Who is reading?
The six answers are the same for everyone. Which order you read them in, and the path through them, is not.
Two carbon border regimes now reach Indian exporters, and they are on different clocks. The EU's mechanism has been live since 1 January 2026 and covers cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. The UK's starts on 1 January 2027 and covers the same list without electricity. Both work the same way in principle: the importer pays for the carbon embedded in the goods, less whatever carbon price was already paid where they were made.
That deduction is where India's Carbon Credit Trading Scheme enters. On 27 August 2026 HMRC listed CCTS as a qualifying carbon pricing scheme for the UK, which is the story that reached Indian coverage on 7 September. It is real and it matters. It is also the smaller and later of the two markets. The EU route for recognising a foreign carbon price runs through Article 9 of its own regulation, and the rules for operating it are not settled.
The uncomfortable part is the same on both sides of the Channel. Relief is calculated from the carbon price actually borne, not from the existence of a scheme. Emissions covered by free allowances carry no price. CCTS sets emission intensity targets, so a plant that meets its target has paid nothing to deduct. And no Indian carbon credit certificate has ever traded at a published price, which is the number both calculations need. This track holds what each regime requires, in numbers, and a dated account of what does not yet exist.
The six slots
- Trigger — Two regimes, two clocks, one already running Settled
- Requirement — Deduction is a calculation, not a status In motion
- Instruments — One form specified, one still unclear In motion
- Readiness — Recognised, and still not claimable Absent
- Economics — Eligibility is settled. The amount is not. Absent
- Response — No observable behaviour on either side yet Absent
Observer
Learning how carbon border regimes interact — advisor, investor, journalist, student
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1TriggerSettled
Two regimes, two clocks, one already running
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2RequirementIn motion
Deduction is a calculation, not a status
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3InstrumentsIn motion
One form specified, one still unclear
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4ReadinessAbsent
Recognised, and still not claimable
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5EconomicsAbsent
Eligibility is settled. The amount is not.
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6ResponseAbsent
No observable behaviour on either side yet
Exporter to the EU
An Indian producer of cement, iron or steel, aluminium, fertilisers, electricity or hydrogen already inside the live EU regime
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1TriggerSettled
Two regimes, two clocks, one already running
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2RequirementIn motion
Deduction is a calculation, not a status
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3ReadinessAbsent
Recognised, and still not claimable
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4EconomicsAbsent
Eligibility is settled. The amount is not.
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5InstrumentsIn motion
One form specified, one still unclear
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6ResponseAbsent
No observable behaviour on either side yet
Exporter to the UK
An Indian producer in the five UK-covered sectors, with a fixed 1 January 2027 start
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1TriggerSettled
Two regimes, two clocks, one already running
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2InstrumentsIn motion
One form specified, one still unclear
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3RequirementIn motion
Deduction is a calculation, not a status
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4ReadinessAbsent
Recognised, and still not claimable
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5EconomicsAbsent
Eligibility is settled. The amount is not.
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6ResponseAbsent
No observable behaviour on either side yet
CCTS obligated entity
A plant already carrying a GEI target, asking whether CCTS compliance buys anything abroad
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1EconomicsAbsent
Eligibility is settled. The amount is not.
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2ReadinessAbsent
Recognised, and still not claimable
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3RequirementIn motion
Deduction is a calculation, not a status
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4TriggerSettled
Two regimes, two clocks, one already running
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5InstrumentsIn motion
One form specified, one still unclear
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6ResponseAbsent
No observable behaviour on either side yet
The slots in full
Trigger Settled
Why does this reach me?
Both regimes are law. The EU's has been operating since January 2026; the UK's starts January 2027. Checked 9 Sep 2026.
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The EU CBAM definitive regime has applied since 1 January 2026
It covers cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. EU importers above a single mass-based threshold of 50 tonnes of CBAM goods must become authorised CBAM declarants, buy certificates from their national competent authority, declare embedded emissions and surrender certificates annually.
European Commission — CBAM definitive regime · checked 2026-09-09 verified
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UK CBAM applies from 1 January 2027 to aluminium, cement, fertiliser, hydrogen, and iron and steel
The UK list omits electricity, which the EU includes. A producer shipping to both markets faces two different scopes, two different start dates and two different evidence regimes for the same goods.
