# If our EU buyer uses a direct customs representative, who carries the CBAM obligations?

Canonical: https://senseible.earth/answers/cbam-direct-customs-representative-liability

Your EU buyer does. EU CBAM Q&A 7.3: obligations lie with whoever put the CBAM account number in the customs declaration, and an importer using a direct customs representative remains the CBAM declarant and remains liable. Only an indirect representative can carry the obligations instead.

## Direct and indirect, in one line each

- Direct representative: lodges the customs declaration in the importer's name. The importer stays the CBAM declarant and stays liable.
- Indirect representative: lodges it in its own name for the importer and, as authorised declarant, carries the CBAM obligations. For an importer not established in the EU, this is the only route.

## Helpers do not take the liability

Q&A 7.3 lets importers use service providers to prepare and submit CBAM documents, and Q&A 7.1 lets a declarant delegate the technical submission. Neither moves the legal responsibility. Under Q&A 1.16, the authority deals with the authorised declarant and may impose penalties on it.

## What it means for you as the supplier

- Send your emissions data to the party whose CBAM account number goes on the customs declaration, usually your buyer. A broker acting as direct representative is not that party.
- Ask your buyer to confirm in writing who the authorised declarant is for your goods.
- If the broker acts as indirect representative, it is the declarant, and it may ask you for data directly.

## Why buyers ask so many questions

A buyer that stays liable carries the risk of a wrong figure. Expect it to ask for your verification report, installation details and the CN codes behind each shipment, and to check them before it declares.

## What Senseible does here

Senseible prepares the embedded emissions your buyer needs, from your records. We build it from your records, check every figure in-house, and an accredited verifier we partner with signs it off. Have your own verifier? Send it to them. It does not act as declarant or file CBAM declarations.

- [One tonne, one declarant](https://senseible.earth/answers/one-tonne-one-cbam-declarant)
- [Check your buyer is authorised](https://senseible.earth/answers/check-eu-buyer-is-authorised-cbam-declarant)
- [What declarants need from you](https://senseible.earth/cbam-authorised-declarant)

Sources: [European Commission, CBAM Questions and Answers (last updated 15 October 2026)](https://taxation-customs.ec.europa.eu/document/download/013fa763-5dce-4726-a204-69fec04d5ce2_en?filename=CBAM_Questions%20and%20Answers.pdf)

Last reviewed 2026-11-01.