Reasonable on its face — Turkey, China, and South Korea all operate real, government-run emissions trading schemes, and CBAM's whole premise is crediting carbon costs already paid elsewhere. If the scheme exists, relief should follow.
A qualifying scheme existing on paper isn't the same as a cost actually borne. Relief is based on price paid, not price listed.
Carbon Price Relief is calculated on the carbon price actually paid on the goods — not the headline price of the emissions trading scheme the producer operates under. HMRC's own guidance, published 16 July 2026, states this outright: "You do not need to get information on the price of emissions that were subject to free allowances or were beneath the threshold... This information should not be included when working out how much Carbon Price Relief you may claim." A scheme can tick every box for "qualifying" (government-administered, mandatory participation, publicly available rules and price) and still generate zero relief, if the sector in question receives free allocation that reduces the price actually paid to nil.
That's precisely the position for steel — CBAM Proof's largest client sector — under all three of Turkey's TR-ETS pilot, South Korea's K-ETS, and China's CN-ETS, each of which currently allocates close to 100% of allowances free to carbon-leakage-exposed sectors including steel. The scheme is real; the price paid by the specific mill can still be structurally close to zero.
India's position is different again: its Carbon Credit Trading Scheme is live, but there's no confirmed qualifying £/tCO₂ price yet, and the Coal Cess that previously functioned as a carbon price was abolished in September 2025. There's currently no established relief mechanism to point to for Indian-origin goods.
One more mechanic worth knowing, confirmed in the same HMRC guidance: even where a scheme does qualify, the relief calculation uses the mean average headline carbon price over the calendar quarter before the quarter of import — not the price paid on the specific shipment. That's a further reason a scheme's headline number rarely translates cleanly into your actual relief figure.
The angle that actually works for all four origins isn't chasing a CPR claim that the scheme structure won't support — it's replacing HMRC's default emission values with your supplier's verified facility-specific data. Defaults are set at worst-case intensity; verified data is the only lever that moves the underlying emissions number, regardless of what CPR does or doesn't apply.
| Origin | Scheme | Effective CPR |
|---|---|---|
| Turkey | TR-ETS pilot (2026–2027) | ~Zero — near-100% free allocation for steel |
| South Korea | K-ETS Phase 4 | ~Zero — steel treated as carbon-leakage sector |
| China | CN-ETS (expanded 2024) | ~Zero — near-100% free allocation through current period |
| India | CCTS | No confirmed qualifying price; Coal Cess abolished Sept 2025 |
| EU | EU ETS | Genuine — real evidenced carbon cost |
If CPR won't move the number, verified facility data is what will.
See what verified data does to your liability →