# We sell DDP to the UK. Are we liable for the UK CBAM?

Canonical: https://senseible.earth/answers/uk-cbam-ddp-exporter-liable-person

Possibly yes. HMRC makes the importer liable: the person named on the UK import declaration, or on whose behalf it is made, and that person can be based outside the UK. If you ship DDP and the declaration is in your name, the CBAM registration, returns and tax become yours.

## Who HMRC treats as the importer

- Where customs duty is payable: the person named on the import declaration, even if an agent declares for them.
- Where no duty is payable: the person importing the goods, even if someone imports them on their behalf.
- The importer can be established in the UK or outside it.

## Agents do not become the importer

If a freight forwarder, customs broker, haulier, express operator or tax agent declares the goods for you, you are still the importer. A tax agent can file CBAM returns for you but cannot register you, and no liability attaches to it.

## What to check before the next DDP contract

1. Whose name and EORI number will go on the UK import declaration.
2. Whether your covered UK imports could reach the registration threshold of £50,000 in 12 months, or in the next 30 days.
3. Who will hold the records: commodity code, value, net weight, origin and the verification report.
4. Whether moving to DAP, with the buyer as importer, suits both sides.

## What Senseible does here

Senseible builds the per-tonne figure the importer needs, whoever that is. It does not file UK CBAM returns. We build the figure from your records and check every figure in-house; for the UK it must then be verified by a verifier accredited for UK CBAM. Have your own verifier? Send it to them.

- [DDP exporters under the EU CBAM](https://senseible.earth/answers/can-non-eu-exporter-be-cbam-declarant-ddp)
- [UK CBAM vs EU CBAM](https://senseible.earth/answers/uk-cbam-vs-eu-cbam-differences)

Sources: [HMRC, Check if you are classed as the importer for CBAM](https://www.gov.uk/guidance/check-if-youre-classed-as-the-importer-for-carbon-border-adjustment-mechanism-cbam), [HMRC, Carbon Border Adjustment Mechanism (CBAM): Policy summary (updated 2 November 2026)](https://www.gov.uk/government/publications/carbon-border-adjustment-mechanism-cbam-policy-summary/carbon-border-adjustment-mechanism-cbam-policy-summary)

Last reviewed 2026-11-02.