Glossary
Indirect customs representative
Under EU customs law, a person appointed to deal with customs for someone else, acting in its own name on that person's behalf. Under the Carbon Border Adjustment Mechanism (CBAM), it can hold authorised declarant status and carry the importer's obligations.
- Legal source
- Union Customs Code, Article 18 ↗
- Who it applies to
- Customs representatives that lodge customs declarations in their own name on behalf of importers of CBAM goods. Where the importer isn't established in an EU country, the indirect customs representative must obtain the authorised declarant status, even when the importer is under the 50-tonne threshold. Where the importer is established in an EU country, the representative acts as the declarant when the importer appoints it and it agrees, and it must hold the status before importing.
- Example
- A producer of steel bolts outside the EU is the importer of its own goods and isn't established in the EU. A customs agency established in an EU country lodges the customs declarations in its own name on the producer's behalf. The agency must hold the authorised declarant status, even if the producer's imports stay under 50 tonnes in the year.
- Also known as
- indirect representative
EU customs law has two kinds of customs representative. A direct representative acts in the name of and on behalf of another person; an indirect representative acts in its own name but on behalf of another person. A customs representative must, as a rule, be established in the EU's customs territory.
CBAM uses the term to define the importer: when an indirect customs representative lodges the customs declaration, the importer is the person on whose behalf it is lodged. When the representative acts as
From 21 September 2027, a new Union Customs Code, Regulation (EU) 2026/2108, applies and repeals Regulation (EU) No 952/2013. The new code defines direct and indirect representation the same way. References to the old code in other laws, such as CBAM's, then count as references to the new one.
Pending, not law: Commission proposal COM(2025) 989 would have a representative applying for the status give the Economic Operators Registration and Identification (EORI) number, or another national identification number, of each person it acts for.
Our authorised declarant explainer compares using a representative with applying yourself, and our explainer for producers outside the EU covers their side.
Regulations
Carbon Border Adjustment Mechanism (CBAM)
Implementing Regulation (EU) 2026/1740 corrected Annexes I and IV of the default values act, Implementing Regulation (EU) 2025/2621
Used in
EU CBAM authorised declarant: how to apply, or use a customs representative
Beyond the 50-tonne exemption, only authorised declarants can import CBAM goods into the EU. How to apply, the guarantee, and the representative route.
EU CBAM certificate price: how certificates work and what they cost
How the EU CBAM certificate price is set, when you can buy, the 50% quarterly holding rule, surrender by 30 September 2027, and a worked cost example.
EU CBAM 50-tonne threshold: does it apply to you, and what if you cross it?
At 50 tonnes or less a year of CBAM goods (not electricity or hydrogen), you're exempt from the EU CBAM. What counts, and the penalty for crossing unauthorised.
EU CBAM for producers and exporters outside the EU: registration, verification and who pays
Making steel, aluminium, cement or fertiliser in India or elsewhere outside the EU? What EU CBAM means for you: optional registration, verification, who pays.
EU CBAM downstream products: what the proposed extension covers, for whom and from when
The Commission proposes adding downstream steel and aluminium goods to EU CBAM from 1 January 2028. Check the CN codes, who it affects and where it stands.
EU CBAM simplification: what Regulation (EU) 2025/2083 changed
EU CBAM simplification: a 50-tonne yearly threshold replaced the €150 exemption, the deadline moved to 30 September and the quarterly holding fell to 50%.