This week the Government has announced that firms are to be freed from ‘pen-pushing paperwork’ and costly red tape in a business reporting overhaul aimed at saving businesses more than £450 million per year. It will be interesting to see if the statement that “today’s rules are too complex and burdensome for every business, from multinational companies to the removals firm down the road” translates into a reduction in Green Laws, Red Tape and Green Laws Galore.
One can live in hope, but it seems unlikely, not least since the Government is now seeking to introduce a new Carbon Border Adjustment Mechanism (CBAM) from the beginning of next year. A summary of its complex provisions can be found here.
If one believes in the need to reduce consumption (as opposed to territorial) greenhouse gas emissions, then the theory behind the CBAM makes sense of a sort:
CBAM…will ensure highly traded, carbon intensive products from jurisdictions outside the UK face a comparable carbon price to that paid by UK manufacturers, so that UK decarbonisation efforts lead to a true reduction in global emissions rather than simply displacing carbon emissions overseas.
This goes to the heart of one of the main criticisms of the UK’s Net Zero drive – that to date it has in large part failed to reduce emissions overall, since its effect has largely been to export them (along with jobs, industry and wealth) to countries with lower environmental and human rights standards.
So far, then, perhaps so good. However, to describe the CBAM and its implementation as complex and bureaucratic would be a massive understatement. The summary runs to nine very lengthy sections with an annex. Calculating an importer’s CBAM liability involves eight steps:
1. Identify the monitoring period for the CBAM good. This monitoring period is 1 calendar year.
2. Use verified emissions data from that monitoring period to identify the amount, in tonnes, of relevant emissions emitted by the installation in the production of that type of CBAM good during the monitoring period. This step requires the use of the System Boundaries Document and monitoring methodology set out in force of law notices to attribute the installation’s emissions to the CBAM good.
3. Where amounts of relevant emissions identified in step 2 are not amounts of carbon dioxide, convert them into an amount of carbon dioxide equivalent. Nitrous Oxide is multiplied by 265; tetrafluromethane (CF4) is multiplied by 6,630; Hexafluoroethane (C2F6) is multiplied by 11,100.
4. Add together all amounts from steps 2 and 3 to produce a total amount, in tonnes, of carbon dioxide equivalent.
5. Where the CBAM good comprises precursor goods, add precursor emissions for that CBAM good to the emissions already calculated (per step 4).
6. Identify the amount in weight of the CBAM good produced by the installation during the monitoring period.
7. Calculate the emissions intensity by dividing the total tCO2e (per step 5) by the weight of goods produced within a monitoring period (per step 6), rounded to 5 decimal places.
8. Multiply the emissions intensity by the amount of the CBAM good imported into the UK.
The process doesn’t end there. An appropriate verifier must be appointed to verify the data. The verifier must be accredited by an eligible accreditation body for CBAM. Verifiers must also be accredited for the correct scope of activities. For example, a verifier who has been accredited for the activity group corresponding to the production of urea and mixed fertilisers would not automatically be eligible to verify emissions released at an installation producing iron and steel products.
The verification process is described at significant length, but then we’re told that:
Whilst it is preferable for the liable person to use independently verified actual emissions data, default emissions values will also be available to determine the embodied emissions in CBAM goods. This means the liable person can meet CBAM obligations when actual emissions data is unavailable. Default emissions values can also be used for precursor goods, even where actual emissions data is used for the final CBAM good. However, actual emissions data cannot be used for precursor goods if default emissions values are used for the final CBAM good.
From 1 January 2027, there will be one default emissions value set per CBAM good. Default emissions values will be published in a notice on GOV.UK in advance of CBAM coming into force.
CBAM rate calculation
The calculation is comprised of 3 elements:
- The average ETS price, calculated as the mean average of all UK ETS auction clearing prices for the relevant quarter. In a scenario where all ETS auctions fail to clear in a given quarter, the last positive average ETS price will be used.
- The free allocation adjustment, which is calculated as 1 minus the average proportion of sectoral direct emissions covered by Free Allocations (FAs), multiplied by a reduction factor. This average is determined by using UK ETS baseline data reporting data related to the average sectoral direct emissions generated in 2019, 2022 and 2023 by sub-installations producing CBAM goods, and average Fas allocated to those same sub-installations over the same period. Years will be discounted if there were no direct emissions for that sector. The reduction factors will reflect the reduction factors applied to phase out Fas under the UK ETS.
- The final output is the CBAM rate for the given sector for that quarter.
