, opportunities and key learnings
  4. 04Guest speaker session (to be announced)

Choose your session

Microsoft TeamsFree40 minutes eachBook each session separately
  1. Webinar 1: CBAM explained for fastener buyersThursday 12 November 202610:30–11:10 (UK time)
    Book →
  2. Webinar 2: Latest updates: UK and EU CBAM comparedThursday 10 December 202610:30–11:10 (UK time)
    Book →
  3. Webinar 3: CBAM is live: industry reaction and early lessonsThursday 21 January 202710:30–11:10 (UK time)
    Book →
  4. Can't make a session? Sign up for CBAM updates to stay in the loop.
FAQs

Quick answers

Can't find yours? Bring it to a webinar Q&A or speak to our team.

When does UK CBAM start?

UK CBAM comes into effect on 1 January 2027. Registration opens by 1 January 2028, and the first return and payment, covering imports during 2027, is due by 31 May 2028.

Are stainless steel fasteners in scope?

Yes. Commodity code 7318 covers screws, bolts, nuts, rivets, washers and similar articles of iron or steel, and 7326 covers other articles of iron or steel.

Who pays UK CBAM when I buy from Apex?

The importer named on the customs declaration holds the UK CBAM liability. When you buy from Apex, that importer is Apex.

Is UK CBAM based on the price I pay?

No. It is driven by the weight of goods imported, their emissions intensity, the UK CBAM rate and any eligible carbon price already paid overseas.

Is there a threshold?

Yes. UK CBAM applies once you import over £50,000 of CBAM goods in a rolling 12-month period.

Can emissions be measured by testing the product?

No. Emissions arise during production and cannot be determined by testing the finished product. They are calculated from production and emissions data, using actual verified data or UK default values.

Get UK CBAM-ready with Apex.

Apex combines product expertise, supply-chain transparency, emissions data and sourcing support, helping customers manage both cost and carbon.

CBAM Made Clear Webinar 1Thu 12 Nov · 10:30–11:10 · Microsoft Teams · Free

Book