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You will need to keep the following records in written (including electronic) form for 6 years from the latest of either the:Ìý

• date they were createdÌý

• end of the accounting period they relate toÌýÌý

GoodsÌýand import records youÌýmustÌýkeepÌý

Anyone importing CBAM goods into the UK will need to keep records of the CBAM goods they have imported from 1 January 2027.

The records will need to include theÌýfollowing information about each CBAM good, the:

• 8-digitÌýcommodity code and descriptionÌý

• dateÌýit passed the tax point (when it first entered the UK or cleared customs)Ìý

• ±¹²¹±ô³Ü±ðÌýÌý

• ·É±ð¾±²µ³ó³ÙÌý

• evidence for anyÌýexemptions from CBAMÌý

Records can be import declarations (ifÌýyouÌýholdÌýthis information). They could also be other documents relating toÌýtheÌýimported CBAM goods.

These might be from manufacturers,Ìýto show the weight of goods,Ìýor from suppliers, to display the value.Ìý

If youÌýsubmitÌýaÌýCBAM return, you will also need to keep records of:Ìý

• the quarter in which the goods passed the tax pointÌý(when the goods first enteredÌýthe UK or they cleared customs)Ìý

• proof of originÌý

CustomsÌýdocumentsÌý

IfÌýyou’reÌýusingÌýa customs documentÌýas a recordÌýforÌýimported CBAM goods, this could include:

• import declarationsÌý

• import entry acceptance advice

• bill of lading documents

• discharge of a customs procedure (other than temporary admission)Ìý

• commercial documents, including record of movement of goods in the UKÌý

• UK customs duty documents, including eligibility for reliefÌý

• repayment or remission of duty documentsÌý

• evidence of UK origin materials, already carbon taxed in reimported goodsÌý

WhatÌýrecordsÌýyou need to keep if youÌýreportÌýactual emissionsÌý

If 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.Ìý

You’llÌýget the evidence you need from your supplier in the form of a verification report, or verification summary, thatÌýcontainsÌýthe relevant emissions data.Ìý

You’llÌýneed to hold the verification report, or verification summary, relevant to the emission intensity reported on your tax return for 6 years.Ìý

HMRC will publish further detail on verification requirements before 1 January 2027.Ìý

You must use a default emissions value if:Ìý

• actual emissions data is not available to you

• you do not have evidence the emissions data you are reporting has been verifiedÌý

We’llÌýset the default emissions values for CBAM goods later this year.Ìý

We’llÌýprovide guidance on monitoring,ÌýverifyingÌýand reporting actual emissions later this year.Ìý

Weight of goodsÌýrecords you should keepÌý

RecordsÌýforÌýimported CBAM goods must showÌýthe weight excluding packagingÌý(net mass)Ìýin kilograms.ÌýThis should beÌýtheÌý·É±ð¾±²µ³ó³ÙÌýof the CBAM goodÌýat time of import into the UK.Ìý

Enter, up to 6 decimal places, the net mass of the goodsÌýasÌýdescribed inÌýDE 6/8 (Description of Goods).Ìý

Where a net mass greater than 1kg includes a fraction of a unit (kg), it may be rounded offÌýfrom:Ìý

• 0.001 to 0.499 — rounding down to the nearest kgÌý

• 0.5 to 0.999 — rounding up to the nearest kgÌý

A net mass of less than 1 kg should be entered as ‘0’ followed by decimals up to 6, discarding all ‘0’ at the end.ÌýFor example, 0.123 for a package of 123 grams, 0.00304 for a package of 3 grams and 40 milligrams or 0.000654 for a package of 654 milligrams.Ìý

Examples of recordsÌýof weight include import declarations, commercial invoices, carrier weight records, bill of lading orÌýpacking lists.Ìý

Registration for CBAM will open by 1 January 2028.ÌýYou’llÌýneed to provide:

• estimates of the weight of CBAM goods you expect to import in the next 12 months
• an estimate for each sector (aluminium, cement, fertiliser, iron and steel, hydrogen)

Keep evidence of how you estimated weight.Ìý

When youÌýcome toÌýcompletingÌýyour CBAM returns,Ìýyou’llÌýneed to know the actual weight of the imported CBAM goodsÌýin that returns period.

