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Your steel comes from the UK — post-Brexit it’s a third country under CBAM — but the UK ETS carbon price qualifies for an Art. 9 deduction that makes British steel competitive

You import steel from the UK into Ireland, the Netherlands, France or Belgium. Before Brexit, this was intra-EU trade. Now the UK is a third country for CBAM purposes, and every tonne of British steel imported from 1 January 2026 requires a CBAM declaration. But the UK has a significant advantage: the UK Emissions Trading System (UK ETS) imposes a carbon price on steel production, and this price qualifies for a deduction under Art. 9 of Reg. (EU) 2023/956. This makes UK steel more competitive under CBAM compared to origins with no carbon price. CBAMCheck generates both the emissions documentation and the Art. 9 carbon price deduction documentation in one dossier. 12 deliverables. €299 one-time.

Generate your CBAM dossier — €299Free check: does CBAM apply to you?

€299 · One-time · 12 professional deliverables · Your data never leaves your browser

Built on Reg. (EU) 2023/956 · Modified by Reg. (EU) 2025/2083 · 13,566 default values (Reg. 2025/2621) · 100% browser-side — your data never leaves your device

The numbers that matter for your CBAM compliance

€3,200M
UK steel exports to the EU by value
2.909
tCO₂e/t — UK steel default (Reg. 2025/2621)
UK ETS
Active carbon price → Art. 9 deduction available

Your CBAM compliance timeline

1
Register as authorised CBAM declarant
Art. 5. Post-Brexit, UK imports require the same CBAM registration as any other third country.
2
Map your UK steel CN codes
Chapter 72, headings 7301–7326. GHG: CO₂ (direct emissions only per Annex II).
3
Determine embedded emissions
UK default: 2.909 tCO₂e/t. Or request actual emissions from your UK supplier. Art. 7 + Annex IV.
4
Document the UK ETS carbon price for Art. 9 deduction
The UK ETS carbon price is effectively paid by UK steel producers. Collect documentation certified by an independent person per Art. 9(2). This reduces the number of CBAM certificates required.
5
Purchase CBAM certificates quarterly
Art. 22(2). Net of Art. 9 deduction and free allocation adjustment (Art. 31).
6
Submit annual CBAM declaration by 30 September
First declaration: 30 September 2027 for calendar year 2026. Art. 6.

Three mistakes that inflate your CBAM cost or create compliance risk

MISTAKE 1 — IGNORING THE UK ETS

Treating UK steel like steel from a country with no carbon price

The UK ETS imposes a carbon cost on UK steel production. Not documenting this for an Art. 9 deduction means paying for CBAM certificates that could have been partially or substantially offset.

MISTAKE 2 — LEGACY THINKING

Assuming UK steel is still treated as intra-EU trade

Post-Brexit, the UK is a third country under Reg. (EU) 2023/956. All CBAM obligations apply to UK steel imports as they would to imports from any non-EU origin.

MISTAKE 3 — ADDED COMPLIANCE COST SHOCK

Reacting to CBAM as a new cost when the Art. 9 deduction offsets most of it

UK steel producers already pay a carbon price through the UK ETS. The CBAM cost after Art. 9 deduction may be significantly lower than for origins without carbon pricing. Document the deduction to show the true net cost.

What you receive: 12 deliverables in one ZIP file

CBAMCheck generates a complete CBAM compliance dossier — not a single PDF. 12 structured documents delivered as a ZIP file, each citing the specific article of Reg. (EU) 2023/956 it addresses.

1

Scope Assessment

Determines whether your imports fall under CBAM and which obligations apply. Art. 2 + Art. 2a of Reg. (EU) 2023/956.

2

Embedded Emissions Calculation

Calculates embedded emissions per tonne using default values from Implementing Reg. (EU) 2025/2621 or your actual data. Art. 7 + Annex IV.

3

CBAM Certificate Estimation

Estimates the number of certificates required and the projected cost, adjusted for free allocation (Art. 31).

4

Draft CBAM Declaration

Pre-structured declaration following Art. 6(2) requirements: quantities, emissions, certificates, carbon price.

5

Carbon Price Documentation

Documents any carbon price paid in the country of origin for Art. 9 deduction. Pre-formatted for the CBAM Registry.

