UK-EU summit set for November 20 with an emissions trading deal on the table: nothing changes yet for either CBAM

On October 12, 2026 Prime Minister Andy Burnham told the House of Commons that the UK-EU summit will take place in Brussels on November 20, 2026 and that "a deal on emissions trading" is on the table. The statement announces no agreement. It follows a POLITICO report of October 7, relayed by Carbon Pulse, that a link between the UK and EU emissions trading systems had been agreed. UK goods entering the EU remain subject to the EU CBAM, and the UK CBAM starts on January 1, 2027 for EU goods as for any other import.

What the Prime Minister said, and what he did not

The statement fixes the summit date and names emissions trading as one of its subjects; it does not say that a link has been agreed.

The transcript on gov.uk, published the same day, reads: "I can confirm to the House today that it will take place in Brussels on the 20th November." And: "On the table is a trade deal on food and drink products, a deal on emissions trading progress towards linking our energy systems, a new youth experience scheme and deeper cooperation on immigration."

The gov.uk transcript prints no comma after "emissions trading"; the Official Report (Hansard) prints one, so emissions trading and energy systems are separate items. The Prime Minister added that he "will work hard over the next 5 weeks to achieve it", which describes a deal still to be secured.

Three things are missing from the statement.

• No agreement text, and no statement that negotiations have concluded.
• No date on which a link would take effect.
• No mention of CBAM: the words "CBAM" and "carbon" do not appear in the transcript.

Carbon Pulse wrote on October 7, 2026 that POLITICO had reported an agreement, with a deal "expected to be unveiled at a bilateral summit next month". That is a media report, and cbamguide.com has not read the POLITICO article. The negotiation record is in the guide to UK and EU ETS linkage.

Why an ETS link matters for both CBAMs

Each side's law makes a linking agreement the condition for exempting the other's goods, but neither exemption is automatic and nothing is exempt today.

On the EU side, Article 2(4) of Regulation (EU) 2023/956 takes goods out of the EU CBAM when they originate in a country or territory listed in point 1 of Annex III. The United Kingdom is not on that list.

Article 2(6) sets two conditions for a listing. Either the EU ETS applies to the country, or an agreement has been concluded "fully linking the EU ETS and the emission trading system of that third country or territory". The carbon price must also be "effectively charged" on the embedded emissions, with no rebates beyond those of the EU ETS.

The listing itself needs a Commission delegated act under Article 2(11), which enters into force only if neither the European Parliament nor the Council objects within two months, extendable by two more (Article 28(7)). Until then EU importers owe certificates on UK-origin goods.

The UK CBAM is charged on in-scope goods from every origin outside the UK. Section 156 of the Finance Act 2026 lets the Treasury make regulations "excluding emissions embodied in goods that originate from a country or territory with a linked emissions trading scheme from the charge to CBAM". Under section 157(4) and (9) the House of Commons must approve a draft first; a title search of legislation.gov.uk on October 13, 2026 found none.

HMRC's policy summary, updated September 9, 2026, states: "There are currently no jurisdictions exempt from CBAM." The two regimes are compared in UK CBAM vs EU CBAM.

The trade at stake

The EU imported €7.28 billion of CBAM-covered goods (Annex I codes) from the United Kingdom in 2025, the third-largest origin by value after China and Türkiye (Eurostat Comext, 2025).

Iron and steel made up €4.37 billion of that, aluminium €1.58 billion and electricity, which only the EU CBAM covers, €1.16 billion (Comext DS-045409, extracted October 12, 2026). These are trade statistics, not CBAM declarations.

The UK imported 9.16 million tonnes of steel in 2025, 4.86 million tonnes of it recorded from EU member states (HMRC Overseas Trade Statistics, extracted October 12, 2026; this site's selection of steel codes, not the exact Schedule 16 list).

Where the UK CBAM rulebook stood on October 13

SI 2026/809, on calculating the UK CBAM rate and carbon price relief, passed a committee debate on October 12, 2026. The House of Commons had not approved it as of October 13, and the approval period ends on October 20.

SI 2026/809 was made on July 13, 2026. Hansard records that James Murray, Financial Secretary to the Treasury and Paymaster General, moved the motion in the Second Delegated Legislation Committee, which voted 10 to 4 that it "has considered" the regulations.

That vote is not the approval. Under section 157(10) of the Finance Act 2026 the instrument ceases to have effect unless the House of Commons approves it by resolution within a set period. Parliament's procedure record, read on October 13, shows no approval and a period ending October 20, 2026.

Asked about fertiliser, the minister said that "the Government will publish illustrative CBAM rates very shortly", without a date. He gave the EU emissions trading scheme as an example of a qualifying scheme for carbon price relief, so that importers "should not pay twice for the same emissions".

Three gaps remained as of October 13, 2026.

• First UK CBAM rate and default values notice: neither published. The first rate rests on UK ETS auction prices from October to December 2026, and HMRC's CBAM collection says guidance on both will come "soon".
• Force of law notices: both still drafts; on October 9, 2026 HMRC reissued one in a new file format.
• Verifiers: UKAS has announced no UK CBAM verifier accreditation. Its technical bulletin of October 8, 2026 says it "is developing" the accreditation arrangements.

Timeline: October 2026 to May 2028

Only the three dates from January 1, 2027 bind importers; nothing earlier in the table changes a liability.

Legal sources are on the UK CBAM deadlines page.

What to do now

Keep preparing for both regimes until a legal text exists, because a summit announcement changes no liability.

1. UK importers: for every origin, EU goods included, keep import records from January 1, 2027, test the £50,000 threshold and collect the evidence for carbon price relief on EU-made goods.
2. EU importers of UK goods: keep UK-origin goods in your CBAM records, collect emissions data from UK installations and budget certificates at the official quarterly price, €82.32/tCO₂e for the third quarter of 2026.
3. UK exporters: keep supplying emissions data to EU customers, and do not price contracts on an exemption that does not exist.
4. Everyone: record each consignment's origin, which would decide any future exemption (Article 2(5) of the EU regulation).

If you need outside help with either regime, describe the job on the CBAM help page and cbamguide.com introduces you by email to providers that fit.