Booost Submits Public Comments on UK CBAM Secondary Legislation

Booost Inc., a provider of the leading 'Sustainability ERP' and advocate for the 'Sustainability 2026 Problem,' announced that it has submitted a technical consultation response to the UK government (HM Treasury and HMRC) regarding secondary legislation and technical documents for the UK CBAM. Based on its experience supporting Japanese manufacturers, exporters, and trading companies with CBAM compliance, the company provided recommendations regarding practical challenges in the downstream steel supply chain, particularly for products like screws and bolts (HS7318) and other steel products (HS7326). The UK is preparing for the introduction of the UK CBAM in 2027, which will require the declaration of embodied emissions and carbon price adjustments for imported goods such as steel, aluminum, and cement. Given that many Japanese companies operate within multi-layered supply chains, the administrative burden of collecting and verifying emission data is significant. Booost's submission aims to balance the effectiveness of the regulation with practical operational feasibility. Key recommendations include clarifying the system boundary for downstream steel products, reducing the burden of third-party verification, considering the difficulty of obtaining information from upstream material manufacturers, ensuring that low-emission supply chains are not disadvantaged, simplifying carbon price relief, and allowing for data interoperability. Moving forward, Booost will continue to strengthen its support for global carbon border measures through its 'booost CBAM' application and 'booost Data EX-PF' platform.