Our production route is not in HMRC's UK CBAM guidance. How do we ask HMRC?

Email HMRC's CBAM policy team at cbampolicyteam@hmrc.gov.uk. HMRC names technical questions where the published method does not cover your product or process, such as a process that does not use the precursor or production route in its technical guidance, as detailed queries for that address. HMRC usually replies by email within 15 days.

Which channel

• Detailed questions, by email to cbampolicyteam@hmrc.gov.uk: how policy applies where published guidance does not cover your case, future policy not yet published, and technical questions where the method does not cover a product or production process. You can also report a gap you believe the guidance has.
• General questions, through HMRC's online form after signing in: whether CBAM applies to you, help with registration, and more on reporting and record keeping.
• To join HMRC's CBAM mailing list, email the same address with 'CBAM mailing list' in the subject.

Put this in the email

1. Your plant, its location and the goods you send to the UK, with commodity codes.
2. Each process step, with the precursors you make or buy and where they come from.
3. The section of the technical guidance you tried to follow and the exact point where your process departs from it.
4. How you propose to monitor it instead, so HMRC can say yes or no rather than start from scratch.
5. Your UK importer's name, since the figure ends up on its return.

Comments on the guidance itself

HMRC is taking technical feedback on its monitoring, reporting and verification guidance at the same address, with 'MRV technical guidance feedback' in the subject, until 13 November 2026. It says it may update the guidance before 1 January 2027.

While you wait

Write your proposed approach into the monitoring plan and keep HMRC's reply with it. Your verifier will ask why your method differs from the guidance, and HMRC's reply is the clearest evidence you can show.

Example: a subject line and opening

• Subject: Production route not covered by the technical guidance: [product, commodity code]
• Opening: We produce [goods, commodity codes] at [plant, India] for import into the UK by [importer]. Section [x] of the technical guidance describes [route]; our process differs at [step]. We propose to monitor it by [method]. Please confirm whether this is acceptable.

Fill the brackets with your own details.

What Senseible does here

Senseible builds your product figure from your fuel, electricity and material records, so the activity data behind your proposed method is documented when HMRC or your verifier asks. We build the figure from your records and check every figure in-house; for the UK it must then be verified by a verifier accredited for UK CBAM. Have your own verifier? Send it to them.

• CBAM report from your records
• UK CBAM system boundaries
• What a UK CBAM monitoring plan holds

Sources: HMRC, Send HMRC questions about the Carbon Border Adjustment Mechanism (updated 21 October 2026), HMRC, CBAM Monitoring, Reporting and Verification Technical Guidance

Last reviewed 2026-11-03. The guidance feedback window closes 13 November 2026; remove that section after it passes.