From 1 January 2027, UK CBAM puts a carbon charge on imports of iron and steel, aluminium, cement, fertiliser and hydrogen. Whether a product is caught depends on one thing: its commodity code. This is HMRC's full list, sector by sector, with the exceptions and the lookalikes that sit just outside it.

Key takeaways

  • HMRC lists UK CBAM goods by heading or subheading; every code under a listed heading is in scope unless HMRC names it as an exception
  • All of chapter 72 (iron and steel) is in scope, apart from most ferro-alloys and ferrous scrap
  • Everyday articles are caught: screws and bolts (7318), empty steel or aluminium cans (7310, 7612), aluminium foil (7607) and other articles of steel or aluminium (7326, 7616)
  • Household articles of steel (7323) and aluminium (7615) are not on the list, so the line between "household" and "other" decides whether you owe CBAM
  • A wrong code can hide a liability or create a reporting burden you don't have

UK CBAM starts on 1 January 2027. If you import goods in five sectors (iron and steel, aluminium, cement, fertiliser and hydrogen), you may owe a carbon charge on them once their value passes £50,000 in a rolling 12 months. We explained the scheme, the threshold and the timetable in UK CBAM starts on 1 January 2027. This guide is the reference that goes with it: the list of commodity codes HMRC says are in scope.

How HMRC defines UK CBAM scope

HMRC publishes one list per sector in its guidance check which goods are in scope of CBAM. The lists were last updated on 16 July 2026. Each entry is a chapter, heading or subheading, and HMRC's rule is simple: if a heading or subheading is listed, every code beneath it is in scope too, unless it appears in the list of exceptions.

That makes the commodity code the trigger. You don't decide whether a product is a "steel product" by looking at it. You decide by classifying it, and then checking whether its code falls under one of the entries below.

UK CBAM goods list: iron and steel

The iron and steel list is the widest. It covers all of chapter 72 and a set of headings in chapter 73 that include finished articles.

Commodity codeDescription
2601 12Agglomerated iron ores and concentrates, other than roasted iron pyrites
72Iron and steel (the whole chapter, except the items in the exceptions table)
7301Sheet piling of iron or steel; welded angles, shapes and sections
7302Railway or tramway track construction material of iron or steel
7303Tubes, pipes and hollow profiles, of cast iron
7304Tubes, pipes and hollow profiles, seamless, of iron or steel
7305Other tubes and pipes with an external diameter over 406.4 mm
7306Other tubes, pipes and hollow profiles of iron or steel
7307Tube or pipe fittings of iron or steel
7308Structures and parts of structures of iron or steel
7309Reservoirs, tanks, vats and similar containers over 300 litres
7310Tanks, casks, drums, cans, boxes and similar containers of 300 litres or less
7311Containers for compressed or liquefied gas
7318Screws, bolts, nuts, coach screws, screw hooks, rivets, washers and similar articles
7326Other articles of iron or steel

The greenhouse gas covered for iron and steel is carbon dioxide.

UK CBAM goods list: aluminium

Commodity codeDescription
7601Unwrought aluminium
7603Aluminium powders and flakes
7604Aluminium bars, rods and profiles
7605Aluminium wire
7606Aluminium plates, sheets and strip over 0.2 mm thick
7607Aluminium foil up to 0.2 mm thick, whether or not printed or backed
7608Aluminium tubes and pipes
7609Aluminium tube or pipe fittings
7610Aluminium structures and parts of structures
7611Aluminium reservoirs, tanks and vats over 300 litres
7612Aluminium casks, drums, cans, boxes and similar containers of 300 litres or less
7613Aluminium containers for compressed or liquefied gas
7614Stranded wire, cables and plaited bands of aluminium, not electrically insulated
7616Other articles of aluminium

The gases covered for aluminium are carbon dioxide and perfluorocarbons.

UK CBAM goods list: cement, fertiliser and hydrogen

SectorCommodity codeDescription
Cement2507 00 80Other kaolinic clays
Cement2523 10Cement clinkers
Cement2523 21White Portland cement
Cement2523 29Other Portland cement
Cement2523 30Aluminous cement
Cement2523 90Other hydraulic cements
Fertiliser2808 00Nitric acid, sulphonitric acids
Fertiliser2814Ammonia, anhydrous or in aqueous solution
Fertiliser2834 21Nitrates of potassium
Fertiliser3102Mineral or chemical fertilisers, nitrogenous
Fertiliser3105Mineral or chemical fertilisers containing two or three of nitrogen, phosphorus and potassium, and other fertilisers
Hydrogen2804 10Hydrogen

Cement and hydrogen cover carbon dioxide. Nitric acid, potassium nitrate and the fertilisers in 3102 and 3105 also cover nitrous oxide.

