If goods are exempt from the United Kingdom (UK) Carbon Border Adjustment Mechanism (CBAM), does the importer still keep records?

Yes. HM Revenue and Customs (HMRC) says importers keep records for goods they believe are exempt. It names four exemptions: private use, UK origin, returned goods relief, and temporary admission with full relief from customs duty. Each has its own proof, such as the import declaration showing full relief.

The rule

HMRC's records page says: "You need to keep records for imported CBAM goods you believe are exempt from the scope of CBAM."

Exempt does not mean no paperwork. It is like a doctor's note for a day off: the exemption stands only if you can show the note.

Proof HMRC lists for each exemption

• Private use: evidence of the good being used to build something for private use, proof that you still own the goods, and proof of how you use the goods for private use.
• UK origin: production records, invoices, accounting details, suppliers' declarations, and any information relied on as importers knowledge.
• Returned goods relief: proof of earlier UK export, proof of reimport into the UK within 3 years, evidence the goods are in the same state, import declarations for the reimport, and serial or batch numbers or packing lists.
• Temporary admission with full relief: evidence the good is eligible for full relief, the import declaration showing full relief, and proof that the goods follow the terms of Temporary Admission, for example that the good has not been released into free circulation.

Headline proof HMRC lists for each exemption

Temporary admission lets goods come in for a short stay, like a borrowed ladder that has to go back. HMRC's policy summary says that when full relief from customs duty is given, the good is not treated as an import for CBAM. With partial or no relief, "CBAM will apply to those goods". If full relief stops while the goods are still in the UK, CBAM applies from the date it stops.

• Private use: evidence of use to build something for private use, proof you still own the goods, and proof of private use.
• UK origin: production records, invoices, accounting details and suppliers' declarations, plus any information relied on as 'importers knowledge'.
• Returned goods relief: proof of earlier UK export, proof of reimport within 3 years, and evidence the goods are in the same state.
• Temporary admission with full relief: evidence of eligibility, and the import declaration showing full relief.

What this means for an Indian supplier (our reading)

Temporary admission lets goods come in for a short stay, like a borrowed ladder that has to go back. When full relief from customs duty is given, HMRC's policy summary says the good is not treated as an import for CBAM; with partial or no relief, "CBAM will apply to those goods".

• For samples or machinery that go to the UK for a show, ask the buyer or agent how the goods will be declared.
• Keep proof of the return shipment as well as the outward one.
• If a sample is sold in the UK, the full relief may end. Tell the buyer at once.

What Senseible does here

Senseible reads fuel invoices and electricity bills into dated, fingerprinted records. It does not file UK CBAM returns, work out your buyer's registration date or check commodity codes. Those stay with the importer and HMRC.

• Trade fair samples and CBAM
• Returned goods relief
• Private use
• UK origin records
• UK CBAM for Indian exporters

Sources: HMRC, Keeping records for CBAM (updated 3 November 2026), HMRC, Carbon Border Adjustment Mechanism (CBAM): Policy summary (updated 2 November 2026)

Last reviewed 2026-11-07. Lists are from HMRC's keeping records page (updated 3 November 2026) and the policy summary (updated 2 November 2026). Re-check if HMRC adds an exemption. The full proof lists sit on the linked pages.