UK CBAM and the changing role of the customs agent.
UK CBAM creates a new responsibility for importers, but it also raises an important question for the customs profession: where does the role of the customs agent end?
From 1 January 2027, UK CBAM will apply to specified imported goods in the aluminium, cement, fertiliser, hydrogen, iron and steel sectors.
The importer will be responsible for determining whether it is liable, registering when required, maintaining records, submitting returns and paying the tax due. The £50,000 registration threshold will be assessed through both a forward-looking test and a backward-looking test.
These are responsibilities that sit with the importer.
But importers will not manage them in isolation.
Customs agents, freight forwarders and international trade specialists already sit close to many of the relationships, processes and data on which CBAM will depend. In many cases, they may be among the first people an importer approaches for help.
That creates an important opportunity for the customs profession, but it also requires firms to decide what role they want to play.
UK CBAM extends the customs conversation
At first glance, UK CBAM appears closely connected to the customs declaration.
Whether an imported product falls within scope will depend on its commodity code. The value, weight, origin and date of import will all contribute to establishing the importer’s position. Much of this information is already captured through the customs process.
That makes customs data the natural starting point.
It does not, however, provide the complete CBAM position.
The importer will also need to establish the relevant emissions associated with its goods, apply the appropriate CBAM rate, consider any available carbon price relief, maintain supporting evidence and understand how its liability is developing.
This moves the conversation beyond whether a declaration was completed correctly.
The question becomes:
What does this import mean for the customer’s ongoing CBAM position?
The importer remains responsible
The distinction between supporting the importer and assuming responsibility for its CBAM position is important.
HMRC’s guidance confirms that an organisation can remain the importer for CBAM purposes even when a customs broker, freight forwarder or another party completes the import declaration on its behalf.
A customs agent’s involvement does not automatically transfer the importer’s liability.
This should give customs firms confidence to define their service carefully.
Supporting a customer with CBAM does not necessarily mean accepting responsibility for every emissions calculation, financial decision or tax return. Different firms will make different choices depending on their expertise, customer base, professional permissions and commercial model.
The opportunity is not based on every customs agent offering the same service.
It is based on each firm deciding where its service should start and end.
Why customers may turn to their customs agent
For many importers, their customs agent already understands:
what they import;
which commodity codes they use;
where their goods come from;
how frequently they import;
the values and quantities involved;
how their customs declarations are managed;
where information is missing or inconsistent.
That is a valuable starting position.
UK CBAM will be new to many importers. Responsibility may sit across customs, tax, finance, procurement, sustainability and compliance teams, without any one person initially having a complete view.
A customs specialist may therefore be well placed to help the customer establish its first reliable picture of exposure.
This could begin with relatively straightforward questions:
Are any of the customer’s commodity codes within scope?
What value of qualifying goods does it import?
Is it likely to meet the registration threshold?
Which products, suppliers and facilities contribute to its exposure?
What additional emissions information will be required?
Who within the customer’s organisation should own the process?
Answering these questions does not require the customs agent to become responsible for every part of CBAM.
It does allow the agent to help the customer move from uncertainty to a defined position.
Three potential service models
There is no single model for providing CBAM support.
The appropriate service will depend on the firm’s expertise, appetite and relationship with its customers.
1. Identify and inform
The first model is to help customers establish whether UK CBAM is relevant to them.
This could include:
checking historic customs activity;
identifying imports with potentially affected commodity codes;
monitoring qualifying import values;
explaining the registration threshold;
highlighting where further specialist advice is required;
helping customers understand what they need to prepare for.
For some firms, this may be the right boundary.
It extends the existing customs service without requiring the firm to provide ongoing emissions, financial or tax advice.
It also creates value for the customer at the point where that value is most useful: before the obligation begins.
2. Advise and support
Some customs and international trade specialists may want to provide a broader advisory service.
This could include helping customers:
maintain an accurate record of qualifying imports;
understand how customs activity contributes to CBAM exposure;
identify gaps in supplier and facility information;
review the use of default or verified emissions;
monitor developing financial exposure;
prepare for registration and reporting;
coordinate with tax, finance, sustainability or external advisers.
In this model, the customs specialist remains close to the import data while helping the customer connect that data to its wider CBAM position.
The service becomes more than identification, but it does not necessarily become fully managed compliance.
3. Managed CBAM
Other firms may decide to build CBAM into their ongoing compliance proposition.
