Trade & Customs Watch is our weekly briefing on the customs, tariff and trade-regulatory developments that matter to businesses moving goods across borders and to the administrations that control them. Each item is drawn from the primary record and linked to it, with a short note on what it means in practice.
The week in brief
The United Kingdom’s carbon border adjustment mechanism moved from policy into law, with secondary legislation laid on 9 September for a start on 1 January 2027, a fortnight after the European Commission published the guidance its verifiers and accreditation bodies will work to. India’s exit from the UK’s Developing Countries Trading Scheme was formally notified, a consequence of the UK–India trade agreement that will change the origin regime for a very large supply base. Three UK consultations on the future shape of the customs regime close within the next ten days. And the Commission released a point update of the EU Customs Data Model, a reminder that declaration data standards are now maintained on a release cycle rather than fixed at go-live.
UK CBAM: secondary legislation laid, start date confirmed
HMRC, 9 September 2026. HMRC updated its CBAM policy summary to record that the Carbon Border Adjustment Mechanism (Emissions and Verification) Regulations 2026 were laid on 9 September, alongside the primary powers already taken in the Finance Act 2026. The mechanism commences on 1 January 2027 and covers aluminium, cement, fertiliser, hydrogen, and iron and steel.
What it means. The UK CBAM is a tax rather than a customs duty. The liability attaches to the importer on a return, not to the customs entry, so it will not be handled automatically by a customs broker in the way that duty is. Importers in the five sectors have roughly fifteen months to establish how embodied emissions will be calculated, monitored and verified for each supplier, and the verification requirement is the part of the build most likely to be underestimated.
EU CBAM: guidance for verifiers and accreditation bodies
European Commission, DG TAXUD, 24 August 2026. The Commission published guidance for CBAM verifiers and national accreditation bodies, following a series of guidance documents issued on 14 August for the definitive period.
What it means. Read with the UK item above, the direction is clear: both regimes require the declared emissions figure to be verified by an accredited third party rather than asserted by the importer. Verifier capacity, not tariff arithmetic, is likely to be the binding constraint on compliance in 2027. A business with exposure in both markets should establish early whether a single accredited verifier can serve both regimes rather than building two parallel compliance paths.
India to leave the Developing Countries Trading Scheme
Department for Business and Trade, 4 September 2026. The Department published a country graduation notice confirming that India will exit the DCTS after a two-year transition period following signature of the UK–India Comprehensive Economic and Trade Agreement. A separate notice moves Bhutan between DCTS preference tiers.
What it means. The duty outcome for Indian-origin goods is broadly preserved; the compliance regime is not. Under the DCTS, preference is unilateral and origin is established under the scheme’s own rules. Under the agreement it becomes reciprocal, with the agreement’s rules of origin, documentation and verification procedures, and an exporter-declaration architecture in place of the scheme’s. Importers sourcing from India should treat the transition as a two-year project to re-establish origin evidence under the new rules, including cumulation, proof requirements and supplier declarations, rather than as a date in the diary.
Three UK consultations closing this month
HMRC and HM Treasury, closes 15 September 2026. The call for evidence on modernising the UK customs regime asks three questions: how future trade patterns will affect the customs system; how customs data should evolve alongside digitalised business operations; and whether the current approach to customs authorisations is fit for a modernised trading world.
HMRC, closes 21 September 2026. The consultation on mandatory registration of customs intermediaries covers the rationale for a statutory register, its scope, minimum registration requirements and enforcement. It follows the publication of a customs intermediary standard (PAS 41201:2026) in June and a voluntary certification scheme now in development.
Department for Business and Trade, closes 14 September 2026. A call for input on deepening trade relationships with Indonesia, the Philippines, the United Arab Emirates and Uruguay, framed principally around those economies’ possible accession to the CPTPP.
What it means. The authorisations question in the customs modernisation call for evidence is the one with lasting consequence: it is where the UK will either preserve or move away from the authorised economic operator architecture it inherited, and the question is being asked in the open. The intermediaries consultation is of interest well beyond the UK. The sequencing of a published standard, then voluntary certification, then a statutory register, is a model that customs administrations elsewhere considering broker licensing would do well to study, because it defines competence before it licenses a sector.
EU Customs Data Model 7.0.1 released
European Commission, DG TAXUD, 27 August 2026. The Commission released version 7.0.1 of the EU Customs Data Model.
What it means. A point release rather than a structural change, but the discipline is the lesson. The EUCDM is the most mature worked example of a harmonised declaration data model in existence, and it is maintained on a release cycle. For any administration designing a single window or replacing a customs management system, the data model is a maintained standard to be governed, not a one-off mapping delivered at go-live and then frozen. Software providers serving EU declarants should confirm their alignment to the new version.
WCO study on the origin of remanufactured and recycled goods
World Customs Organization, 28 July 2026. The WCO published a study examining how origin is determined for goods that have been remanufactured or recovered.
What it means. Circular-economy supply chains are expanding faster than the origin rules that govern them, and remanufactured goods sit awkwardly in most preferential regimes as currently drafted. This is the first substantial multilateral treatment of the question and the reference point to reach for when a preference claim on remanufactured product is challenged.
Trade & Customs Watch is compiled from primary sources: HMRC, the Department for Business and Trade, the European Commission’s Directorate-General for Taxation and Customs Union, the World Customs Organization and national customs administrations. Items are summarised; the linked record is authoritative. Commentary is our own and is general in nature, not advice on any particular transaction. To discuss what any of these developments means for your business or administration, contact us.