CBAM as seen by the customs representative
Customs representatives navigating the Carbon Border Adjustment Mechanism (CBAM) face responsibilities that vary significantly depending on the type of representation they provide. This article examines how liability is allocated under direct and indirect representation, when a customs broker must obtain authorised CBAM declarant status, and the legal and financial consequences that follow, including annual declaration obligations, certificate surrender requirements, and direct exposure to CBAM costs. Practical guidance is also provided on refusing CBAM liability and structuring representation contracts to manage financial risk.
Related content
CBAM liability of importers and ‘other persons’
The CBAM Regulation distinguishes as of 1 January 2026 between importers or their customs representatives who are ‘authorised CBAM declarants’ declaring CBAM goods for release for free circulation, and 'other…
CBAM goes downstream: what importers of steel and aluminium goods must do before 2028
Importers that have only recently adapted to CBAM on raw steel and aluminium now face a further change. The Council's general approach of 12 June 2026 would extend the carbon…
UK CBAM explained: 2027 rules, compliance & practical guidance for importers
A concise briefing from Arne Mielken (Customs Manager Ltd) on the UK's forthcoming Carbon Border Adjustment Mechanism (CBAM), relevant to customs and trade compliance professionals preparing for the UK's own…
EU & UK CBAM explained: key developments and practical implications for traders
A practical, technically detailed session on EU CBAM (Carbon Border Adjustment Mechanism) and the forthcoming UK CBAM, comparing how the two regimes are structured and where importers, suppliers and customs…
CBAM & customs representation
This presentation explains how the Carbon Border Adjustment Mechanism (CBAM) affects customs representatives and importers, from the scope of covered goods to the practical obligations of an authorized CBAM declarant,…
CBAM regulation simplifications: the liability burden
Editor's note. The European Commission has recognised the problem of unnecessary red tape and has announced a far-reaching simplification of certain regulations. The CBAM Regulation is one of them. Which…