Senseible

How often must an Indian plant get its coal analysed for UK CBAM?

If your monitoring plan uses lab analysis rather than standard values, HMRC's technical guidance sets a minimum for coal, coking coal, coke and pet coke: every 20,000 tonnes and at least six times a year. HMRC's own example: a plant burning 500,000 tonnes a year needs at least 25 lab samples, each prepared under a documented sampling plan.

When the frequency rule applies

HMRC lets a plant set calculation factors (emission factor, net calorific value, carbon content and so on) in several ways, listed in rising data quality: standard values, correlations, the supplier's analysis printed on purchase documents, analysis in a non-accredited lab or with simplified sampling, and analysis in an accredited lab with best-practice sampling. The minimum frequencies apply when you analyse. Each result is used only for the batch it was sampled from.

Minimum analyses, HMRC Table 4-1

Analysis is not sampling

One analysis needs a sample that represents the whole 20,000 t batch, so you take many more samples than you analyse. HMRC wants a sampling plan for each fuel in your monitoring plan, covering the standards followed, method, responsibilities, locations, frequencies, quantities, how samples are stored and how they reach the lab.

When you may analyse less often

Example: counting analyses for one year

90,000 t and 150,000 t are example tonnages. A batch part-way through the year still needs its own analysis.

What Senseible does here

Senseible reads coal and pet coke tonnes from your purchase invoices into a monthly record, the activity data each analysis applies to. 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.

Sources: HMRC, CBAM Monitoring, Reporting and Verification Technical Guidance, sections D4.6.1.5.1 to D4.6.1.5.7

Last reviewed 2026-11-03. HMRC is taking feedback on this guidance until 13 November 2026 and may update it before 1 January 2027.