CBAM Customs Brokers: What Brokers Can and Cannot Do

Customs brokers and agents handle customs declarations for importers. They are authorised to act on the importer's behalf for customs clearance purposes. For CBAM, the broker's role is more limited: they can facilitate data collection and provide import data, but they cannot assume CBAM liability or file CBAM returns on your behalf unless specifically authorised through your Government Gateway account.

Many brokers are developing CBAM services to help their clients manage the new regime. These services typically include: identifying CBAM-covered goods in your import declarations, providing import data in a CBAM-ready format, facilitating supplier data collection through existing supply chain relationships, and assisting with emissions calculation methodology.

However, the fundamental principle is that CBAM liability sits with the importer of record, not the broker. Your broker can help you prepare your CBAM return, but you must register with HMRC in your own name, and the legal responsibility for the accuracy and timeliness of your return remains with you.

Your broker holds valuable data for CBAM compliance: your import declarations, CN codes, shipment values (CIF), and net weights. This is the raw material for CBAM calculations. You need this data arranged by CBAM-covered goods to calculate your liability.

Some brokers will provide CBAM-ready extracts — a report showing only the CBAM-covered lines from your import declarations, with CN codes, net weights, and CIF values. This saves you the work of filtering your own import ledger. If your broker cannot provide this, request a full CHIEF/CDS import report for the period, and filter the CBAM-covered codes yourself.

Oremly integrates with broker data feeds. We accept CHIEF/CDS import reports, broker API feeds, and CSV extracts. The system automatically identifies CBAM-covered lines, calculates emissions based on your supplier data or defaults, and produces a return-ready summary. No manual data entry required.

There are several things your broker cannot do for CBAM: they cannot register for CBAM in your name (you must register yourself), they cannot file your CBAM return unless specifically authorised through your Government Gateway account, they cannot assume liability for the accuracy of your emissions data, and they cannot obtain supplier emissions data on your behalf unless they have an existing relationship with your supplier.

A broker who offers a "full CBAM service" should be clear about what they are providing. Some services amount to data preparation and return transcription, which is valuable but still leaves the legal liability with you. Ask your broker for a written description of exactly what CBAM services they provide and whether they accept any liability for CBAM compliance.

Given that CBAM returns cannot be amended after filing, accuracy at the point of submission is critical. Whether you rely on your broker, software like Oremly, or your own team, the responsible person or entity should conduct a final review of the return before submission.