You will need to keep the following records in written (including electronic) form for 6 years from the latest of either the:
\n\ndate they were created
\nend of the accounting period they relate to
\nYou may be charged a fixed penalty of £500 if you do not keep records for Carbon Border Adjustment Mechanism (CBAM). Separate penalties may apply if you do not provide information or documents when asked to by HMRC.
\nAnyone importing CBAM goods into the UK will need to keep records of the CBAM goods they have imported from 1 January 2027.
\n\nThe records will need to include the following information about each CBAM good, the:
\n\n8-digit commodity code and description
\ndate it passed the tax point (when it first entered the UK or cleared customs)
\nvalue
\nweight
\nevidence for any exemptions from CBAM
\nRecords can be import declarations (if you hold this information). They could also be other documents relating to the imported CBAM goods.
\n\nThese might be from manufacturers, to show the weight of goods, or from suppliers, to display the value.
\n\nIf you submit a CBAM return, you will also need to keep records of:
\n\nthe quarter in which the goods passed the tax point (when the goods first entered the UK or they cleared customs)
\nproof of origin
\nIf you’re using a customs document as a record for imported CBAM goods, this could include:
\n\nimport declarations
\nimport entry acceptance advice
\nbill of lading documents
\ndischarge of a customs procedure (other than Temporary Admission)
\ncommercial documents, including record of movement of goods in the UK
\nUK Customs Duty documents, including eligibility for relief
\nrepayment or remission of duty documents
\nevidence of UK origin materials, already carbon taxed in reimported goods
\nIf you choose to report actual emissions for the CBAM goods you import, you must keep evidence that the emissions data you are reporting has been verified.
\n\nYou’ll get the evidence you need from your supplier in the form of a verification report, or verification summary, that contains the relevant emissions data.
\n\nYou’ll need to keep the verification report, or verification summary, relevant to the emission intensity reported on your tax return for 6 years.
\n\nHMRC will publish further detail about verification requirements before 1 January 2027.
\n\nYou must use a default value if:
\n\nactual emissions data is not available to you
\nyou do not have evidence that the emissions data you are reporting has been verified
\nWe’ll set the default values for CBAM goods later this year.
\n\nWe’ll provide guidance on monitoring, verifying and reporting actual emissions later this year.
\n\nRecords for imported CBAM goods must show the weight excluding packaging (net mass) in kilograms (kg). This should be the weight of the CBAM good at time of import into the UK.
\n\nEnter, up to 6 decimal places, the net mass of the goods as described in section ‘Group 6: Goods Identification’ of CDS Declaration Completion Instructions for Imports.
\n\nWhere a net mass greater than 1kg includes a fraction of a unit (kg), it may be rounded to the nearest kg. Where the fraction is:
\n\n0.499999kg or less — round down to the nearest kg
\n0.5kg or more — round up to the nearest kg
\nA net mass less than 1kg should be entered as ‘0.’ followed by up to 6 decimal places, discarding all ‘0’s at the end.
\n\nFor example:
\n\nExamples of records of weight include import declarations, commercial invoices, carrier weight records, bill of lading or packing lists.
\n\nRegistration for CBAM will open on 1 January 2028. You’ll need to provide:
\n\nYou’ll also need to keep evidence of how you estimated weight.
\n\nWhen you come to completing your CBAM returns, you’ll need to know the actual weight of the imported CBAM goods in that returns period.
\n\nYou may be able to get this information from your import declarations or supplier. You’re responsible for getting the information about the correct weight.
\n\nYou can claim relief to reduce the amount of CBAM due if you can show you have already paid a charge on the CBAM goods to a qualifying carbon pricing scheme.
\n\nKeep copies of the carbon pricing verification form completed by a suitable verifier as evidence for your calculation. We’ll publish further detail about verification later this year.
\n\nIf you are claiming Carbon Price Relief through your CBAM return, you will need to keep records of:
\n\nthe qualifying carbon pricing scheme your CBAM goods were subject to
\nhow the goods qualify for Carbon Price Relief — including verified effective carbon price calculations
\nwhich elements of the qualifying carbon price scheme you used to decide the price
\nhow you adjusted down the CBAM liability — including exchange rates used to convert to pound sterling (GBP)
\nYou need to keep records of claims for CBAM-related repayments from HMRC. You might claim a repayment if you made an error on your return that led to an overpayment.
\n\nThe details you need to keep include the:
\n\nreason for the claim
\ndate the error was found
\naccounting period which the claim relates to
\nfull details of the CBAM goods (from the relevant return)
\ndate the CBAM liability was originally paid
\nYou’ll need to keep these records for 6 years from the date you send the claim.
\n\nHMRC will only repay overpaid CBAM for the 3 years before you make a claim.
\n\nA claim for repayment may be refused if HMRC finds:
\n\nyou’ve passed the economic burden of the amount you are looking to claim on to another person
\npayment of the claim would unjustly enrich you
\nIn these circumstances, a claim will not be refused on the grounds of unjust enrichment if you:
\n\nagree to reimburse your customer
\nmeet the conditions of HMRC’s reimbursement scheme
\nWhere reimbursement is made, you should keep records of:
\n\nnames and addresses of each person the claimant reimburses or plans to reimburse
\nthe amount to be reimbursed to each person
\namount of interest included in the total amount reimbursed to each person
\ndate that each reimbursement was made
\nThese records need to be kept for the period of 6 years beginning from either (whichever is later) the:
\n\nlast day of the accounting period to which the records relate
\nday the claimant makes the reimbursement to which the records relate
\nYou need to keep records for imported CBAM goods you believe are exempt from the scope of CBAM.
\n\nCBAM goods can be exempt if:
\n\nthey are for private use
\nthey are of UK origin
\nReturned Goods Relief is claimed
\nthey came into the UK under Temporary Admission with full relief from Customs Duty
\nKeep records of any CBAM goods that you import into the UK for private use. This could include:
\n\nevidence of the good being used to build something for private use
\nproof that you still own the goods
\nproof of how you use the goods for private use
\nKeep records of any CBAM goods you import which are of UK origin (under the non-preferential rules of origin). This could include:
\n\nproduction records
\ninvoices
\naccounting details
\nsuppliers’ declarations
\nany information you have relied on as ‘importers knowledge’
\nKeep records of Returned Goods Relief if you reimport unaltered CBAM goods into the UK within 3 years of export. This includes:
\n\nproof of earlier UK export
\nproof of reimport into the UK within 3 years
\nevidence the goods are in the same state
\nimport declarations for reimport
\nserial or batch numbers or packing lists
\nKeep records of CBAM goods which enter the UK under Temporary Admission with full relief from import duty. This includes:
\n\nevidence that the good is eligible for full relief
\nthe import declaration (showing full relief) for the good entering the UK
\nproof that the goods are following the terms of Temporary Admission, for example, the good has not been released into free circulation
\n