What records show that goods are of UK origin for the UK Carbon Border Adjustment Mechanism (CBAM)?
HM Revenue and Customs (HMRC) says importers keep records of any CBAM goods of UK origin, which could include production records, invoices, accounting details, suppliers' declarations and any information relied on as importer's knowledge. Origin follows the UK's non-preferential rules of origin.
What HMRC says
"CBAM will be charged on goods which originate from outside of the UK according to the UK's non-preferential rules of origin. Those with a UK place of origin are not in scope of CBAM."
Records HMRC lists
- production records
- invoices
- accounting details
- suppliers' declarations
- any information you have relied on as 'importers knowledge'
For goods that return inside a complex good
Records for goods that return inside a complex good are covered on the UK-made steel page: /answers/uk-cbam-uk-made-precursor-exemption.
What it means for you
Our reading, not HMRC's: goods you make in India are not of UK origin, so they stay in scope. Your buyer uses either your verified figure or HMRC's default value. A claim of UK origin has to be backed by the records above, and a supplier's declaration is only one item on that list.
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 origin or hold origin declarations.
Sources: HM Revenue and Customs, Keeping records for Carbon Border Adjustment Mechanism (CBAM) (updated 3 November 2026), 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.