What happens to UK Carbon Border Adjustment Mechanism (CBAM) duties if the importer dies, is incapacitated or becomes insolvent?
Another person can carry on a registered importer's business for CBAM if it dies or is incapacitated, and must tell HM Revenue and Customs (HMRC) within 21 days. For insolvency, HMRC treats the insolvency office holder as the registered person; earlier liability stays with the registered person.
Death or incapacity
- Another person can carry on the business for CBAM purposes.
- That person must inform HMRC within 21 days, with information showing they have authority to carry on the business and information about the death or incapacitation, with evidence.
- HMRC treats them as the registered person for 6 months, "with the potential for this to be extended where appropriate".
Insolvency
- HMRC treats the insolvency office holder as the registered person for CBAM.
- Liability that arose before the insolvency procedure began continues to be payable by the registered person.
- Liability that arises after is treated as an expense of the procedure, unless the procedure is an equivalent procedure under the law of a country or territory outside the United Kingdom.
- HMRC's list of office holders includes an administrator, a liquidator, an administrative receiver and a trustee in bankruptcy.
What it means for a supplier
Our reading, not HMRC's: your verified figure and verification summary stay relevant to the return of whoever is treated as the registered person, so keep sending them to the named contact. HMRC's summary does not say what happens to supplier contracts.
What Senseible does here
Senseible reads fuel invoices and electricity bills into dated records, which feed a plant's emissions figure. It does not give legal or insolvency advice.
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.