Can we test a fuel less often for UK CBAM if sampling it is unsafe?
Possibly. HMRC's technical guidance treats a monitoring approach as technically infeasible where space, safety conditions or technology available in your country rule it out, provided you document it in the monitoring plan. Its own example accepts cutting a fuel analysis from weekly to monthly on safety grounds, backed by evidence that the fuel barely varies.
What HMRC accepts as infeasible
- Not enough space to install the equipment.
- Safety concerns within the installation.
- The technology the approach needs is not available in the country where the goods are made.
- HMRC adds that technical infeasibility is usually closely linked with unreasonable cost.
HMRC's worked example
- Situation: a source stream had to be analysed weekly. Samples were taken by hand and carried to an external lab, and the stream's composition made taking and transporting them risky.
- Proposal: analyse monthly instead, at the plant's internal lab, which was not certified for the analysis but was certified to the same quality standards as the external lab. The plant showed the composition varied very little and that both labs' results matched closely.
- Conclusion: acceptable on safety grounds, because evidence supported both the lower frequency and the internal lab.
How to put it on record
Write the justification into your monitoring plan. HMRC offers an optional template in Annex IX of its guidance; you can use your own if it captures the same points. Your verifier will read it against the evidence, so the case needs data, not a statement that sampling is difficult.
Evidence worth gathering first
- A safety risk assessment of the sampling point and the transport route to the lab.
- A year or more of past analyses showing how little the fuel varies.
- Side-by-side results from your lab and an accredited lab on the same samples.
- A revised sampling plan showing who samples, where, how often and how samples are handled.
Example: what the change means in a year
- Weekly analysis: 52 samples carried to an external lab
- Monthly analysis: 12, done in-house
- 40 fewer trips to a risky sampling point, if your evidence shows the composition holds steady
Counts follow HMRC's weekly to monthly example.
What Senseible does here
Senseible reads the fuel quantities from your purchase invoices that each analysis is applied to, so a change in analysis frequency does not leave gaps in the tonnes. We build the figure from your records and check every figure in-house; for the UK it must then be verified by a verifier accredited for UK CBAM. Have your own verifier? Send it to them.
Sources: HMRC, CBAM Monitoring, Reporting and Verification Technical Guidance, section D4.5.6
Last reviewed 2026-11-03. HMRC is taking feedback on this guidance until 13 November 2026 and may update it before 1 January 2027.