But then there’s carbon price relief: the liable person can claim carbon price relief (CPR) which will reduce their CBAM liability if the embodied emissions in the CBAM goods they have imported have been subject to a qualifying carbon pricing scheme and they have the necessary verification documents, such as the carbon pricing verification form, as well as other relevant information, to calculate the amount of CPR. This includes where a CBAM good has been subject to more than one qualifying carbon pricing scheme and produced in more than one installation within the same jurisdiction.
The total relief claimed cannot exceed the amount of CBAM liability due.
It’s all as clear as mud, and filling in the associated paperwork must be like wading through mud. And who has to wade through that mud? All but the very smallest of import businesses:
A person must register with HMRC for CBAM if they meet or exceed the minimum registration threshold. The minimum registration threshold considers the total value of CBAM goods that are imported or are expected to be imported into the UK over a given period as set out in the 2 tests below. The value is set at £50,000.
That’s less than the annual turnover threshhold for VAT registration in the UK.
The above notes regarding the bureaucracy involved in all this barely scratches the surface. If you’re interested, I urge you to visit the relevant government website. I provided an embedded link above, but for ease of access, it’s here.
EU CBAM
Also, whatever one’s personal view as to the merits or demerits of Brexit, this does seem to be a case of the UK government simply continuing to behave as though the UK never left the EU. In large measure, the UK CBAM replicates (albeit one year later) the EU’s CBAM. This replication is obvious when one looks at the goods to be covered by CBAM, or rather goods within these sectors: aluminium; cement; fertiliser; hydrogen; and iron and steel. The reasoning seems to be that these are “carbon-intensive” sectors – or it may simply be that these are the sectors covered by the EU’s CBAM, and it was easier (especially for a government keen to re-establish close ties with the EU) to do what the EU has already done.
As the EU’s CBAM has been in operation since the beginning of this year, I asked AI how it was going. As is usual, it responded with a reply that was on-message, having trawled the websites seeking to claim it as a shining success. So I decided to push AI a little, and challenge its quick and easy answer by asking:
Leaving aside the pro-CBAM propaganda from the EU and its acolytes, how successful has it really been? Doesn’t the EU have a massive – and growing – trade deficit with China?
That prompted a very different answer, which I reproduce below in its entirety:
Stripping away the institutional optimism, looking closely at the real-world metrics reveals that the European Union faces deep structural trade imbalances, and the early months of the definitive CBAM phase have exposed significant friction.
The EU-China Trade Deficit: A Widening Chasm
Yes, the EU has a massive and growing trade deficit with China. The numbers confirm this imbalance is a severe macroeconomic headache for Brussels:
The Record Deficit: The EU’s goods trade deficit with China reached €359.9 billion.
Escalating Trajectory: Far from shrinking, the deficit widened by another 9% in the first half of 2026. The gap is averaging a staggering €1 billion a day, prompting EU Trade Commissioner Maroš Šefčovič to warn that the massive gap is “unsustainable” and could trigger broader trade defense measures.
The Tariff Deflection Factor: A primary driver of this growing deficit isn’t actually CBAM. Following the escalation of US-China trade tensions, heavily subsidized Chinese industrial output has been deflected away from the US market directly into Europe’s open consumer market of 450 million people.
The Harsh Reality of CBAM’s “Success”
When evaluated strictly against the claim of a frictionless rollout, CBAM reveals several major structural flaws:
1. It Misses the Bulk of Chinese Imports
Critics point out that CBAM is currently a drop in the ocean regarding the total trade deficit. In its current phase, CBAM only covers specific raw commodities (steel, aluminum, cement, fertilizers, hydrogen, and electricity). These goods account for only about 1.8% of China’s total exports to the EU. The actual drivers of the trade deficit—finished electronics, machinery, solar panels, and electric vehicles—are not yet covered by CBAM.
2. The Verification Nightmare
The EU claimed the transition to the financial phase went smoothly, but the reality on the ground is a data verification bottleneck. Importers are struggling immensely with Measurement, Reporting, and Verification (MRV) compliance. Reconciling China’s domestic carbon accounting with the EU’s strict embedded-emissions methodologies has created major bureaucratic friction. Importers are trapped using punishing “default values” that over-estimate carbon content, driving up immediate costs.
3. Self-Inflicted Economic Harm (The Fertilizer Crisis)
The mechanism is drawing intense internal fire because it acts as an import tax on European industries. For example, the tax on imported nitrogen fertilizers has caused significant pushback from farming groups. European lawmakers are currently locked in fierce debates over whether to remove emergency safeguards that would prevent CBAM from driving up domestic food and agricultural costs, leading critics to argue the policy is penalizing European businesses more than foreign polluters.
