Excluded from BICS by your SIC code? What appeals can and cannot fix
Last updated 31 July 2026.
If your manufacturing looks like the activity BICS was designed for but your SIC code is not on the eligible list, the government has confirmed an appeals process exists for businesses excluded in error. Read closely, that is narrower than it first appears, and it may not reach a business that is correctly classified and simply not listed.
The list is closed
The eligible list froze on 8 July 2026: 84 four-digit SIC codes and 1,641 six-digit HS product codes, final for 2027, with the government stating it does not intend further changes. Eligibility for the first year is defined strictly by those lists, using SIC 2007 codes. The move to the revised SIC 2026 classification has been deferred to the 2030 review.
That finality is why the appeals process matters, and why its scope matters more.
Who this affects
The casualties are businesses whose real activity matches the policy intent but whose classification does not. Chemicals is the clearest example: formulators, adhesives manufacturers and detergent producers who manufacture physical products but record a SIC code such as 2059, which is not on the list, and whose adjacent codes are not on it either. Some can legitimately re-examine whether their recorded SIC reflects what they actually do. Others are simply classified outside the scheme. Note the limit on that: a company cannot solve the problem by changing its registered SIC. It would have to demonstrate that it genuinely operates within an eligible activity and manufactures an eligible product, and DBT has said it will require evidence beyond the self-declared Companies House code.
It also affects companies whose Companies House SIC code is wrong or out of date, which is common. Businesses can change what they manufacture faster than they update their filings. The Companies House record is therefore the starting point, not the whole assessment: the applicant will still need to evidence its genuine manufacturing activity and its eligible products.
What an appeal is, and what it is not
The confirmed scope is narrow. The appeals process is described as being for businesses that may have been excluded from the scheme in error. That is a mechanism for correcting misclassification, not for arguing that a sector-level threshold produced an unfair result in a particular case.
The uncomfortable implication is that a correctly classified business in a deliberately excluded sector may have no individual route into BICS at all. That follows directly from the design: electricity intensity was tested at sector level, and the government explicitly rejected a business-level test, which is the only thing that would have recognised an outlier.
What we do not know yet
The government has confirmed the process exists and promised detail in guidance. Not yet published: the grounds an appeal can be brought on, the deadline, the evidence required, and whether an appeal can run alongside a standard application. That last point matters, because the application window closes on 30 November and an appeal that cannot run in parallel could expire before it is decided.
What to do now
Three things are worth doing before the detail lands.
Check the SIC code recorded against your company at Companies House. If it no longer reflects the company’s genuine principal activity, correct it through a confirmation statement, and do not wait for the normal filing date if that falls after the BICS application window. It is the first thing any assessment will look at.
Assemble the evidence of what you actually manufacture: products, processes, and the HS codes your goods fall under. An eligible SIC is only the first gate, not a qualification in itself, so the product side matters as much. If your products sit inside the 1,641 eligible HS6 codes, that is the core of any case, and you can check them here: the BICS eligible codes lookup.
And do not assume exclusion. Where a company records several SIC codes, or manufactures across more than one activity, the eligibility question is genuinely arguable, and the answer is worth establishing properly before writing the scheme off.
If you are unsure whether your site is genuinely excluded, that is exactly what the BICS Readiness Audit.
Not sure whether the exclusion is definitive?
The BICS Excluded-Sector Review checks whether an apparent exclusion actually holds: whether the company has another genuine eligible activity, whether its products match an eligible HS6 code, and whether the case is likely to fall within the appeal mechanism once guidance is published. Fixed fee, two business days.
See what is included →Related: Pro-rating bands explained · MPAN mapping: what you need before 1 October · The Year 1 additional payment, explained
Sources: the frozen code lists, appeals commitment, SIC 2007 basis and the 2030 review are from the Government response on regulatory changes and scheme delivery, 8 July 2026. Appeal grounds, deadline and evidence requirements have not been published at the time of writing.
Anthony Salasidis, Meridian Trade Advisory. If you think I have got something wrong, tell me and I will correct it.