6

Annex V Record Template

Record-keeping template compliant with Annex V requirements. Ready for verifier review.

7

Verification Preparation

Structured preparation for Art. 8 verification by an accredited verifier. Annex VI checklist included.

8

Supplier Letter Template

Model letter in English requesting emissions data and installation information from your third-country supplier.

9

Compliance Calendar (.ics)

Importable calendar with quarterly certificate obligations (Art. 22(2)), annual declaration deadline (30 September), and key milestones.

10

Executive Summary

One-page overview of your CBAM exposure: cost estimate, timeline, risk areas. Ready for management or board reporting.

11

Interactive HTML Dashboard

Standalone HTML dashboard with 2026–2032 projections reflecting free allocation phase-out (Art. 31). Works offline, no subscription.

12

Compliance Calendar Document

Visual calendar of all CBAM deadlines, reporting windows and certificate purchase schedules.

Generated from your input data, in your browser. No data leaves your device.

See what you get

Download a sample CBAMCheck dossier. This is a real output generated with generic data — the same 12 deliverables you will receive with your company’s actual figures.

Download sample dossier (ZIP)

Generic data. Your dossier will contain your actual import figures, CN codes and emission calculations.

Estimate your CBAM exposure

Select your sector and country of origin. CBAMCheck searches through 13,566 official records from Implementing Reg. (EU) 2025/2621 and shows the result with the 2026 mark-up included.

Quick CBAM Calculator

Average European Commission default values per sector and country of origin.

Default emissions (tCO₂e/t)
Mark-up 2026 (10%)
Total emissions with mark-up
CBAM rate 2026 (2.5%)
Estimated certificates

This is a quick estimate. Your complete dossier includes projections through 2032, an editable interactive dashboard, and 10 PDF documents.

Generate your complete dossier — €299 →

Average values per sector from Implementing Reg. (EU) 2025/2621. The complete dossier uses the exact CN code of your goods, not the sector average. Estimated EU ETS price: €75/tCO₂e.

What CBAM compliance costs with each alternative

FeatureFree toolCBAMCheckSaaS Enterprise
PriceFree€299 (one-time)€1,990–€4,800/year
ModelGeneric template12 professional deliverablesAnnual subscription
Default valuesNot included13,566 (Reg. 2025/2621)Partial
Interactive dashboardNoHTML, 7-year projectionInside platform
Supplier letterNoEnglish template includedVariable
Art. 8 verification prepNoIncludedVariable
PrivacyVariable100% browser-sideData on server
Multi-company supportNoVia Professional PackYes

Choose your licence

1 DOSSIER
€299
/ dossier

  • 10 professional PDF documents
  • Interactive HTML Dashboard (projection 2026–2032)
  • 13,566 official values integrated
  • Template letter in English for supplier
  • Importable .ics calendar
  • 10 regenerations · 30 days
  • 1 licence = 1 importing company
Get your individual licence →
PROFESSIONAL PACK
€1,999
70 generations · 1 key

  • 70 generations with a single key
  • 70 complete dossiers (12 deliverables each)
  • Switch product between generations
  • Ideal for customs representatives
  • For consultants billing CBAM compliance
70 interactive HTML Dashboards × product (projection 2026–2032). Real-time tables and charts with variable calculations. No technical training required. Fully intuitive.
🔒 Data stays on your computer. No information shared with third parties.
Request Professional Pack →

How your licence works

1
1 licence = 1 importing company. You pay €299 for the dossier you generate now. The licence is linked to your company name + EORI.
2
Up to 10 regenerations of the ZIP to correct data, adjust goods or update technical information.
3
30-day editing window from first activation. Within that period you can regenerate the dossier as many times as needed (up to 10).
4
The downloaded dossier is yours forever. It does not expire and is not tied to any subscription. The 10 PDFs, HTML dashboard and .ics calendar remain functional offline.

The EU CBAM portal asks for data. CBAMCheck calculates it.

THE EU CBAM PORTAL

Asks you to declare data

The EU CBAM Registry (Art. 14) requires you to submit total embedded emissions, number of certificates and carbon price documentation. It does not calculate these for you. You must arrive with the numbers ready.