You may be able to get this information from your import declarations or supplier.ÌýYou’reÌýresponsible for getting the information about the correct weight.Ìý

Tax reliefÌýand repaymentÌýrecordsÌýyou must keepÌý

YouÌýcanÌýclaim reliefÌýto reduceÌýthe amount of CBAM dueÌýif youÌýcan show youÌýhave already paidÌýa chargeÌýonÌýtheÌýCBAM goods to a qualifying carbon pricing scheme.Ìý

Keep copies of the carbon pricing verification form completed by a suitable verifier as evidence for your calculation. We’llÌýpublishÌýfurtherÌýdetail about verification later this year.Ìý

Carbon Price ReliefÌý

If youÌýareÌýclaimingÌýCarbon Price ReliefÌýthrough your CBAM return, you will need to keep records of:Ìý

• the qualifying carbon pricing scheme your CBAM goods were subject toÌýÌý

• how theÌýgoodsÌýqualify for Carbon Price ReliefÌý—Ìýincluding verified effective carbon price calculations

• which elements of the qualifying carbon price scheme you used toÌýdecideÌýthe price

• how you adjusted down the CBAM liability — includingÌýexchange rates used to convert to sterling (GBP)Ìý

RepaymentÌýclaimsÌýrecordsÌý

You need to keep recordsÌýofÌýclaims forÌýCBAM-relatedÌýrepayments from HMRC.ÌýYou might claim a repayment if you made an error on your return that led to an overpayment.Ìý

The detailsÌýyou need to keepÌýinclude the:Ìý

• reason for the claimÌý

• date the error was foundÌý

• accounting period which the claim relates toÌý

• full details of the CBAM goodsÌý(from the relevant return)Ìý

• date the CBAM liability was originally paidÌý

You’llÌýneed to keep theseÌýrecords for 6 years from the date you send the claim.

HMRC will only repay overpaid CBAM for the 3 years before you make a claim.Ìý

A claim for repayment may be refused if HMRC finds:Ìý

• you’veÌýpassed the economic burden of the amountÌýyou are looking toÌýclaimÌýon to another person

• payment of the claim would unjustly enrich you

In these circumstances, a claim will not be refused on the grounds of unjust enrichment if you:Ìý

• agree to reimburse your customer

• meet the conditions of HMRC’s reimbursement scheme

Where reimbursement is made, you should keep records of:Ìý

• names and addresses of each person the claimant reimburses or plans to reimburseÌý

• theÌýamount to be reimbursed to each personÌý

• amount of interest included in the total amount reimbursed to each person

• date that each reimbursement was madeÌý

These records need to be kept for the period of 6 years beginningÌýfromÌýeither (whichever is later)Ìýthe:Ìý

• last day of the accounting period to which the records relateÌý

• day the claimant makes the reimbursement to which the records relateÌý

Exemption from CBAM records you must keepÌý

You need to keep records for imported CBAM goods you believe are exempt from the scope of CBAM.Ìý

CBAM goods can be exempt if:Ìý

• they are for private useÌý

• they are of UK origin

• Returned Goods Relief is claimed

• they came into the UK under temporary admission with full relief from customs duty

Private useÌý

Keep recordsÌýofÌýany CBAM goodsÌýthat you import to the UK for private use. This could include:

• evidence of the good being used to build something for private useÌý

• proofÌýthatÌýyou still own the goodsÌý

• proof of how you use the goods for private useÌý

ÌýUK originÌý

Keep recordsÌýofÌýany CBAMÌýgoods you import which are of UK origin (under the non-preferential rules of origin). This could include:Ìý

• production recordsÌý

• invoicesÌý

• accounting detailsÌý

• suppliers’ declarations

• any information you have relied on as ‘importers knowledge’Ìý

Returned GoodsÌýReliefÌý

Keep recordsÌýofÌýReturned Goods ReliefÌýif you reimport unaltered CBAM goods to the UK within 3 years of export. ThisÌýincludes:Ìý

• proof ofÌýearlierÌýUK exportÌý

• proof of reimport to the UK within 3 yearsÌý

• evidence the goods are in the same stateÌý

• import declarations for reimportÌý

• serial or batch numbers or packing listsÌý

Temporary admission with full reliefÌý

Keep recordsÌýofÌýCBAM goods which enter the UK underÌýtemporary admissionÌýwith full relief from import duty.ÌýThisÌýincludes:Ìý

• evidence that the good isÌýeligible for full reliefÌý

• the import declarationÌý(showing full relief)Ìýfor the good entering the UKÌý

• proof thatÌýthe goods areÌýfollowingÌýthe terms of temporary admission,Ìýfor example,Ìýthe good has not been released into free circulation