techUK has submitted a response to the HM Treasury and HMRC led consultation on the proposals for the design and administration of the UK Carbon Border Adjustment Mechanism (CBAM).
Some of the policy recommendations we put forward to the Committee include:
- Align with the EU on default values calculation methods and timelines.
- Introduce provisions for using default values when obtaining precise data is particularly challenging so that businesses can comply without incurring excessive costs or administrative burdens.
- Allocate CBAM revenue to net zero initiatives, despite this not being a traditional practice​.
- Agree a longer implementation period to allow businesses time to adapt and avoid high consultancy fees or incorrect returns.
- Cooperate with international organisations to ensure global oversight of CBAMs to prevent trade distortions.
- Regularly review CBAM scope and ensure technological developments and changes in international standards are taken into consideration.
- Ensure greater interoperability between the UK and EU CBAM regimes to avoid confusion and trade barriers.
- Require businesses to disclose the percentage of scrap metals used in complex CBAM goods and establish a threshold for these to be exempted to encourage circular economy practices.
- Provide clear guidance on enforcement procedures to help businesses understand their obligations and avoid inadvertent non-compliance.
- Establish an additional threshold based on the weight of imported items to account for smaller high-value items.
- Exempt small business parcels and consumer parcels from the mechanism.
- Work with UKAS to determine verification requirements to ensure market readiness and effective compliance.
- Include lists of customs declarations containing CBAM goods on the upcoming online returns platform to streamline reporting.
- Publish detailed methodologies for calculating CBAM rates for each sector to provide businesses with greater predictability and certainty.
techUK will continue working with the UK government to address the sector's concerns and ensure the effective implementation and operation of the UK CBAM. Members will be updated about any developments.