# Can we use a local lab that is not ISO/IEC 17025 accredited for UK CBAM fuel tests?

Canonical: https://senseible.earth/answers/uk-cbam-non-accredited-laboratory

Only by exception. HMRC's technical guidance says labs analysing your fuel or material samples must be accredited to ISO/IEC 17025 for the methods used. A non-accredited lab is allowed only with evidence that an accredited one is technically not feasible or would cost unreasonably, and you must prove that lab's competence in your monitoring plan.

## Two things to show

1. Why an accredited lab is out of reach: technically not feasible, or unreasonable cost worked out with HMRC's method.
2. That the lab you use instead is competent, with the evidence written into your monitoring plan.

## HMRC's competence test

- Economically independent of your company, or at least organisationally shielded from your management's influence.
- Applies the relevant standards for each analysis.
- Staff competent for the tasks assigned.
- Controls sampling and sample preparation, including sample integrity.
- Regular quality checks: equipment calibration, proficiency testing schemes, certified reference materials and inter-comparison with an accredited lab.
- Maintains, calibrates, adjusts and repairs its equipment, and keeps records of it.

## Your own plant lab

It can qualify, but the independence point is the hard one: the lab must be shielded from production management. HMRC's technical feasibility example accepted a plant's internal lab, not certified for the analysis but certified to the same quality standards as the external lab, once the plant showed the two labs' results matched closely.

## What it does to your data quality

HMRC ranks analysis in a non-accredited lab below analysis in an accredited lab with best-practice sampling, and above the supplier's analysis printed on purchase documents. Your verifier will read the evidence for whichever you chose, so keep proficiency test results and the comparison with an accredited lab on file.

## What Senseible does here

Senseible reads fuel tonnes from your invoices, the activity data your lab results are applied 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)
- [How often to analyse coal](https://senseible.earth/answers/uk-cbam-coal-analysis-frequency)
- [Testing less often on safety grounds](https://senseible.earth/answers/uk-cbam-technical-feasibility-sampling-safety)
- [What the verifier asks the plant](https://senseible.earth/answers/uk-cbam-what-verifier-asks-plant)

Sources: [HMRC, CBAM Monitoring, Reporting and Verification Technical Guidance, sections D4.5.6, D4.6.1.5.1 and D4.6.1.5.8](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.