Insights / CBAM
CBAM for Exporters Outside the EU: Who Declares and Who Verifies
We export steel to an importer in the EU. Who declares under CBAM and surrenders certificates, us or them?
The EU side. The authorised CBAM declarant, normally the importer in the EU or its indirect customs representative, declares and surrenders certificates (Articles 4, 6 and 22). An operator outside the EU may ask to be registered in the CBAM registry (Article 10), and has its embedded emissions verified by an accredited verifier (Article 10(5) and Article 18).
What the act says
- Articles 4, 6 and 22: Authorisation, declaration and surrender sit with the authorised CBAM declarant in the EU.
- Article 10: A third-country operator may register in the CBAM registry; the registration is valid for five years (Article 10(3)).
- Article 10(5): Embedded emissions are verified by a verifier accredited under Article 18 and can be shared with the declarant.
What to do
- Measure direct emissions per installation and product, and get them verified.
- Share verified data with EU customers early: default values usually cost them more.
Sources
- Regulation (EU) 2023/956 (CBAM), consolidated text (CELEX 32023R0956)
- Regulation (EU) No 952/2013 (Union Customs Code) (CELEX 32013R0952)
Last checked against the act text on 2026-10-20. For information only, not legal advice.