Who is the importer for UK CBAM?

The first organisational question in a UK CBAM review is not “who placed the order?” It is “who is the importer?” HMRC describes the importer as the liable person—the individual or organisation that may need to monitor the threshold, register, submit returns and pay the tax.

When customs duty applies

HMRC says that where customs duties are payable, the importer is the individual or organisation named on the import declaration—even where somebody else declares the goods on its behalf.

The declaration is therefore the best starting evidence. Ask for the legal name, EORI number and declaration reference rather than relying only on a purchase order or supplier invoice.

When no customs duty is payable

Where no customs duties are payable, HMRC says the importer is the individual or organisation importing the goods, including where another person imports them on its behalf. A zero-duty rate does not by itself mean there is no importer for CBAM.

Agents can help, but responsibility stays put

HMRC lists tax agents, employees, freight forwarders, hauliers, customs brokers, express operators and fast parcel operators as examples of people who may act on behalf of the importer.

A tax agent may submit CBAM returns for the liable person. The policy summary says the agent cannot register on the liable person’s behalf and does not take on the liability merely by acting as agent.

Group companies need separate attention

A corporate group can have central procurement, one company paying suppliers and another company named on customs declarations. Do not total every group import under the best-known company name.

1. List the legal entities. Record the full legal name and EORI number used by each importing entity.
2. Sample the declarations. Check who is named on recent entries for each route, broker and business unit.
3. Separate the registers. Keep threshold monitoring and records attributable to the correct liable person.
4. Resolve exceptions. Escalate declarations that use an unexpected entity or unclear representation arrangement.

What to ask your customs contact

• Which legal person is named as importer on the declaration?
• What EORI number appears on the entry?
• Is the broker acting directly or indirectly, and on whose behalf?
• Are any goods entered without customs duty, and which business imports them?
• Can the business receive a regular declaration-level export?