The exceptions

These codes sit inside a listed chapter or heading but HMRC has taken them out of scope.

Commodity codeDescriptionSits within
7202 21Ferro-silicon72
7202 30Ferro-silico-manganese72
7202 50Ferro-silico-chromium72
7202 70Ferro-molybdenum72
7202 80Ferro-tungsten and ferro-silico-tungsten72
7202 91Ferro-titanium and ferro-silico-titanium72
7202 92Ferro-vanadium72
7202 93Ferro-niobium72
7202 99 10Ferro-phosphorus72
7202 99 30Ferro-silico-magnesium72
7202 99 80Other ferro-alloys72
7204Ferrous waste and scrap, and remelting scrap ingots72
3105 60Fertilisers containing only phosphorus and potassium3105

The products that catch importers out

Most businesses that think about CBAM picture steel coil or aluminium ingots. The list reaches further, into goods that retailers, food producers and manufacturers buy every week.

ProductExample commodity codeCustoms dutyIn UK CBAM?
Steel screws and bolts with heads7318 15 95 890%Yes (7318)
Empty steel cans for preserving food7310 21 11 000%Yes (7310)
Empty aluminium cans and containers7612 90 80 006%Yes (7612)
Household aluminium foil in rolls7607 11 11 197.5%Yes (7607)
Steel ladders and step stools7326 90 30 002%Yes (7326)
Garden fertiliser in packs of 10 kg or less3105 10 00 906%Yes (3105)
Stainless steel kitchen and household articles7323 93 00 900%No
Aluminium household and kitchen articles7615 10 80 906%No
Steel nails7317 00 60 000%No

Duty rates are third-country rates from the UK Trade Tariff on 23 October 2026. Household aluminium foil from China also carries anti-dumping duty of up to 35.6%.

The household rows are the ones to watch. A steel article goes to 7323 if it is a table, kitchen or household article, and to 7326 if it isn't. The same split exists for aluminium between 7615 and 7616, and an aluminium foil container under 7612 is in scope while a household foil article under 7615 is not. Screws and bolts are in; nails are out. These lines decide whether goods are CBAM goods, so a supplier's description of "metal homeware" isn't enough to settle it.

Packaging needs the same care. Cans imported already filled with food or drink are normally classified with their contents, so it is empty packaging that brings CBAM in.

UK CBAM in or out: lookalike products one heading apart. In scope: 7318 steel screws, bolts and washers; 7326 other articles of steel; 7616 other articles of aluminium; 7612 aluminium foil containers; 7310 and 7612 empty cans imported as packaging; 7326 steel card holder. Not in scope: 7317 steel nails; 7323 household articles of steel; 7615 household articles of aluminium; 7615 household foil articles; filled cans classified with their contents; 4202 leather or textile card holder
One heading apart: the lookalike products either side of the UK CBAM line. Source: HMRC, check which goods are in scope of CBAM (16 July 2026).

A worked example: the steel card holder

One of the products in our TTVerified demonstration catalogue is a slim credit card holder. The supplier's description was "CARD HOLDER RFID SLIM", and the code on file was 4202 31 00 90, under the heading for cases and wallets, which is where most card holders belong.

TTVerified asked one question the supplier description didn't answer: what material makes up the outer surface? Card holders are classified by their outer surface, and this one was steel. That moves it out of 4202 and into 7326 90 98 90, other articles of iron or steel.

The duty is 2% either way, so the old code was costing the importer nothing at the border. The difference is CBAM. 7326 is on HMRC's list and 4202 isn't, so the correct code turns the card holder into a CBAM good, with records to keep from 1 January 2027 and value that counts towards the £50,000 threshold. Under the old code, none of that would have been visible until HMRC asked.

In our audits of new customers, around 2 in 5 tariff codes turn out to be wrong. A wrong code doesn't always change the duty, which is why it can sit unnoticed for years. Under CBAM, a wrong code with the same duty rate can still leave a tax liability unreported.

What CBAM will cost per product

HMRC published the default values on 16 October 2026: one emissions figure for each 8-digit code, whatever the country of origin, in tonnes of CO2 equivalent per tonne of goods. You can use them instead of actual emissions data from your supplier, but if you file a return on default values you can't amend it later with actual data.

The charge is the embodied emissions multiplied by the CBAM rate for the sector, less relief for any carbon price already paid abroad. HMRC will publish the rates for January to March 2027 before the end of this year. To show how the sums work, it has published illustrative rates based on the UK ETS price in the third quarter of 2026.

