Is a private buyer in the UK liable for the UK Carbon Border Adjustment Mechanism (CBAM) on goods bought from India?

HM Revenue and Customs (HMRC) says private individuals importing CBAM goods for non-commercial purposes will not be liable. Only individuals importing CBAM goods in the course of a business that meet either liability test are liable. HMRC also expects records to show private use.

What HMRC says

"Only individuals importing CBAM goods in the course of a business that meet either of the CBAM liability tests will be liable for CBAM. This means private individuals importing CBAM goods for non-commercial purposes will not be liable for CBAM."

Records for private use

HMRC lists private use among the exemptions and says importers keep records of CBAM goods imported for private use. The examples it gives of what this could include are:

• evidence of the good being used to build something for private use
• proof that you still own the goods
• proof of how you use the goods for private use

What the wording does not settle

Our reading, not HMRC's: the wording turns on who the importer is and whether the import is in the course of a business. HMRC names the importer as the person on the customs declaration where duty is payable, or the person importing the goods where none is. If you ship delivered duty paid and your name is on the declaration, do not assume the buyer's private status protects you. Ask HMRC about your case.

What Senseible does here

Senseible reads fuel invoices and electricity bills into dated records, which feed a plant's emissions figure. It does not decide who is the importer on a UK sale or whether an import counts as private use.

• Are you the liable person on a delivered duty paid sale?
• How the 50,000 pound threshold is valued
• The UK CBAM tax point
• Records your UK buyer will ask for

Sources: HM Revenue and Customs, Carbon Border Adjustment Mechanism (CBAM): Policy summary (updated 2 November 2026), HM Revenue and Customs, Keeping records for Carbon Border Adjustment Mechanism (CBAM) (updated 3 November 2026), HM Revenue and Customs, Check if you're classed as the importer for CBAM, HM Revenue and Customs, Send HMRC questions about CBAM

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.