HMRC Publishes UK Carbon Border Adjustment Mechanism Guidance Ahead of January Start
HMRC has published a collection of guidance on the UK Carbon Border Adjustment Mechanism (CBAM) ahead of its January start date. The update was flagged in Osborne Clarke's September 2026 ESG Knowledge Update, which also noted that EU right to repair rules are now in force, placing new obligations on manufacturers selling goods in the EU, and that new guidance sets out how biodiversity net gain will apply to nationally significant infrastructure projects ahead of a November deadline. The European Commission has also published guidance on article 25 of the Net-Zero Industry Act, which establishes a framework for strengthening Europe's net-zero technology manufacturing ecosystem.
Why this matters
The publication of HMRC's CBAM guidance marks a concrete step toward the UK regime's January implementation. Businesses importing carbon-intensive goods into the UK will need to understand their compliance obligations before the start date. The parallel EU developments, right to repair rules and Net-Zero Industry Act guidance, signal a busy period of ESG regulatory change on both sides of the Channel.
On the Ground
Energy and environment practices will field client queries on CBAM compliance readiness ahead of January. The right to repair obligations create product regulation work for manufacturing and retail clients operating in the EU. A trainee would be tasked with monitoring HMRC's CBAM guidance portal, summarising new materials, and flagging deadlines to supervising partners.
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