A managed service could bring together:
monthly import data;
product and supplier information;
emissions records;
forecast and actual liability;
evidence;
actions;
reporting preparation;
coordination across the customer’s internal and external teams.
This is the most comprehensive model.
It also requires clear responsibilities, appropriate technical capability and a controlled system for managing information across multiple customers and reporting periods.
The opportunity may be significant, particularly for customs firms with established compliance services and long-standing customer relationships. However, the service must be designed around reliable processes rather than informal spreadsheet support.
The data is the input. The position is the job.
Customs data is central to UK CBAM, but moving files from one system to another is not the same as managing compliance.
An importer’s CBAM position will change as new goods are imported, emissions information is updated, CBAM rates are published and evidence becomes available.
The role of technology is to turn the underlying customs activity into a position that can be understood and managed.
That means connecting:
Commodity code · Weight · Value · Origin · Supplier · Facility · Emissions · CBAM rate · Liability · Evidence
The output should not simply be another dataset.
It should show the importer and its adviser:
which imports are affected;
where exposure is concentrated;
what information needs attention;
how liability is developing;
what has changed;
which actions are outstanding;
what evidence supports the reported position.
This is particularly important for customs firms managing more than one customer.
Without appropriate technology, every additional customer creates another set of spreadsheets, calculations, evidence files and reporting deadlines. That makes it difficult to provide a consistent and scalable service.
Technology does not replace professional judgement
A specialist platform can undertake much of the repeatable work involved in managing CBAM.
It can process customs data, apply governed calculation methods, maintain reporting-period positions, organise evidence and identify information requiring attention.
It cannot decide how a customs firm should advise a particular customer.
Professional judgement is still required to interpret the position, understand the customer’s circumstances, identify risks and determine when input from another specialist is needed.
This separation is important.
Technology manages the repeatable infrastructure. The customs specialist provides the judgement, relationship and support.
It also allows customs firms to work alongside tax, financial, legal and sustainability advisers without presenting themselves as experts in every discipline affected by CBAM.
Defining the boundary of the service
Before launching a CBAM proposition, customs firms should be clear about what they will and will not provide.
Useful questions include:
Are we identifying potential exposure or confirming liability?
Will we monitor the registration threshold?
Will we maintain the customer’s import position?
Will we support supplier and facility data collection?
Will we advise on emissions information?
Will we forecast financial liability?
Will we prepare information for the return?
Will we submit anything on the customer’s behalf?
Which decisions remain with the importer?
When will we refer the customer to another professional adviser?
What technology, controls and evidence will support our work?
These boundaries should be reflected in the engagement, the operating process and the way the service is described to customers.
A clearly defined service is more credible than a broad promise to “manage CBAM” without explaining what that means.
A natural extension, not an entirely new profession
UK CBAM does not mean every customs agent must become a tax adviser, carbon accountant or emissions verifier.
It does create an opportunity to build on expertise and relationships that already exist.
Customs specialists understand the international movement of goods. They work with the commodity codes, values, weights and origins on which the new mechanism depends. They also understand the practical difficulties of obtaining accurate information across complex supply chains.
For firms that choose to develop the capability, UK CBAM can become a valuable extension of the services their customers already trust them to provide.
The starting point is not deciding how much new work the firm can take on.
It is deciding where the firm can add genuine value, where specialist technology can do the heavy lifting and where another professional adviser should be involved.
That is how the customs profession can play an important role in UK CBAM while keeping the importer’s responsibility, and the boundaries of the customs service, clear.
Decide what role you want to play
UK CBAM will create new responsibilities for importers, but it will also change the conversations they have with customs specialists.
For some firms, the opportunity may be to help customers identify affected imports and understand their exposure. Others may choose to provide ongoing advice or build CBAM into a broader managed compliance service.
The right model will depend on your expertise, customer relationships and commercial priorities. What matters now is deciding where your role should begin and end, and having the right technology behind it.
Notch turns customs data into a clear, governed CBAM position. It helps customs and international trade specialists assess customer exposure, manage emissions information, monitor liability and support ongoing compliance, without having to build the underlying infrastructure themselves.
You retain the customer relationship and decide how you want to support them. Notch provides the specialist CBAM platform behind your service.
Interested in adding UK CBAM to your services?
Find out more about the Notch CBAM Partner Programme LINK