4. The Clean Export Laundering (“Resource Shuffling”)
Foreign manufacturers are already finding loopholes. Instead of fundamentally decarbonizing their entire supply chains, international conglomerates are simply “shuffling” their resources—allocating their limited supply of green-energy manufacturing exclusively to EU-destined exports, while continuing to dump coal-heavy, high-emission production into domestic markets or less regulated regions. The global net reduction in emissions is thus far less than advertised.
Ultimately, while the EU has successfully built the bureaucratic machinery to collect the tax, calling CBAM an absolute “success” ignores its current inability to dent the broader trade deficit, the severe operational compliance costs it inflicts on EU importers, and the rising domestic inflation it threatens to trigger.
Conclusion
There the AI reponse ends. I’m not kidding myself – with a little judicious prodding and goading, AI can be persuaded to write pretty much whatever it “thinks” its interlocutor wants to read. Nevertheless, its amended response does mention a whole load of issues, that suggest that the EU version of CBAM (which the UK version will largely replicate) has to date proved to be highly problematic – costly, inflationary, bureaucratic, and of limited efficacy. It might have been a good idea for the UK government to watch and wait, to see how things pan out with the EU version of CBAM before rushing to join in. It might have been a good idea to contemplate a meaningful but simple version of CBAM before rushing forward with Net Zero plans and the associated expensive renewable energy that has crippled UK manufacturing and driven jobs, wealth and manufacturing abroad, mostly – but not exclusively – to China. At least then UK industry might have stood a chance when the costs of energy-intensive industries were hiked. Instead, this looks like a sorry attempt, too little too late, to do any good. It seems guaranteed to increase bureaucracy and to fuel domestic inflation. I might be wrong, of course, and we will have to wait and see. But that, I suggest, is what the UK government should have done regarding the EU version of CBAM before rushing to follow suit.
Mark,
You’ve done my head in. 😦
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John,
I think it’s the government that did that. I am merely a humble messenger. 😊
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The CBAM was in both branches of the Uniparty’s manifestos. So it was inevitable that it was going to turn up.
The choice of imports to levy the tax on is rather absurd, as we have no home grown alternatives for several. It also admits that doing things the good old carbon way is cheaper, unless you make it artificially more expensive with yet more taxes.
No CBAM can benefit UK businesses, since it is entirely one-sided. It will inevitably lead to inflation (the present crop appear to have inflation as a political goal, to judge by the things they are doing).
I do not know the answer to the question of how to prevent the Chinese car industry from eliminating what is left of the UK’s.
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I have several problems with this CBAM, as alluded to or hinted at in my piece. In brief:
It represents shutting the stable door after the horse has bolted. Any intelligent person could have worked out that re-engineering our grid to accommodate widely dispersed renewables would make UK electricity significantly more expensive. The intelligent thing to have done would have been to introduce a CBAM then, to protect UK industry from the cheaper competition it would face from abroad, most obviously from China.
The irony is that we probably didn’t do that at the time because we were then in the EU, and EU free trade rules prevented us from doing it.
Now, however, the EU has woken up (too late) to the damage that unfettered free trade, combined with higher energy prices (stemming from net zero energy policies) has caused. And so, because it has introduced a bureaucratic and problematic CBAM, the UK decides to do the same (even though we now have the freedom to adopt different trade policies).
The CBAM is limited in scope, but massively complex and bureaucratic, adding greatly to the burdens of those businesses affected by it. It is likely to fail in its primary purpose and to push up domestic inflation.
It would have been much wiser to give the EU CBAM two or three years to bed in, to see whether it was proving to be beneficial or damaging. But it appears that cosying up to the EU (even though we have left it) trumps all other considerations.
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As I understand it this is what’s happening:
CBAM is being introduced because the Government intends that ‘UK decarbonisation produces a true reduction in global emissions rather than simply displacing carbon emissions overseas’. ** In other words, we’ve made our own industry more expensive (by means of the Emissions Trading Scheme (ETS)) so as to reduce emissions. But we don’t want that to give importers an opportunity to undercut domestic industry (i.e. via so-called ‘carbon leakage’). And therefore we’re making imports more expensive as well by introducing this extraordinarily complex mechanism.