HMRC — CBAM: list of current qualifying carbon pricing schemes · checked 2026-09-09 verified
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India's Carbon Credit Trading Scheme is a recognised qualifying carbon pricing scheme for the UK
Listed as 'Indian Carbon Credit Trading Scheme (CCTS)', one of sixteen schemes, alongside the EU ETS, China's national ETS, K-ETS and NZ ETS. Published 27 August 2026 by HM Revenue and Customs, reflecting information available as of 19 June 2026. Reported in India on 7 September, eleven days later.
HMRC — CBAM: list of current qualifying carbon pricing schemes, published 27 August 2026 · checked 2026-09-09 verified
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UK recognition is conditional and can be withdrawn
HMRC states that if, after 19 June 2026, a listed scheme changes such that it no longer fully meets the criteria, it will not be a qualifying carbon pricing scheme. HMRC also describes the list as a draft kept under review. CCTS is still being built out, so its status depends on the design continuing to satisfy UK criteria.
HMRC — CBAM: list of current qualifying carbon pricing schemes · checked 2026-09-09 verified
Richard’s view
The recognition India celebrated in September applies to the market that has not started yet. The one already charging is the EU's, live since January. If you export to both, the urgent regime is the one nobody wrote a headline about.
Next step Someone else
The Commission's definitive-regime page and HMRC's qualifying list
Between them these two pages establish scope, start dates and the deduction principle for both regimes. Short, plain and authoritative.
Both are government publishers. We have no relationship with either and receive nothing if you read them. Monitored since 9 Sep 2026, last checked 9 Sep 2026.
Requirement In motion
What would have to be true, in numbers?
The UK calculation is published and final. The EU's route for deducting a foreign carbon price is set in principle but its operating rules are not settled. Checked 9 Sep 2026.
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Both regimes deduct a carbon price already paid, rather than exempting recognised countries
The Commission states that if importers can prove a carbon price has already been paid during production of the imported goods, the corresponding amount can be deducted. HMRC's relief works the same way. Neither grants a country-level exemption.
European Commission — CBAM definitive regime · checked 2026-09-09 verified
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The EU certificate price tracks the EU ETS auction price, as a quarterly average in 2026 and a weekly average from 2027
Authorised CBAM declarants buy certificates from the national competent authority in their country of establishment, priced in euro per tonne of CO2.
European Commission — CBAM definitive regime · checked 2026-09-09 verified
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UK relief requires a completed carbon pricing verification form, independently verified, covering one of the two calendar years before import
The importer must obtain the form from the installation or through the supply chain. HMRC states plainly that relief cannot be claimed if the form cannot be obtained or was not completed by an appropriate verifier.
HMRC — Get a carbon pricing verification form · checked 2026-09-09 verified
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The UK effective carbon price is total priced emissions divided by total installation emissions, and excludes free allowances
Emissions are split across the elements of the scheme and multiplied by each element's price per tCO2e. HMRC instructs that free allowances are not calculated, since their price is zero. Greenhouse gas removals with no public price are excluded on the same logic. Compensation, rebates and refunds reduce relief.
HMRC — Work out your Carbon Price Relief · checked 2026-09-09 verified
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The UK price used must be publicly available and drawn from the previous calendar quarter
For the headline carbon price, graduated carbon prices and greenhouse gas removals, HMRC requires a publicly available price from the previous calendar quarter, taken as a mean average where not fixed. Relief is then converted to sterling at HMRC-published rates and capped at the CBAM liability due.
HMRC — Work out your Carbon Price Relief · checked 2026-09-09 verified
What does not exist
The EU's operating rules for deducting a foreign carbon price under Article 9 are not confirmed as final
The Commission states the deduction principle plainly, but the detailed implementing rules — how a scheme is recognised, what evidence is required, who certifies it — are the part that decides whether an Indian plant can actually claim anything. Secondary coverage describes a draft implementing regulation circulated in May 2026 with a consultation closing in June 2026. We have not read an adopted text and do not cite one. Until that is confirmed against the Commission's own legislation page, the EU requirement is stated here only at the level the Commission itself states it.
Monitored since 2026-09-09 · last checked 2026-09-09
Richard’s view
Read both calculations and the same structure appears twice: eligibility is the easy half, evidence is the hard half, and the input that decides the number is a price India has not yet produced. The UK has published its arithmetic in full. The EU has published the principle. Neither can be completed today by an Indian installation.
