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Myth vs Fact

The wrong beliefs that are already out there

Every claim traced to the exact statutory provision — because in a market this new, the wrong answer spreads faster than the right one.

Myth "The UK CBAM registration deadline is 31 January 2028 — I've got until then."
Fact Registration is a rolling trigger — £50k trailing-12-month test or a 30-day forward look, whichever fires first — normally due within 30 days. 2027 triggers get HMRC's first-year easement to 31 Jan 2028, but liability and record-keeping run from the trigger date regardless.
Source: FA 2026 Sch 17 para 2 · draft CBAM (Transitory Provision) Regulations 2026 · HMRC CBAM Policy Summary, April 2026
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Myth "My EU CBAM report covers my UK obligations too."
Fact Separate regimes, separate legal bases, separate methodologies. A CBAM certificate or payment under the EU regime does not satisfy UK CBAM, and vice versa — though most of the underlying emissions data can be reused.
Source: FA 2026 Sch 16 · draft CBAM (Emissions & Verification) Regulations 2026
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Myth "I'll file on default values now and correct it once I have verified data."
Fact A return filed on default values cannot later be amended to substitute verified facility data — that specific swap is barred by statute. The data has to be in hand before you file, not after.
Source: FA 2026 Sch 17 para 8(2)
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Myth "My Turkish/Chinese/Korean supplier pays a carbon price, so I'll get Carbon Price Relief."
Fact A scheme existing on paper isn't the same as a cost actually borne. TR-ETS, K-ETS and CN-ETS all grant close to 100% free allocation for steel — CPR is based on the price actually paid, which is structurally near-zero for these origins.
Source: FA 2026 s.150 · draft CBAM (Calculation of CBAM Rate and CPR) Regulations 2026
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