Will companies be allowed to report at centralised level if subsidiaries in the different Member States have different Economic Operators Registration and Identification (EORI) numbers?
In principle, CBAM goods are attributed to a CBAM reporting declarant through the EORI number provided to the customs authorities. This means that by default, the CBAM reports for the different subsidiaries (with different EORI numbers) will be done separately.
However, multiple group entities of the same multinational corporation can appoint one single indirect customs representative to carry out customs obligations and the related CBAM obligations at a centralised level for all group entities.
It is also possible that one group entity acts as indirect customs representative for the CBAM goods imported by all other group entities. However, the general rule still applies: indirect customs representatives which act as reporting declarants and submit CBAM reports must also carry out the customs obligations related to the goods covered by the CBAM report.
Further, it would also be possible for one group entity to submit CBAM reports as service provider for other group entities of the same multinational corporation. This is in principle possible, but (i) the other group entities would remain reporting declarants for the goods they imported and would therefore remain legally liable for the CBAM report, and (ii) the group entity acting as service provider would need to submit a separate CBAM report for the goods imported by each group entity, including for the goods it has imported itself.
Source: EC’s Questions and Answers on CBAM