"My Turkish/Chinese/Korean supplier pays a carbon price, so I'll get Carbon Price Relief."

Why the scheme existing isn't enough

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 both South Korea's K-ETS and China's CN-ETS. HMRC's own confirmed Qualifying Carbon Pricing Scheme list (announced 27 August 2026, based on information as of 19 June 2026) names both schemes as qualifying — but both currently allocate close to 100% of allowances free to carbon-leakage-exposed sectors including steel. The scheme is real, and confirmed; the price paid by the specific mill can still be structurally close to zero.

Turkey's TR-ETS is a different, more fundamental case, and worth being precise about the distinction. HMRC's confirmed qualifying list names sixteen schemes — Turkey's TR-ETS is not among them. This isn't a free-allocation problem the way China and Korea's is; it's that the scheme does not currently appear to meet HMRC's own qualifying criteria at all. The list is explicitly non-exhaustive and under active review, so this could change — but as things stand, there is currently no confirmed CPR route for Turkish-origin steel, for a different and more basic reason than for Chinese or Korean steel.

India's position is different again: its Carbon Credit Trading Scheme is confirmed on HMRC's qualifying list, 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, despite the scheme itself qualifying.

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.