Actual emissions or default values?

UK CBAM liability will use the emissions embodied in the imported good. Current policy gives the liable person two routes: independently verified actual emissions data from the producer, or a government default emissions value.

Route 1: actual emissions data

Actual data is intended to describe the direct emissions created in producing the CBAM good within the relevant system boundary. The importer needs the emissions intensity from the producer, expressed in tonnes of carbon dioxide equivalent per functional unit.

For many goods the functional unit is a tonne of goods under the same commodity code. Cement and fertiliser have specific composition-based rules. Complex goods may also include emissions from relevant precursor goods.

Actual data needs qualifying verification

HMRC’s policy summary says the figure must be verified by a qualifying verifier. The verification report identifies the installation, operator and verifier, the emissions data checked and the verifier’s opinion. A verification summary may contain the good-specific result.

HMRC’s record guidance says to retain the relevant verification report or summary for six years. If the actual data is unavailable, or there is no evidence that it has been verified, a default emissions value must be used.

Route 2: default emissions values

The government will publish one default value per CBAM good before the mechanism starts. Defaults allow an importer to meet the reporting requirement when verified actual data cannot be obtained.

At this rules snapshot, HMRC says the values and further detailed guidance are still to be published. Do not use a guessed factor, a corporate carbon factor or an EU value as if it were the UK default.

The route can differ by good

Keep the basis at transaction or goods level. Some producers may provide verified actual information while others cannot. HMRC’s policy also contains specific rules for combining actual and default information for precursor goods, so complex products should be reviewed carefully.

Information to collect before deciding

1. Identify the good. Record the 8-digit commodity code, description, net weight and producer.
2. Ask the producer. Request emissions intensity, functional unit, monitoring period and installation details.
3. Check verification. Obtain the report or summary and identify the verifier rather than relying on a “verified” label.
4. Record the basis. Mark actual verified, default required or still under review, with the evidence reference.