CBAMCHECK

Calculates the data you need to declare

CBAMCheck takes your import data (tonnes, CN codes, country of origin) and generates the embedded emissions calculation, certificate estimation, carbon price documentation and all supporting records. You download the dossier and use it to complete the CBAM Registry submission.

Enforcement: what happens when CBAM certificates are missing

Art. 26 of Reg. (EU) 2023/956 sets the penalties.

⚠️
Authorised declarant: penalty identical to EU ETS excess emissions penalty
EU ETS rate per missing certificate

Art. 26(1): an authorised CBAM declarant who fails to surrender the required certificates by 30 September faces a penalty identical to the excess emissions penalty under Art. 16(3) of Directive 2003/87/EC, increased pursuant to Art. 16(4). The penalty applies per certificate not surrendered. Payment does not release the obligation to surrender outstanding certificates (Art. 26(3)).

⚠️
Unauthorised importer: penalty 3–5 times the standard rate
3–5×

Art. 26(2): a person who introduces goods without authorisation faces a penalty of 3 to 5 times the standard penalty, depending on duration, gravity, scope, intent and cooperation. This also applies to importers exceeding the de minimis threshold (50 tonnes, Art. 2a) without authorisation (Art. 26(2a)).

Importing steel from the UK, Turkey, India and other origins? The Art. 9 deduction applies only where a carbon price exists.

The Professional Pack covers 70 dossier generations. Compare net CBAM costs across origins — the UK ETS deduction makes British steel a different proposition from origins with no carbon price.

Request Professional Pack
One-business-day response · No sales call required

What CBAMCheck guarantees and what it does not

CBAMCheck generates a document structured according to Art. 6 and Art. 7 + Annex IV of Regulation (EU) 2023/956 from the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as importer or authorised CBAM declarant.

We guarantee that the document structure follows Regulation (EU) 2023/956 and that the legal references cited are correct. We do not guarantee that a specific document will be accepted by a national competent authority in a specific case.

CBAMCheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.

Frequently asked questions

Is UK steel subject to CBAM after Brexit?
Yes. Post-Brexit, the United Kingdom is a third country outside the EU customs territory. All steel imports from the UK fall under Reg. (EU) 2023/956 from 1 January 2026. The UK is not listed in Annex III (exempt countries).
Can I deduct the UK ETS carbon price under Art. 9?
Yes. The UK ETS imposes a carbon price on covered installations including steel production. Art. 9(1) allows a reduction in CBAM certificates to account for carbon prices effectively paid in the country of origin. Documentation must be certified by an independent person per Art. 9(2). CBAMCheck generates the carbon price documentation template.
How does the Art. 9 deduction work in practice?
The carbon price effectively paid in the UK (via UK ETS allowances) is converted into a corresponding reduction in CBAM certificates. The implementing acts under Art. 9(5) govern the conversion methodology. Any rebates or free allocation in the UK ETS must be netted against the carbon price claimed.
Is the UK ETS price high enough to offset most of the CBAM cost?
The UK ETS price is significant and may offset a substantial portion of the CBAM certificate cost. The exact offset depends on the UK ETS allowance price relative to the CBAM certificate price, and any free allocation in the UK ETS. CBAMCheck’s interactive dashboard projects the net cost through 2032.
Is this a subscription?
No. One-time payment. The licence includes 30 days of editing and 10 regenerations. The downloaded dossier is yours to keep.
Can I get a refund?
Upon activating the licence you give express consent for immediate generation of digital content pursuant to Art. 16(m) of Directive (EU) 2011/83, waiving the 14-day withdrawal right. Refunds are accepted only for a reproducible technical fault.
What if the regulation changes?
If the regulation changes during your licence validity, you can regenerate the document with the updated version of the generator at no extra cost.
⚠️ Important notice: CBAMCheck is a self-assessment documentation tool, not legal advice and not a third-party audit. The document is generated from your input data. You are responsible for the accuracy of the data you provide. CBAMCheck does not replace a qualified professional assessment.

UK steel has a carbon price advantage under CBAM. Document it.

12 deliverables. UK default 2.909 tCO₂e/t. Art. 9 carbon price documentation. UK ETS deduction pathway. €299.

€299 one-time
12 professional deliverables · Browser-side · No subscription · Reg. (EU) 2023/956
Generate your CBAM dossier — €299