Our EU group has several importing companies. Can one of them file CBAM for all?

Not as one declaration. The EU's CBAM Q&A 1.21 says goods follow each company's EORI number, so by default each subsidiary declares separately. One indirect customs representative can handle CBAM for all of them, or one group company can file as service provider, but each importer stays liable.

The three set-ups

• Each company is its own authorised CBAM declarant. This is the default.
• One indirect customs representative, outside the group or a group company, acts for all of them. It must then also carry out the customs formalities for the goods in its CBAM declarations.
• One group company submits declarations as service provider. The others stay authorised declarants and legally liable, and a separate declaration is filed for each company, including the service provider's own imports.

For the Indian supplier

• Requests may come from several companies of one group. The same installation data serves them all.
• Ask which company, and which EORI number, each shipment is invoiced to, so your figures land in the right declaration.
• Send one figure per CN code and period to all of them. Different numbers to different group companies will be noticed.

What Senseible does here

Senseible's guide for authorised declarants sets out what each importing company will ask its suppliers for. Senseible does not act as a customs representative or file CBAM declarations.

• Working with authorised declarants
• Check your EU buyer is a declarant
• Can a non-EU exporter be declarant

Sources: European Commission, CBAM Questions and Answers (15 October 2026), question 1.21

Last reviewed 2026-11-01.