CBAM for customs agencies and forwarders

Customs agencies are in a special position with CBAM: they see their customers' imports first – and as indirect representatives bear obligations themselves, regardless of quantity.

At a glance

Indirect customs representatives need authorised CBAM declarant status regardless of quantity.
For importers established in the EU, the indirect representative can decline the CBAM obligations; they then remain with the importer.
For importers outside the EU an authorised indirect representative must import – without a mass threshold.
With direct representation the CBAM obligations lie with the importer.

Direct or indirect representation

With direct representation the customs agency acts in the name of the importer; the CBAM obligations – threshold, authorisation, declaration – lie with the importer. With indirect representation it acts in its own name. It must then itself be an authorised CBAM declarant, regardless of how much is imported.

For importers established in the EU, the indirect representative can decline to take over the CBAM obligations. Importers not established in the EU – for example with deliveries duty paid (DDP) – cannot become CBAM declarants themselves; there is no way around an authorised indirect representative.

Added value for your clients

Many importers don't know how close they are to the 50-tonne threshold. The customs agency has the data from the customs declarations and can warn them early – before the authorisation deadline gets tight.

CBAMfix for customs agencies

With the customs agency edition you manage any number of clients in one account: bulk import from your customs software via CSV, the threshold per client at a glance, warnings before the authorisation deadline and read-only access for your clients so they can see their own status. Billing is a base price plus an amount per client.

Frequently asked questions

Does a customs agency have to become a CBAM declarant?

Only if it declares CBAM goods as an indirect customs representative – then regardless of quantity. With direct representation the obligations lie with the importer.

Does the 50-tonne threshold apply to indirect representatives?

No. For indirect customs representatives the authorisation requirement applies from the first CBAM good.

Can my clients see their CBAM status themselves?

In CBAMfix, yes: you invite clients with read-only access. They see their imports, the threshold and the projection without being able to change anything.

Stay on top of the 50-tonne threshold

CBAMfix reads your import documents, checks every CN code against Annex I, keeps count and warns you in time before the authorisation deadline.

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