Who does what: the four roles · CBAM Aluminium

4.Who does what: the four roles

Episode S1-04 · Who does what: the four roles · 2:27

Authorised CBAM declarant (EU side). Only an authorised declarant may import CBAM goods. Normally this is the EU importer. If the importer is not in the EU, its indirect customs representative must hold the status and carries the obligations. The declarant is liable for the declaration.

Operator (you). The person who operates or controls the installation, including a parent company. You have no legal CBAM obligation: importers can buy from you anyway and use default values. But only you have the real emission data, so in practice you monitor, report and pass it on.

Accredited verifier. Actual emissions must be checked by a verifier accredited in an EU Member State. You hire the verifier. See S3.

Authorities. Each Member State has a national competent authority (NCA) that grants authorisations, reviews declarations and imposes penalties. The European Commission runs the CBAM registry and registers non-EU operators.

KEY Without your verified data, your customer must use default values, which include a mark-up. Verified actual data is therefore a sales argument.

Sources: REG Art 3(15), 3(31), 4, 5(1)-(2a), 7(2), 8(1), 10(1), 11(1), 17(7a), 18(2), Annex IV point 4.1; G1 §2.4.1 p.12-13; G2 §6 p.15; QA §1.16 p.16, §1.18 p.17, §5.10 p.44; GOLIVE p.1.