Who is the CBAM reporting declarant for electricity imports?
In general, the CBAM reporting declarant is the person who submits the customs declaration. As is the case for other CBAM goods, importers established outside of the EU must appoint an indirect representative to fulfil the CBAM reporting obligations. There is also the possibility to appoint service providers for CBAM reporting purposes, but this does not lift importers (or indirect representatives, where applicable) from liability.
During the definitive period, under Article 5(4) of the CBAM Regulation, where transmission capacity for the import of electricity is allocated through explicit capacity allocation, the person to whom capacity has been allocated for import and who nominates that capacity for import shall be regarded as an authorised CBAM declarant in the Member State where the person has declared the importation of electricity in the customs declaration.
Source: EC’s Questions and Answers on CBAM
CBAM Regulation
CBAM Regulation 2023_956