UK CBAM will initially apply to qualifying goods within the aluminium, cement, fertiliser, hydrogen and iron and steel sectors.

Whether an individual import is affected depends on its commodity code and the applicable UK CBAM rules.

Responsibility generally sits with the importer of record where that person meets the requirements to become liable for UK CBAM.

For businesses with complex import arrangements, establishing who is responsible should be an important part of CBAM preparation.

Yes. Businesses will generally need to register where the total value of their CBAM goods imported during a 12-month period reaches the applicable £50,000 registration threshold.

Businesses close to the threshold should monitor imports rather than waiting until the end of the year to assess their position.

UK CBAM liability will depend on factors including the quantity and type of goods imported, the emissions associated with their production, the applicable UK CBAM sector price and any eligible carbon price already paid overseas.

This means CBAM is not simply a reporting requirement. It can create a material tax, cash flow and margin exposure.

Default emissions values provide an emissions basis where acceptable actual emissions data is not available.

For many businesses, defaults are likely to be important when initially forecasting CBAM exposure while they work with suppliers to obtain robust facility-level emissions information.

Potentially. Where compliant actual emissions are lower than the applicable default value, using them may reduce the emissions on which CBAM liability is calculated.

However, lower liability should not be assumed until the required emissions data and supporting evidence are available and meet the UK CBAM requirements.

No. They have similar policy objectives, but they are separate regimes with different rules, timelines, pricing mechanisms and reporting requirements.

Businesses importing into both the UK and EU may therefore need to manage both regimes.

Before 2027.

Businesses may need time to identify affected product lines, understand financial exposure, establish internal ownership, engage suppliers, obtain emissions information and develop reporting and evidence processes.

Notch is a specialist CBAM technology and intelligence business.

The Notch CBAM Intelligence Platform helps organisations understand, forecast, manage and report their CBAM obligations across the UK and EU regimes.

Notch brings the different parts of CBAM management together in one platform, including:

• identifying affected imports and product lines

• forecasting emissions and financial exposure

• managing product, supplier and production-facility information

• supporting emissions-data management

• managing reporting workflows and evidence

• producing CBAM reporting outputs

• monitoring regulatory and data changes that may affect exposure

The aim is to turn CBAM from a fragmented compliance exercise into a manageable financial and operational process.

Yes. Notch is designed to support organisations operating under the UK and EU CBAM regimes, including businesses that need to manage both.

Yes. Financial forecasting is a core part of the Notch platform.

Businesses can model expected import volumes, emissions and CBAM pricing to understand potential liability before the reporting period begins and monitor how exposure changes over time.

Yes. The platform is designed to support facility and product-specific emissions information alongside applicable default emissions.

This enables organisations to understand where obtaining compliant actual emissions data could affect their CBAM exposure.

Yes. Notch is designed for organisations that need to manage CBAM across multiple reporting entities, product lines, suppliers and production facilities.

Notch Nudges help users understand when changes in CBAM rules, emissions data or other governed intelligence could affect their organisation.

Rather than simply notifying users that something has changed, Notch is designed to help identify what changed, what it could mean for exposure and what action may be required.

The Notch Import Check is a free tool that helps businesses understand whether their imports could be affected by UK CBAM.

Upload one month of HMRC CDS import data and Notch identifies potentially qualifying imports, affected product lines and potential exposure.

The Notch free CBAM Readiness Assessment helps organisations understand how prepared they are for UK CBAM.

Answer 15 questions in less than five minutes and receive a personalised readiness report covering six areas:

Leadership & Governance · Product & Import Visibility · Supplier & Emissions Data · Financial Readiness · Reporting & Auditability · Operational Workflow Maturity

You receive a personalised report including your overall readiness score and classification, performance across the six readiness areas, identified gaps and recommended next steps.

No. Both are free Notch resources designed to help organisations establish where they stand and what they may need to do next.

Yes. Notch works with organisations across customs and international trade, tax and accounting, sustainability and carbon, and other professional and commercial services.

CBAM creates a new requirement for many of the businesses that advisers already support.

A Notch partnership can help organisations extend their existing services into CBAM, strengthen client relationships and create new commercial opportunities without having to build dedicated CBAM technology and operational infrastructure from scratch.

No. We recognise that different organisations want to play different roles.

Some partners want to build a substantial CBAM advisory capability. Others want to support existing clients or introduce them to specialist CBAM technology and expertise.

We structure the relationship around the partner's capabilities, clients and objectives.

Yes. The Notch Partner Workspace is designed to help partners support multiple clients through a single environment, including visibility of client readiness, financial exposure, reporting activity and outstanding actions.

Visit our Become a Partner page and tell us a little about your organisation and how you are interested in working with Notch.

One of the team will then contact you to explore opportunities to work together.

Our Insights & Updates section provides practical commentary on regulatory developments, financial exposure, emissions data, supplier engagement and CBAM readiness.

You can also follow Notch and James's Linkedin pages for commentary on ongoing updates as the UK moves towards implementation in 2027.

Whether you're trying to understand your own CBAM exposure, preparing your organisation for 2027 or exploring how you could support clients, we'd be happy to help. Contact us