Who files the CBAM declaration for steel landed at the port of Rotterdam?

The authorised CBAM declarant: the importer, or an indirect customs representative acting for it, authorised by the competent authority before importing. A direct representative cannot carry the obligation for the importer. Importers bringing in 50 tonnes or less a year of covered goods are exempt.

Who can be the declarant

• The importer established in the EU that lodges the customs declaration in its own name.
• An indirect customs representative, which acts in its own name for the importer, if it agrees to take on the CBAM obligations.
• Not the non-EU exporter itself; it can register in the CBAM Registry and share data, but it does not declare.

What the declarant does

1. Holds the authorisation, or has applied for it in time under the 2025 transitional arrangement, before importing covered goods above the threshold.
2. Collects embedded emissions per CN code and origin, from verified supplier data or default values.
3. Holds certificates each quarter and surrenders them with the annual declaration for the previous year.

Transit and storage

Goods only in transit or in a customs warehouse are not yet released for free circulation, so the CBAM obligation arises when they are released into the EU market.

What Senseible does here

Senseible's CBAM cost calculator estimates certificate cost from 2026 to 2034 for covered goods, and non-EU suppliers can use Senseible to keep document-backed fuel and electricity records to share with you. Senseible does not file CBAM declarations or verify emissions.

• Can a non-EU exporter be the declarant?
• Become an authorised declarant
• The 50 tonne exemption

Sources: Regulation (EU) 2023/956 (CBAM Regulation), consolidated, Regulation (EU) 2025/2083, CBAM simplification, European Commission, CBAM definitive regime

Last reviewed 2026-10-21.