From 1 January 2027, UK businesses importing steel, aluminium, cement, fertiliser or hydrogen will want a verified emissions figure from each producer, because it usually means a smaller CBAM bill than the government's default values. That same figure is exactly the kind of supplier-specific data that makes a Scope 3 footprint better. Once you have it, use it twice.
Two uses for one number
- For CBAM, the producer's verified emissions intensity, in tonnes of CO2e per tonne of product, times the weight you import gives the embodied emissions. HMRC applies the rate for the quarter, less any Carbon Price Relief. Without a verified figure, you use the default for the commodity code, which has a 10% markup in every sector except fertiliser.
- For Scope 3, the same intensity times the tonnes you bought in your reporting year gives the emissions for those purchases under category 1, purchased goods and services. It replaces the spend-based estimate most businesses start with.
Getting the figure is the hard part. Our post on how to ask an overseas supplier for CBAM data has an email template you can copy, and how to work out a UK CBAM bill covers the CBAM sum in full.
A worked example
A fabricator imports 200 tonnes of hot-rolled steel coil (commodity code 72081000) in 2027. Say it paid £600 a tonne, so £120,000 in all. (That price is an assumption for the example, not a market quote.)
| Method | Sum | Tonnes CO2e |
|---|---|---|
| Spend-based Scope 3 estimate | £120,000 × 0.77428 kg per £ (Defra 2023, basic iron and steel) | 92.91 |
| CBAM default value | 200 t × 2.722 t CO2e per tonne | 544 |
| Mill's verified figure (made up for this example) | 200 t × 1.9 t CO2e per tonne | 380 |
For CBAM, the verified figure saves money. At the government's illustrative iron and steel rate of £9.69 per tonne of CO2e, the default would give a charge of about £5,275 and the verified figure about £3,682. The illustrative rate is not the real one: official rates are published each quarter, the first before the end of 2026. Our post on the illustrative rates and default values explains where they come from.
For Scope 3, the verified figure gives 380 tonnes instead of 92.91. That may look like bad news, but it is better data. Defra's multiplier is an average in kg CO2e per pound for a whole industry: it doesn't know what kind of steel you bought, what you paid for it or how it was made. Here the price we assumed, times the multiplier, comes to about 0.46 tonnes CO2e per tonne of steel, well below either per-tonne figure. With supplier data, a switch to lower-carbon steel, or to a mill with a lower figure, shows up in your footprint. With spend data, only a change in what you spend does. Our post on spend-based Scope 3 explains the method and its limits.
Three things to watch
- CBAM counts direct emissions only. The UK charge is based on the direct emissions embodied in the goods. A cradle-to-gate figure for Scope 3, as the GHG Protocol describes for purchased goods, would also include the emissions from the electricity used to make them. For steel made in electric arc furnaces, or aluminium, that can be a large share. If you want the fuller figure, ask your supplier for indirect emissions per tonne as well, and say in your report which you used.
- Don't count the purchase twice. When the supplier figure goes in, take the spend-based line for the same purchases out.
- Match the years. For 2027 imports, the CBAM figure may be the producer's 2026 one if 2027 isn't verified in time. For Scope 3, use the tonnes bought in your reporting year with the most recent figure you have, and note which year it covers.
If you sell to EU customers rather than buy from overseas, the same logic runs the other way: your customer's EU CBAM bill depends on your figure, and so does their Scope 3. See how the EU and UK CBAM differ and our guide to answering a customer's carbon data request.
How Carbon Recycling helps
Carbon Recycling is not a CBAM verifier or tax adviser and doesn't file CBAM returns. It is where the supplier figure becomes part of your footprint.
Every plan includes Scope 1, 2 and 3 with official DESNZ factors, and spend-based Scope 3 from your purchase ledger as a starting point. On the Growth plan, supplier data requests send each supplier a secure link. They send back the emissions for what they supplied to you over the period and how they worked it out, which for CBAM goods is the tonnes you bought times their per-tonne figure. Once you accept it, it goes into your Scope 3 under the category you chose, and you remove the spend-based line it replaces. The CBAM pack, coming soon, works out the embedded emissions and the UK CBAM charge on the same imports.
The 14-day free trial lets you add data and see how your reports look. Printing, saving and downloading need a paid plan.