Next step Someone else
HMRC's relief calculation guidance
It carries a fully worked numerical example, including the compensation adjustment. It is the clearest published statement of how either regime turns a foreign carbon price into money off.
HMRC is a government publisher. No commercial relationship, no referral, nothing received. Monitored since 9 Sep 2026, last checked 9 Sep 2026.
Instruments In motion
What counts as a valid response?
The UK instrument and verifier standard are fully specified. The EU equivalent is not established here. Checked 9 Sep 2026.
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The UK instrument is the carbon pricing verification form, published under an HMRC force-of-law notice
It records the installation's total emissions in tCO2e for a calendar year, broken out across the scheme elements those emissions were subject to. Where a scheme charges emissions indirectly, this must be converted to tCO2e using that scheme's emissions factors.
HMRC — Get a carbon pricing verification form · checked 2026-09-09 verified
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The UK form must break emissions into five defined elements
Headline carbon price; free allowances; graduated carbon prices, where emissions above a threshold are priced higher than the headline rate; greenhouse gas removals; and thresholds, where emissions below a level are charged at zero. Compensation received or due is recorded separately. The elements other than compensation must sum to the installation's total emissions.
HMRC — Get a carbon pricing verification form · checked 2026-09-09 verified
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The UK verifier must be accredited by a full member of the Global Accreditation Cooperation and independent of the installation, the importer and the jurisdiction
The accreditation body must be a GAC full member and a signatory to the GAC Multilateral Recognition Agreement. The verifier must hold accreditation to ISO/IEC 17029:2019, ISO 14064-3:2019, ISO 14065:2020 and ISO 14066:2023 at the time of verification.
HMRC — Get a carbon pricing verification form · checked 2026-09-09 verified
What does not exist
The EU's evidence instrument for a claimed foreign carbon price is not established on this track
The UK has named one form and four ISO standards. The EU equivalent has not been read from a Commission source here, so we do not state one. For a producer shipping to both markets the practical question is whether a single verification exercise can satisfy both regimes or whether two are required, and that cannot be answered until the EU instrument is confirmed.
Monitored since 2026-09-09 · last checked 2026-09-09
Richard’s view
The four ISO standards are the interesting line on the UK side. BEE's own accreditation procedure for ACV agencies leans on ISO 14065, and it issued a separate clarification on that requirement. Whether an agency accredited for CCTS work also satisfies the full UK set, under an accreditation body the UK accepts, is a different question from whether it is on BEE's register — and nobody appears to have asked it publicly.
Next step Someone else
HMRC's verifier standards, and the Commission's legislation page
HMRC names the four ISO standards and links both the force-of-law notice containing the form and the Global Accreditation Cooperation full member list. The Commission's legislation and guidance page is where the EU implementing rules will appear when adopted.
Government and independent publishers. No relationship, no referral fee. Monitored since 9 Sep 2026, last checked 9 Sep 2026.
Readiness Absent
Can this actually be done today?
Eligibility exists on paper in the UK. The inputs either calculation needs do not exist in India today. Checked 9 Sep 2026.
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The ICM portal's Statistics section, the likely first official source of Indian price data, still reads 'Coming Soon'
ICM portal — statistics · checked 2026-09-09 verified
What does not exist
No publicly available CCTS price per tCO2e exists, so neither regime's deduction can be computed
HMRC requires a publicly available price from the previous calendar quarter for the headline carbon price element, and any EU deduction rests on the same kind of evidence of a price actually paid. No Indian carbon credit certificate has traded at a published price and the portal's Statistics section is not populated. Until a public price exists an Indian installation cannot complete step 3 of HMRC's own calculation. This is the binding constraint, and it sits in India, not in Europe.
Monitored since 2026-09-09 · last checked 2026-09-09
It is unconfirmed whether verifiers accredited for CCTS work satisfy the UK's verifier test
The UK requires accreditation by a Global Accreditation Cooperation full member and MLA signatory, plus accreditation to ISO/IEC 17029, ISO 14064-3, ISO 14065 and ISO 14066. India's national accreditation body NABCB describes itself as a GAC signatory, but that is the body's own description; we have not confirmed it against the GAC full member directory, nor confirmed which Indian verifiers hold all four standards. Until that is resolved, no exporter can be told with confidence who can sign their form.
