CBAM for DDP deliveries and importers outside the EU

With “delivered duty paid” (DDP) deliveries, the supplier takes care of the import. For CBAM it then matters who is named as importer in the customs declaration – and whether they are established in the EU. That determines who must be authorised and whether the goods get through the border.

At a glance

The importer is whoever declares the goods in their own name – or, with indirect representation, the person on whose behalf they are declared (Art. 3(15)). With DDP that is often the supplier.
Only importers established in an EU Member State can apply for authorised CBAM declarant status (Art. 5(1)).
For importers outside the EU, the indirect customs representative must be authorised – even if the importer stays below the 50-tonne threshold (Art. 5(2)).
The indirect representative takes over the importer's CBAM obligations for these goods (Art. 5(2a)).

Who is the importer with DDP?

The DDP delivery term governs who bears costs and risk between buyer and seller. It does not automatically decide who the importer is for CBAM – the customs declaration does.

If the supplier has the goods declared for itself via an indirect customs representative, the supplier is the importer. If, however, the goods are declared in your name, you are the importer – with the 50-tonne threshold, authorisation and all obligations, even if the supplier pays for clearance.

Importers not established in the EU

Authorised CBAM declarant status is applied for by the importer established in an EU Member State (Art. 5(1)). A supplier from China, Turkey or the United Kingdom therefore cannot do this itself.

An indirect customs representative must import on its behalf, and that representative must be an authorised CBAM declarant – regardless of whether the importer falls under the exemption up to 50 t (Art. 5(2)). For the goods imported this way, the representative bears the CBAM obligations that would otherwise fall on the importer (Art. 5(2a)). Without an authorised declarant, CBAM goods may not be imported.

And the 50-tonne threshold?

The exemption up to 50 t applies per importer and calendar year (Art. 2a) – all their imports count, including those declared for them by an indirect representative. The indirect representative needs the authorisation in any case. However, it only has to submit a declaration and certificates for importers who exceeded the threshold – then for all their goods of the year, including the first tonnes (recital 7 of Regulation (EU) 2025/2083).

The 50-tonne threshold →

What you should clarify as a buyer

Before CBAM goods arrive at your premises under DDP, a few questions to the supplier are worthwhile:

In whose name are the goods declared – yours or the supplier's?
Does the supplier import via an indirect customs representative with CBAM authorisation? Otherwise the shipment may get stuck at the border.
Who bears the CBAM costs, and are they included in the price? This should be in the contract.
If you are the importer yourself: the quantity counts towards your 50-tonne threshold.
Can the supplier provide emission data for its installation? Without it, default values with a mark-up apply.

Importing yourself instead of DDP

Some buyers switch to importing in their own name, for example with the DAP delivery term. They then become the importer themselves: below 50 t a year they are exempt (the exemption must be stated in the customs declaration), above it they need the authorisation themselves. Which option is cheaper depends on quantity, price and effort.

Am I subject to CBAM? →

How CBAMfix helps

CBAMfix counts your CBAM imports per calendar year and records for each item whether it went through direct or indirect representation. If an import goes through an indirect representative or your company is not established in the EU, CBAMfix points out who must be authorised.

Frequently asked questions

My supplier delivers DDP – do I have to deal with CBAM?

That depends on who is named as importer in the customs declaration. If the supplier declares for itself via an indirect representative, the obligations lie there. If the goods are declared in your name, you are the importer.

Can my supplier from a third country become a CBAM declarant itself?

No. Only importers established in an EU Member State can apply for authorisation. An importer outside the EU needs an indirect customs representative with CBAM authorisation.

Does the customs representative need authorisation even for a few tonnes?

Yes. For importers outside the EU the indirect customs representative must be authorised, regardless of whether the importer falls under the 50-tonne exemption (Art. 5(2)). A declaration and certificates are only due, however, if the importer exceeds the threshold.

Does this affect deliveries from Switzerland?

Goods originating in Switzerland are excluded from CBAM. However, if a Swiss dealer supplies goods originating in another third country, such as steel from China, CBAM applies – and without being established in the EU, the dealer cannot become a CBAM declarant itself.

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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