# How often must an Indian plant get its coal analysed for UK CBAM?

Canonical: https://senseible.earth/answers/uk-cbam-coal-analysis-frequency

If your monitoring plan uses lab analysis rather than standard values, HMRC's technical guidance sets a minimum for coal, coking coal, coke and pet coke: every 20,000 tonnes and at least six times a year. HMRC's own example: a plant burning 500,000 tonnes a year needs at least 25 lab samples, each prepared under a documented sampling plan.

## When the frequency rule applies

HMRC lets a plant set calculation factors (emission factor, net calorific value, carbon content and so on) in several ways, listed in rising data quality: standard values, correlations, the supplier's analysis printed on purchase documents, analysis in a non-accredited lab or with simplified sampling, and analysis in an accredited lab with best-practice sampling. The minimum frequencies apply when you analyse. Each result is used only for the batch it was sampled from.

## Minimum analyses, HMRC Table 4-1

- Coal, coking coal, coke, petroleum coke, peat: every 20,000 t and at least six times a year.
- Fuel oils, including heavy fuel oil: every 20,000 t and at least six times a year.
- Natural gas: at least weekly.
- Other fuels: every 10,000 t and at least four times a year.
- Limestone and dolomite: every 50,000 t and at least four times a year.

## Analysis is not sampling

One analysis needs a sample that represents the whole 20,000 t batch, so you take many more samples than you analyse. HMRC wants a sampling plan for each fuel in your monitoring plan, covering the standards followed, method, responsibilities, locations, frequencies, quantities, how samples are stored and how they reach the lab.

## When you may analyse less often

- The fuel is not in the table: HMRC points to the one-third rule, a frequency that leads to a third of the uncertainty over the whole reporting period.
- Meeting the minimum would cost unreasonably, shown with HMRC's unreasonable cost method.
- The fuel is uniform, shown by past analyses including the previous calendar year, and its values vary by no more than a third of the uncertainty that applies to its activity data.
- Whatever you change, write it into the monitoring plan, or the verifier will treat it as a gap.

## Example: counting analyses for one year

- 90,000 t of imported coal: 90,000 / 20,000 = 4.5 batches, but the six-a-year floor applies, so at least 6 analyses
- 150,000 t: 150,000 / 20,000 = 7.5, so at least 8 analyses, one for each batch
- HMRC's case, 500,000 t: at least 25 analyses

90,000 t and 150,000 t are example tonnages. A batch part-way through the year still needs its own analysis.

## What Senseible does here

Senseible reads coal and pet coke tonnes from your purchase invoices into a monthly record, the activity data each analysis applies to. 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.

- [CBAM report from your records](https://senseible.earth/cbam-suite)
- [Using a non-accredited lab](https://senseible.earth/answers/uk-cbam-non-accredited-laboratory)
- [UK CBAM standard fuel factors](https://senseible.earth/answers/uk-cbam-standard-fuel-emission-factors)
- [What a UK CBAM monitoring plan holds](https://senseible.earth/answers/uk-cbam-monitoring-plan-contents)

Sources: [HMRC, CBAM Monitoring, Reporting and Verification Technical Guidance, sections D4.6.1.5.1 to D4.6.1.5.7](https://assets.publishing.service.gov.uk/media/6ad219fe0f7b53973e02680f/CBAM_technical_guidance.pdf)

Last reviewed 2026-11-03. HMRC is taking feedback on this guidance until 13 November 2026 and may update it before 1 January 2027.