The most difficult counterterms to construct in any supersymmetric theory are those that cannot be written as full superspace integrals of gauge-invariant integrands. In $D=4$ maximal supergravity it has been known for some time that there are just three of these at the linearised level. In this article we discuss these counterterms again from the point of view of representations of the superconformal group. In particular, we show that the only independent invariants constructed from shortened superconformal multiplets in $D=4$ are BPS.