CarbonMeter

CBAM supplier data · CN 2804 10

UK CBAM for hydrogen importers

From 1 January 2027, UK CBAM puts a price on the carbon embedded in imported hydrogen. According to HMRC's CBAM policy summary, importers can report the actual embedded emissions of those goods or use government default values. Default values are not specific to your supplier's plant. The real figure comes from that plant.

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Where the carbon in hydrogen comes from

Hydrogen's emissions depend almost entirely on how it's made: coal gasification is highest, steam methane reforming is high, and electrolysis ranges from near zero on renewable power to high on a coal-heavy grid. EU CBAM counts direct emissions for hydrogen; check the UK rules.

Inputs whose data you need, by carbon impact

These are the goods, precursors and inputs that carry emissions into hydrogen under CBAM. Impact bands are qualitative and vary by plant, production route and power source.

  • Coal

    Very high impact

    Feedstock for gasification. The most carbon-intensive route.

    Data to request: Quantities and carbon content.

  • Coal gasification

    Very high impact

    The highest-emitting route.

    Data to request: Coal use and hydrogen output.

  • Natural gas

    High impact

    Feedstock and fuel for steam methane reforming.

    Data to request: Volumes by use.

  • Steam methane reforming

    High impact

    The most common route today. Carbon capture lowers it substantially where fitted.

    Data to request: Gas use, any CO₂ captured and stored, and hydrogen output.

  • Grid electricity

    Varies with power source

    Electrolysis on grid power inherits the grid's carbon intensity.

    Data to request: Consumption and grid country.

  • Electrolysis

    Varies with power source

    Splits water with electricity. Emissions follow the power source.

    Data to request: Electricity per kilogram of hydrogen and its source.

  • Hydrogen

    Varies with power source

    The imported CBAM good, and a precursor for ammonia.

    Data to request: Production route and embedded emissions per tonne.

  • Renewable electricity

    Low impact

    Near-zero emissions when the supply is genuinely matched to consumption.

    Data to request: Contract and matching evidence.

  • By-product (chlor-alkali)

    Low impact

    Hydrogen from chlorine production. Depends on how emissions are allocated between products.

    Data to request: Allocation method and hydrogen output.

Not counted, or counted as zero, under CBAM: water. You do not need their emissions data for the CBAM return, though quantities can explain a product's figure.

Suppliers to contact, and what to ask

The plant that made the goods holds most of the data. Some inputs come from other companies you may need to reach through it.

Supplier typeWhat they supplyWhat to ask for
Natural gas suppliersSupply reformer feedstock and fuel.Gas volumes, split feedstock and fuel.
Coal suppliersSupply gasification plants.Coal quantities and carbon content.
Power utility (grid)Supply grid electricity for electrolysers.Grid country and, where offered, supply-specific emission factors.
Renewable generatorsSupply renewable power under a direct contract.The contract and evidence that the power was generated and matched.
Chlor-alkali producersProduce hydrogen as a by-product of chlorine.Hydrogen output and how emissions are allocated.

What to do before 1 January 2027

  1. 1. Map. List your imported hydrogen by supplier and tonnage, and find the plant behind each supplier, not just the trader.
  2. 2. Request. Ask the 5 supplier types above for the data listed, starting with the suppliers covering most of your tonnage. Accept the EU CBAM template if they already use it.
  3. 3. Check. Compare each figure with the production route and the default value for that product and country, and send outliers back with a specific question.
  4. 4. Report. Keep the evidence behind every figure. HMRC says the first UK CBAM return and payment, for 2027, are due by 31 May 2028.

CarbonMeter's CBAM readiness pilots do this with you: we map your imports to the plants that made them, request and check the data, and report embedded emissions per supplier and product with the evidence behind each number.

Questions

Which hydrogen goods does UK CBAM cover?

UK CBAM applies from 1 January 2027 to imported hydrogen, commodity codes under CN 2804 10, according to HMRC's CBAM policy summary. The importer is liable once its CBAM goods pass a £50,000 threshold, and can report the actual embedded emissions of the goods or government default values.

Where does the carbon in hydrogen come from?

Hydrogen's emissions depend almost entirely on how it's made: coal gasification is highest, steam methane reforming is high, and electrolysis ranges from near zero on renewable power to high on a coal-heavy grid. EU CBAM counts direct emissions for hydrogen; check the UK rules.

What should a UK importer ask a hydrogen supplier for?

The data that the plant which made the goods holds: for coal, quantities and carbon content.; for coal gasification, coal use and hydrogen output.; for natural gas, volumes by use.; for steam methane reforming, gas use, any CO₂ captured and stored, and hydrogen output.. Many producers already report this to EU customers in the European Commission's CBAM template.

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