UK CBAM 2027: What Stoke-on-Trent Makers Must Do

If your business imports steel, aluminium, cement or fertiliser, or exports products containing those materials to customers in the EU, you are already inside the CBAM compliance window. Stoke-on-Trent’s manufacturing base, from ceramics and tiles to metals fabrication, has more skin in this game than the national headlines suggest. The EU Carbon Border Adjustment Mechanism has been fully operational since January 2026. The UK version goes live on 1 January 2027. That deadline is confirmed in UK legislation, and HMRC will enforce it.

I manage supply chains and operational systems for a living. When a new compliance regime lands, the first question I ask is: who actually gets caught by it, and what does the preparation workload look like? Here is the honest answer for businesses in Stoke and across Staffordshire.

What Is CBAM and Why Should Stoke-on-Trent Businesses Care Right Now

CBAM stands for Carbon Border Adjustment Mechanism. The basic idea is this: carbon-intensive goods produced in countries with weaker emissions rules than the EU or UK are now subject to a carbon cost when they cross the border. The intention is to stop what policy-makers call “carbon leakage”, where production simply shifts to countries without carbon pricing.

The term “embedded emissions” is central to understanding your obligations. Embedded emissions means the total greenhouse gas emitted, measured in tonnes of CO2 equivalent, during the entire production process for the goods being imported or exported. If you buy steel from a country with no carbon pricing, those embedded emissions will be higher than equivalent steel produced under a carbon scheme, and the CBAM charge will reflect that difference.

For UK businesses, there are two separate CBAM regimes running at the same time.

The EU CBAM has been fully operational since 1 January 2026. If you export iron, steel, aluminium, cement, fertiliser, electricity or hydrogen to EU buyers, your EU customer is the one making the CBAM declaration, but they need verified embedded emissions data from you, their UK supplier, to do it. That data obligation lands on your desk even if you never deal with EU customs paperwork yourself.

The UK CBAM goes live on 1 January 2027. This is an HMRC-administered tax (not a certificate scheme like the EU version) applied to imports of aluminium, cement, fertiliser, hydrogen, and iron and steel brought into the UK from outside Great Britain. The official HMRC CBAM collection page is the authoritative starting point for understanding your obligations.

Stoke-on-Trent has a particular stake in this. The city’s ceramics sector is its industrial identity. In May 2026, Stoke-on-Trent City Council published a major ceramics industry report calling on government to secure the future of the sector. That recognition matters, because the CBAM story for Stoke is not straightforward, and the nuance is not being covered anywhere.

Which Stoke Businesses Are in Scope: Sectors, Commodity Codes and the £50,000 Threshold

Before you assume CBAM applies to you, or does not, check the specifics carefully.

For the UK CBAM from January 2027, the sectors in scope are: aluminium, cement, fertiliser, hydrogen, and iron and steel. Glass and ceramics were included in the 2024 consultation but were removed from the 2027 launch scope. That is good news for Stoke pottery businesses in the short term, but do not assume it stays that way. The government has reserved the right to add sectors in future reviews.

The £50,000 threshold is the most practical number in this whole policy. If your total imports of CBAM-covered goods over a 12-month period come to less than £50,000, you are not required to register for UK CBAM. For many smaller Stoke manufacturers buying in modest quantities of steel or aluminium, this may be a relief. But you need to calculate that figure now, in mid-2026, not when registration opens.

To check whether your commodity codes bring you into scope, use the GOV.UK step-by-step checker. Penalties for late registration are confirmed, so do not leave this until December 2026.

For the EU CBAM, the scope is broader: iron, steel, aluminium, cement, fertiliser, electricity and hydrogen. If you are a Stoke manufacturer exporting products that contain any of these materials to EU customers, your buyer may already be asking you for embedded emissions data. If you cannot provide that, you become a problem for their compliance, and potentially a supplier they replace.

The Dual Burden: How EU CBAM (Live Now) and UK CBAM (January 2027) Affect You Differently

The most confusing part of this for Stoke businesses is that there are two regimes, they work differently, and they can both apply at the same time.

The EU CBAM is a certificate scheme. Your EU customer buys CBAM certificates, priced against EU Emissions Trading Scheme (ETS) auction prices, to cover the carbon cost of importing your goods. The burden falls on them formally, but they cannot complete their declaration without your data. The House of Commons Library briefing on CBAM confirms that the first annual EU CBAM declaration is due on 31 May 2027, covering 2026 imports. That means your EU customers are building their data sets right now.

The UK CBAM is an HMRC tax. It is applied at the point of import. You, as the UK importer of CBAM-covered goods from outside Great Britain, pay it directly to HMRC. There is no certificate to buy. The rate is set by government based on sector-specific carbon values. You account for it through the HMRC system.

