Senseible

Can a UK importer leave the UK Carbon Border Adjustment Mechanism (CBAM) register?

On application, but only if HM Revenue and Customs (HMRC) is satisfied the person is not required to be registered and has not been liable in the previous 12 months. It may decline if CBAM or returns are outstanding, or the person will be registrable within 12 months.

What HMRC says

When HMRC may decline

A nil return still counts

HMRC says a nil liability still needs a return for that accounting period. Our reading, not HMRC's: a buyer that stops importing your goods keeps filing until HMRC accepts its deregistration. The rule is on the return calendar page.

What it means for you

Our reading, not HMRC's: a buyer that is still registered may keep asking for your verified figure each period, even in a quiet quarter. The 12 months are looked at back from the date it applies, so a buyer is clear only once a full year has passed since it was last liable.

What Senseible does here

Senseible reads fuel invoices and electricity bills into dated records, which feed a plant's emissions figure. It does not register or deregister importers.

Sources: HM Revenue and Customs, Carbon Border Adjustment Mechanism (CBAM): Policy summary (updated 2 November 2026)

Last reviewed 2026-11-05. HM Revenue and Customs says the details in its policy summary may be subject to change. Re-check the policy summary and the keeping-records page before relying on a date or condition.