On 18 December 2023, the UK government announced its plan to introduce a UK CBAM by 2027 (see our previous alert) and mentioned that they will conduct consultations in 2024 to finalize details. The UK government followed through its plan and opened consultations on 21 March 2024. (see here) Interested parties can submit their response via online until 13 June 2024.  

• Consultation period: 21 Mar ~ 13 June 2024 (12 weeks)
• Questions: Interested parties can submit their response to 41 questions online. Questions concern the application of the UK CBAM, calculating of the UK CBAM liability, and administration, payment and compliance of the UK. 
• Next steps: After the consultation, the UK government will analyse responses and will prepare primary legislation which stakeholders will have an opportunity to comment on. Primary legislation and any necessary secondary legislation will then be brought forward ahead of the start of the UK CBAM in 2027. 

The UK’s plan to introduce its own CBAM is its response to the EU CBAM. It will be important for interested stakeholders to provide input and closely monitor the development of the UK CBAM and its differences with the EU CBAM. 

EU CBAM: The EU CBAM has been being implemented from October 2023. During a transition period (1 October 2023 ~ 31 December 2025), EU importers have to comply with reporting requirements, but do not need to purchase CBAM certificates yet. Once CBAM is fully in place from 2026 onward, EU importers will be obliged to purchase CBAM certificates. (See our previous alert here)

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Any questions? Please do not hesitate to contact Reed Smith. With our deep understanding of environmental and customs/trade law, we are uniquely positioned to help businesses understand the EU/UK CBAM as it develops, assess the risk and impact on business operations, and provide practical solutions.