The practical implication for a Stoke business with a cross-border supply chain: you may be dealing with both at once. You might import steel from outside the UK (UK CBAM liability from January 2027) and export finished components containing that steel to an EU manufacturer (EU CBAM data request from that EU customer, needed for their 2026 declaration). Both require preparation now.

There is one evolving situation worth watching: the potential linkage of the UK and EU Emissions Trading Schemes. If negotiations succeed, UK exporters to the EU could be exempted from EU CBAM charges, because the carbon would already be priced under the UK ETS. This would significantly reduce the dual burden. But the timeline for any linkage decision is uncertain, and waiting for it would be a serious compliance risk. Prepare as if it does not happen.

Your Practical Compliance Checklist: Emissions Data, Record-Keeping and Registration Steps

Here is what you actually need to do, in order of urgency.

1. Check your commodity codes. Run your import commodity codes through the GOV.UK CBAM scope checker. If your codes are not in scope, document that and review again when the government publishes its next sector review. If they are in scope, move to step 2.
2. Calculate your 12-month import value. Take the total value of covered CBAM goods you have imported over the past 12 months. If it is below £50,000, you are currently below the registration threshold. If it is approaching that figure, plan for registration now rather than scrambling in late 2026.
3. Understand your record-keeping obligations. HMRC guidance on CBAM record-keeping confirms that from 1 January 2027, importers of CBAM goods must keep records including net mass of goods, commodity codes, embedded emissions figures, and any carbon price already paid in the country of origin. These records must be kept for six years. Start building your data collection process now, because you cannot retrospectively gather this information easily.
4. Talk to your EU customers. If you export to EU buyers, ask them whether they have made a CBAM declaration that includes your goods. If they have, or are planning to, they will need your production emissions data. You may already have been asked for this and not recognised what the request was about. Treat any EU customer asking about your carbon data or production processes as a CBAM-related request.
5. Engage with HMRC directly. The HMRC CBAM collection page provides contact routes for policy and general enquiries. These are free, official channels and the fastest way to stay current as secondary legislation finalises.

Local Support and Next Steps: Where Stoke Businesses Can Get Help Today

The local business support landscape in Staffordshire is genuinely useful here, and none of it costs you a consultancy day-rate to access. That matters in a city where most manufacturers are running tight margins already.

The British Ceramic Confederation (BCC) is headquartered in Stoke-on-Trent and represents the overwhelming majority of UK ceramic production. The BCC has been actively engaged in CBAM policy discussions and submitted evidence during the consultation process on behalf of the ceramics sector. If you are a ceramics manufacturer, the BCC is your best first call for sector-specific guidance on EU CBAM indirect exposure and what happens if ceramics is added to the UK CBAM scope in a future review. Do not treat the current ceramics exemption as permanent.

The Staffordshire Chambers of Commerce provides advisory support to member businesses on trade compliance matters. If you are not a member and you are navigating cross-border supply chains, membership is worth considering purely for the advisory access.

The Staffordshire Growth Hub is a free resource for Staffordshire businesses funded through the Business Support Programme. It offers funded diagnostic reviews and can connect you to specialist trade advisers who understand the local manufacturing context. It is worth a conversation before you pay anyone else for compliance advice.

If you are a Stoke ceramics business and you are not directly in scope for UK CBAM because glass and ceramics were removed from the 2027 launch, do not disengage from this topic. Your EU customers may be in scope. Your raw material suppliers may be in scope. And the sector could be added in the next review. Monitor the HMRC guidance and engage with the BCC. The worst outcome is being caught by a regulation you knew was coming but waited too long to prepare for.

You can also review the draft CBAM regulations published by government to understand how the secondary legislation is taking shape before it is finalised.

The January 2027 deadline is a firm one. The data collection requirement starts on that date, not when registration opens. Start the groundwork now, while you still have time to do it calmly rather than under pressure.

The administrative burden of CBAM compliance is real: emissions data collection, supplier conversations, record-keeping systems, and regular monitoring of regulatory changes. I know what it looks like when a compliance deadline lands on a team that is already stretched, because I have been that team. Running a business operation while new regulatory obligations pile up is not a theory exercise. It is a real workload problem.

That workload problem is exactly where AI systems can help. Building the data pipelines, the supplier data request workflows, and the internal records systems that CBAM requires is structured, repeatable work. It is the kind of work AI agents can run for you, rather than consuming your operations manager’s week every time a new obligation lands.

If that is relevant to where your business is right now, I offer a free discovery call to Staffordshire businesses. We look at where AI can realistically cut admin cost or lift output in your specific operation, and I build and deploy it, trained on your own processes and data. No generic software demos, no “learn ChatGPT” sessions. Practical systems that save your team time on real tasks. Book a free discovery call at Wright Advisory if you want to talk through what that looks like for your business.