SectorIllustrative CBAM rate (per tonne CO2e)
Iron and steel£9.69
Aluminium£9.79
Cement£8.78
Fertiliser£1.45
Hydrogen£9.24

Some default values for everyday goods:

8-digit codeGoodsDefault value (tCO2e per tonne)
7318 15 95Steel screws and bolts with heads5.584
7310 21 11Steel cans for preserving food4.662
7612 90 80Aluminium casks, drums, cans and boxes4.887
7607 11 11Aluminium foil in rolls of 10 kg or less3.505
7326 90 30Ladders and steps of iron or steel3.367

At the illustrative rate, 10 tonnes of steel bolts would carry 55.84 tonnes of embodied emissions and a CBAM charge of about £541. These figures are HMRC's illustrations and don't create a liability. The real rate for each quarter will be published at the start of it.

How to check your own codes against the list

How to check your codes against the UK CBAM list in six steps: pull your codes in chapters 25, 28, 31, 72, 73 and 76; find the longest matching HMRC entry; check the exceptions; question the boundaries; keep records from 1 January 2027; track the £50,000 threshold
Six steps to check your commodity codes against HMRC's UK CBAM list.
  1. Pull every commodity code you import into chapters 25, 28, 31, 72, 73 and 76. Those are the only chapters on the list.
  2. For each code, find the longest entry on HMRC's list that it starts with. A code starting 7318 is in scope; a code starting 7323 is not.
  3. Check it against the exceptions. A code starting 7202 21 is out, even though chapter 72 is in.
  4. Question the codes that sit near a boundary: 7323 against 7326, 7615 against 7616, 4202 against 7326, and filled against empty cans.
  5. For anything in scope, start recording the 8-digit code, description, the date the goods passed the tax point, customs value and net weight from 1 January 2027, and ask suppliers for emissions data. HMRC can charge a £500 penalty for failing to keep CBAM records.
  6. Work out when you cross £50,000. HMRC applies two tests: whether you expect to import £50,000 of CBAM goods in the next 30 days, and, on the first day of each month, whether you imported £50,000 in the previous 12 months. Registration opens on 1 January 2028, and if you became liable during 2027 you must register by 31 January 2028.

Step 2 only works if the code is right in the first place. The list tells you which codes are in scope. It can't tell you whether your product belongs under the code you have been using.

Where TariffTel fits

Every code classified in TTVerified is checked against CBAM and flagged when it is in scope, alongside anti-dumping duty and the duty and preferential rates. Codes come from expert-built question pathways, like the outer-surface question that caught the card holder, and a customs specialist verifies each one, so you can show HMRC why a product is or isn't a CBAM good.

If you have a range of metal products, packaging or fixings to check before January, start with the lines you are least sure of. The TTVerified 14-day free trial includes 10 classifications with no card needed, or talk to our classification team about reviewing a full range. For a single product, TTExplore suggests 10-digit codes with its reasoning from £2 a code.

FAQ

Goods in five sectors: iron and steel, aluminium, cement, fertiliser and hydrogen. HMRC defines the scope by commodity code, listing chapters, headings and subheadings. Every code under a listed heading is in scope unless HMRC names it as an exception.
Yes. Screws, bolts, nuts, washers, rivets and similar articles of iron or steel fall under heading 7318, which is on HMRC's list.
Not if they are correctly classified as table, kitchen or household articles of iron or steel under heading 7323, which isn't on the list. Other articles of iron or steel under 7326 are in scope, so the classification decides it.
Yes. Aluminium foil up to 0.2 mm thick falls under heading 7607, which is on the list, whether or not it is printed or backed with paper or plastic.
Empty steel cans (7310) and empty aluminium cans (7612) are in scope. Cans imported already filled are normally classified with their contents, so they aren't CBAM goods.
No. Nails fall under heading 7317, which isn't on HMRC's list, while screws and bolts under 7318 are.
Not yet. HMRC published default values and illustrative rates on 16 October 2026 and says the rates for January to March 2027 will be published before the end of 2026. Rates are then set for each sector every quarter.
No. Ferrous waste and scrap under heading 7204 is one of HMRC's exceptions, along with most ferro-alloys under 7202.
The sectors overlap, but the schemes differ. The EU scheme also covers electricity, uses a 50-tonne threshold rather than £50,000, and has been charging since 1 January 2026. We compared them in CBAM: what you need to know for 2026.
Elizabeth Davies

Elizabeth Davies

Head of Customs Compliance & Classification, TariffTel

Elizabeth has more than 15 years’ experience in customs classification, advising UK retailers, manufacturers and food producers on getting commodity codes right and keeping them right. A regular speaker at Food and Drink Federation (FDF) webinars, she leads the team behind TariffTel’s expert-verified classification methodology.

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