Can a UK buyer split imports across companies to stay under the UK Carbon Border Adjustment Mechanism (CBAM) threshold?
HM Revenue and Customs (HMRC) says it is introducing legislation to deter the artificial separation of business activities and prevent circumvention of liability to the tax. HMRC has not said how it will judge this, so ask HMRC before arranging imports around the threshold.
What HMRC says
"HMRC is also introducing legislation to deter the artificial separation of business activities and prevent circumvention of liability to the tax." That is all the policy summary says on the point.
The tests that apply
The forward and backward threshold tests are on the threshold page: /answers/uk-cbam-threshold-customs-value.
What is not known
The summary does not define "artificial" or give examples. Our reading, not HMRC's: moving orders between companies for no reason other than to stay below the threshold is the kind of arrangement the wording is aimed at. Ask HMRC before arranging imports around the threshold.
Where to ask
HMRC says detailed policy questions go by email to cbampolicyteam@hmrc.gov.uk, and it usually replies within 15 days.
What Senseible does here
Senseible reads fuel invoices and electricity bills into dated records, which feed a plant's emissions figure. It does not advise on registration.
- How the threshold is valued
- Are you the liable person on a delivered duty paid sale?
- Penalties HMRC can use
Sources: HM Revenue and Customs, Carbon Border Adjustment Mechanism (CBAM): Policy summary (updated 2 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.