Monitored since 2026-09-09 · last checked 2026-09-09
HMRC does not define what 'independent of the jurisdiction of the qualifying carbon pricing scheme' excludes
The verifier must be independent of the installation, the importer and the jurisdiction. Read narrowly this bars state-linked bodies; read broadly it could complicate the use of Indian verifiers for an Indian scheme. Two of the fifteen agencies on BEE's ACVA register are industry federations. The wording is published but its scope is not, and guessing at it would be a claim we cannot source.
Monitored since 2026-09-09 · last checked 2026-09-09
No confirmation that CCTS obligated entities hold installation-level emissions in the per-element breakdown the UK form requires
CCTS reporting is organised around greenhouse gas emission intensity against a target. The UK form wants total installation emissions apportioned across headline price, free allowances, graduated prices, removals and thresholds. These are not the same shape, and the mapping between them has not been published by either government.
Monitored since 2026-09-09 · last checked 2026-09-09
Richard’s view
This is the slot that matters, and it is empty on purpose. An exporter reading the headlines will conclude that a discount is now available. What is actually available is eligibility, in one of the two markets, for a discount whose size cannot yet be computed, evidenced on a form that may not yet have a qualified signatory in India, using a price that does not exist. None of that makes the recognition unimportant — it had to happen first. It does mean the work between now and January 2027 is evidence work, and it has not started.
Next step Our service
Readiness review for a Europe-bound plant
A scoped assessment of one installation: whether its emissions data can be mapped to the five HMRC elements, what a verifier would need, which of the two regimes actually bites first for your shipments, and what remains blocked pending an Indian public price. The output is a written gap list with dates, not an assurance that relief is claimable — because on today's facts it is not.
This is our own paid advisory service and we would be the provider. We are not accredited to verify, and nothing in this review substitutes for an independent verifier's form. Named alternative providers do not yet exist for this specific question; if that changes we will say so here. Monitored since 9 Sep 2026, last checked 9 Sep 2026.
Economics Absent
What does it cost, and what is it worth?
The UK rules for computing relief are settled; the inputs that would give either regime's deduction a value are not. Checked 9 Sep 2026.
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UK relief cannot exceed the CBAM liability due
HMRC — Work out your Carbon Price Relief · checked 2026-09-09 verified
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HMRC states that in some cases no carbon price relief will be available
The examples given are where all emissions are covered by free allowances, or where a scheme provides full relief or rebates.
HMRC — CBAM: list of current qualifying carbon pricing schemes · checked 2026-09-09 verified
What does not exist
The value of UK recognition to any specific Indian exporter cannot be computed
Relief is effective carbon price multiplied by embodied emissions. The first term needs a public Indian price that does not exist. CCTS also sets emission intensity targets rather than an absolute cap, so an entity that meets its target bears no carbon cost and has nothing to deduct. Any figure quoted today for what this saves Indian exporters is an assumption and should be labelled as one.
Monitored since 2026-09-09 · last checked 2026-09-09
No published mapping between CCTS compliance outcomes and the 'free allowances' and 'thresholds' elements
How an intensity-target scheme is expressed in a form designed around absolute allowances determines how much of an installation's emissions count as priced. That single mapping decision probably moves the number more than anything else on this track.
Monitored since 2026-09-09 · last checked 2026-09-09
No figure for Indian exposure by regime
The commercially decisive question is how much Indian tonnage in the covered sectors goes to the EU versus the UK, because one regime is charging now and the other starts in January. We have not sourced trade volumes for the covered CN codes and will not estimate them.
Monitored since 2026-09-09 · last checked 2026-09-09
Richard’s view
The commercially useful sentence is not 'the UK has recognised CCTS'. It is 'Europe will discount your border liability by the carbon price you actually paid, and India has not yet established what anyone pays'. The first sentence is news. The second is the one that changes what a finance team does this quarter.
Next step Nobody yet
No defensible relief estimate exists yet
Nobody, ourselves included, can give a credible number for what CBAM relief is worth to an Indian exporter, because the effective carbon price input does not exist. We monitor the ICM Statistics section, the UK qualifying list and the Commission's legislation page weekly, and this slot changes the week a public Indian price appears.