Essentially it’s all about reducing global emissions. The key question therefore is this: does the ETS produce a worthwhile reduction in global emissions? If it doesn’t this whole shebang is an elaborate and costly waste of time. And I suspect it may not. For example any reductions will be minute in a global context and hardly justify the policy’s damaging economic costs. And it might even increase global emissions – for example increased steel cost means more expensive UK car manufacture which means more carbon heavy Chinese imports.
A better solution therefore might well be to abandon ETS (and thus CBAM) altogether.
** https://www.gov.uk/government/publications/introduction-of-carbon-border-adjustment-mechanism/carbon-border-adjustment-mechanism?utm_source=chatgpt.com
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Robin,
I agree entirely. From your link, there’s this:
It’s not exactly reassuring.
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And I should have added that common sense and logic suggest discontinuing the ETS would be in order. Maintaining the ETS and adding CBAM to it simply compounds the problem.
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“bureaucratic” is the word that stood out to me the most. Had to look it up to be sure I understood It’s meaning in this context –
“relating to a system of controlling or managing a country, company, or organization that is operated by a large number of officials: The company was inefficient because it was highly bureaucratic.“
Wonder how many “officials” are rubbing their hands at the prospect.
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I am but a simple soul of average intelligence but I found myself thinking “is this a case of bullshit baffling brains?” I was somewhat relieved to see I am not the only one here that “had my head done in” 🤭😂 So… for those who are much cleverer than I am help me out here.. is the gist of this they are going to tax some things, but not all things, that are made in China specifically, because let’s face it everything pretty much is? The figure of the trade deficit being around a billion pounds a day with China and the EU is eye watering, and worrying but not totally surprising. At the end of the day who will bear the actual cost of this extra tax? I’m guessing ….US 🤨
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koalascrumptiousdcd37e26d1,
Hole in one!
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Catherine McBride has written a good article on this – and other dire obligations which we are moving to take on as part of our “reset” with the EU.
Her example of the impact on ammonia prices highlights the craziness:
“The most ridiculous example of the UK applying the EU’s CBAM is in Anhydrous ammonia. Anhydrous ammonia is an essential ingredient in fertiliser production. The UK no longer makes Ammonia, although it used to both make it and export it as recently as 2022. Now the UK imports about 350,000 tonnes of ammonia, almost exclusively from countries with cheap gas, as ammonia is made from methane (natural gas). In 2025, the US supplied about a third of the UK’s ammonia imports, as it was the UK’s cheapest supplier. Joining the EU’s CBAM would have increased the import price of US Ammonia by about a third in 2026 and pushed up the price of the UK’s more expensive suppliers by between 10% and 14%. This is insane. The UK needs fertiliser; fertiliser needs ammonia; ammonia is made from gas; the EU doesn’t have much gas; both the UK and the EU have to import ammonia to make fertiliser, but both are increasing the cost of importing something neither makes. Why does anyone think this is a good idea?”
Full article: https://catherinemcbride.substack.com/p/the-eu-energy-reset-is-unnecessary?publication_id=1862615&post_id=215016316&isFreemail=true&r=219jpi&triedRedirect=true
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So, in summary:
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In a democracy, voters need to know what they’re voting for. The government thinks CBAM is terribly important, and a success. I therefore suggest that voters should be forced to listen to a reading of this article on the main evening news. I guarantee that by the time the newsreader got to:
“Hexafluoroethane (C2F6) is multiplied by 11,100. Add together all amounts from steps 2 and 3 to produce a total amount, in tonnes, of carbon dioxide equivalent. Where the CBAM good comprises precursor goods, add precursor emissions for that CBAM good to the emissions already calculated (per step 4).”
there would be riots in the streets – or mass suicide.
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“CBAM! A punch to the face of British business
The carbon border adjustment mechanism (CBAM) is just another tariff on imported materials, many of which are essential inputs for UK industry but are no longer made in the UK.”
https://gbbc.uk/cbam-a-punch-to-the-face-of-british-business/
Well worth a read, even if you get no further than the executive summary, which is depressing enough (but nevertheless very enlightening).
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Thank you Mark. I think. I’ll read the whole thing. Call it a penance. Meanwhile, I excerpt this from the summary:
Surely there must be some mistake. Gas is priced internationally, and drilling our own gas would not lower bills. That’s what Minitrue told me via its prominent position on social media platforms. I didn’t see any comments disputing it, either.
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It’s worse than we thought!
Catherine McBride put out another article a few days ago on the TWO systems which loom on the horizon – the EU version and our own effort (due to come into force in 3 months’ time):
https://catherinemcbride.substack.com/p/a-tale-of-two-cbams
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