ALFED has developed a UK Carbon Border Adjustment Mechanism (CBAM) briefing paper, setting out the key concerns and priorities being raised by members as the proposed January 2027 implementation date approaches.

The briefing has now been shared as a matter of urgency with relevant colleagues across HM Treasury, HMRC, Department for Business, Innovation, Science and Trade (BIST), and wider Government, ensuring that the practical concerns of the UK aluminium industry are being fed directly into ongoing discussions.
While ALFED and our members support the principle of a UK CBAM that protects domestic industry from carbon leakage and creates a level playing field, significant questions remain around the practical readiness of the scheme. These include default emissions values, verification and accreditation arrangements, recognition of carbon costs paid abroad, sector-specific technical guidance and the interaction with wider UK-EU ETS discussions.
Learning from the EU experience
The paper has been informed by discussions through the ALFED Trade Committee, including feedback from members with direct experience of EU CBAM implementation.
Their experience highlights the importance of having the necessary rules, systems, methodologies and verification arrangements established well in advance. Late publication and continued uncertainty in the EU have made it more difficult for businesses to model exposure, understand potential liabilities, establish compliance processes and make informed commercial decisions.
With the UK implementation timetable becoming increasingly compressed, ALFED is calling for greater certainty as a matter of urgency.
Our recommendations to Government include the publication of a clear implementation roadmap and proposed default emissions values; clarity around verification, accreditation and carbon costs paid abroad; sector-specific technical guidance and practical testing; clarification of the relationship with UK-EU ETS discussions; and a formal mechanism for continued technical engagement with affected industries.
We need your feedback
We continue to encourage ALFED members to share their experiences, concerns and practical questions with us.
This briefing is not the end of our engagement. We will continue feeding member evidence directly into Government as preparations for UK CBAM progress, and the more practical examples we can provide from across the aluminium value chain, the stronger our representation can be.
If there are particular areas of UK CBAM that are causing concern for your business – whether around data, reporting, verification, supply chains, commercial planning or implementation readiness – please get in touch with the ALFED team.
Our priority is to ensure Government understands not only the policy implications of CBAM, but what implementation will mean in practice for UK aluminium businesses.
ALFED will continue to engage closely with Government and members over the coming months, pushing for the clarity and lead time industry needs ahead of January 2027.
To view ALFED’s CBAM Briefing paper, please see below:



