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.