A dated negative finding, not a referral. We would be a candidate provider once the inputs exist and we will disclose that plainly at the time. Monitored since 9 Sep 2026, last checked 9 Sep 2026.
Response Absent
What are the options, and what are others choosing?
The EU regime is live but no Indian deduction behaviour is observable to us, and the UK regime has not started. Checked 9 Sep 2026.
What does not exist
No evidence of any Indian installation obtaining a carbon pricing verification form
The form is the gating artefact for every UK relief claim. The first Indian installation to hold a compliant one will have solved the verifier question in practice, which is currently unresolved in theory. That is the signal worth waiting for.
Monitored since 2026-09-09 · last checked 2026-09-09
No published position from the Indian government on how CCTS data will be made usable for CBAM claims
Neither BEE nor the ICM portal has published anything on the UK recognition as of 9 September 2026, thirteen days after HMRC listed CCTS. Whether India intends to publish a reference price or a data-sharing route is the most useful thing that could be said next, and nobody has said it.
Monitored since 2026-09-09 · last checked 2026-09-09
Richard’s view
There is a temptation to fill this slot with what exporters 'should' do. That is advice dressed as observation. The truthful version is that the EU regime has been charging since January, the UK starts in January, no Indian claim behaviour is visible to us in either, and this track will record the first that is.
Next step Nobody yet
No participant behaviour to report
We watch the UK qualifying list, HMRC's CBAM collection, the Commission's CBAM pages and the Indian portals weekly, and will record the first evidence of an Indian installation claiming a carbon price deduction in either regime.
A dated negative finding, not a referral. Monitored since 9 Sep 2026, last checked 9 Sep 2026.
Not citable — deliberately withheld
| Claim | Why it is not used |
|---|---|
| UK recognition of CCTS reduces the tax burden on Indian exporters by a stated amount | Widely reported in this form. Relief is a calculation from an effective carbon price that does not yet exist in India, and HMRC says in some cases no relief will be available. No quantified claim is defensible today. |
| His Majesty's Treasury notified BEE of the recognition | Reported by PTI on 7 September 2026. The authoritative public artefact is an HM Revenue and Customs guidance page published 27 August 2026. A letter from HMT may exist but we have not seen it, so the department is reported, not verified. |
| The EU has recognised CCTS, or that UK recognition carries over to the EU | Not established. These are separate regimes under separate law. The Commission states the deduction principle but we have not read an adopted EU instrument recognising CCTS, and we do not infer one from the UK decision. |
| The EU Article 9 implementing rules are final, or their contents | Secondary sources describe a draft circulated in May 2026 with a consultation closing in June 2026. We have not read an adopted text on the Commission's own legislation page and will not describe rules we have not read. |
| Indian ACV agencies can sign the UK carbon pricing verification form | Not established. Requires confirmation of NABCB's Global Accreditation Cooperation full membership and MLA signatory status, and of which verifiers hold ISO/IEC 17029, ISO 14064-3, ISO 14065 and ISO 14066. Being on BEE's ACVA register does not answer the UK test. |
Beta — read this before you rely on a figure
What this is. Each track answers the same six questions about one subject and shows the date each answer was last checked. Every claim names the primary document it came from. Where something does not exist yet, that is stated with the date the watch began.
What beta means here. The system that assembles these pages is new. Slots may be drafted by an automated research process before an editor reviews them, and no page is published until a person has read it and signed it off. Some sources cannot be read automatically, and where that is true the page says so rather than reporting an unchanged figure.
Check the source before you act. These pages are a starting point for your own reading, not a substitute for it. Rules, prices, accreditations and eligibility lists change between checks, and a date on this page is the date it was last verified, not a guarantee it is current today. Every claim links to the document it came from. Use that document.
Not advice. Nothing here is legal, financial, compliance or investment advice, and it is not a recommendation to buy, sell or retire any carbon credit or to take any regulatory position. It does not create a client relationship. For a decision that carries money or liability, take professional advice on your own facts.
Interests to declare. Richard N. Bright is CEO of Carbon Registry India, a non-profit standard and an NCCF initiative, and provides paid advisory services. Where a track points a reader towards those, it is disclosed on that slot. Most slots point somewhere else, and some point nowhere, which is the honest answer more often than the field admits.
Corrections. If a figure here is wrong, say so and it will be corrected and dated. That is the fastest way to make this better, and it is welcome.