FAQ.- Who bears responsibility for CBAM reporting?

During the transitional phase, customs authorities will notify customs declarants of their reporting duties. The reporting declarant, whether importer or indirect customs representative, depends on who submits the customs declaration. Customs authorities have discretion in communicating these obligations.

The reporting obligations fall upon:

– The importer:

• When submitting a customs declaration for releasing goods for circulation under their own name and behalf.
• When holding authorization to submit customs declarations and declares goods importation.

– The indirect customs representative:

• When lodging the customs declaration on behalf of the importer located outside the EU.
• When agreeing to reporting obligations per Regulation 2023/956, if the importer is within the EU. The appointed representative must be EU-based and comply with customs representative criteria set by the respective Member State.