Our European Union (EU) customs broker clears Carbon Border Adjustment Mechanism (CBAM) goods for several importers as indirect customs representative and acts as their authorised CBAM declarant: does it file one annual declaration or one per importer?

One. The Commission's Questions and Answers (Q&A) 1.19 say an indirect customs representative acting as authorised CBAM declarant for multiple importers must submit one single annual CBAM declaration with all the goods it carried out customs declarations for that year. It cannot submit more than one annual declaration for the same year.

What Q&A 1.19 says

• An importer is free to use different indirect customs representatives. Each is accountable for the specific CBAM goods it introduced in its customs declaration.
• Each representative shows its own Economic Operators Registration and Identification (EORI) number at customs, which is the evidence of who must comply with the CBAM obligations. The Commission says this means there can be no double-counting of embedded emissions.
• A representative that acts as authorised CBAM declarant for multiple importers submits one single annual declaration containing all the goods for which it carried out the customs declaration during the calendar year.

Do not confuse it with a group service provider

Q&A 1.21 covers a different case: a group company filing as a service provider for other group companies files a separate declaration per entity. The linked page on group companies has the detail.

What it means for an exporter

• Ask your buyer who lodges the customs declaration and whose EORI number goes on it. That party carries the obligation for those shipments.
• Our reading: if the buyer changes broker part way through a year, shipments declared by each broker land in that broker's own declaration, so send your data to whoever is the declarant on each shipment.
• A broker that serves many importers may ask you for data in its own name. The data you hold is the same for every importer.

What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. It does not decide an importer's CBAM position, it is not a CBAM verifier and it does not file declarations.

• One tonne, one declarant
• Group companies and one declarant
• When an indirect representative declines CBAM
• Direct customs representative liability
• CBAM for Indian exporters

Sources: European Commission, CBAM Questions and Answers (updated 15 October 2026), questions 1.19 and 1.21

Last reviewed 2026-11-06. Based on Q&A 1.19 and 1.21 as updated on 15 October 2026. Ask the buyer's authority if a set-up mixes a broker and group companies.