Yesterday in Marghera, as part of a conference organized by Assosped Venezia and ANASPED, the Regulation was discussed European Law No. 956 of 2023 which introduced a carbon tax to high-carbon products that are imported into the EU and, in particular, the repercussions, risks and and the possible opportunities that the standard, which defines a Carbon Border Adjustment Mechanism (CBAM), can have for customs brokers. "In fact," he said. explained the lawyer Sara Armella - from the analysis of the law as it is written now, profiles of responsibility have emerged especially with regard to the indirect representative of those importers who are not resident in the EU. This - has highlighted - is an aspect that needs to be cautiously because it involves the assumption of the risk of administrative sanctions, but they have a significant economic situation. We have seen how to protect yourself from this Risk: mandate contracts, insurance, very careful choice of the operators for whom to assume responsibility for CBAM declarant, given that any liability the indirect representative of the non-resident is at risk. That said, it's right underline that this is a major breakthrough from the point of view of from the point of view of environmental sustainability, the idea of going to penalizing the polluting productions that harm us all, is That is certainly a good thing. From a professional point of view, it can also be an opportunity, someone said it, Why importing companies are unprepared for this new fulfilment, and the ability and experience of the freight forwarders is certainly fundamental."

More risks than opportunities are seen by the President of the Venice Customs Brokers Association: specifying that it is "a fundamental issue for the but also for businesses, because it touches those that, as the lawyer Sara Armella has well pointed out, are the responsibilities and risks that the indirect representative is facing', Marco Corda clarified that the personal opinion "is that in the case of subjects who do not residents of the European Union and who therefore need the indirect representation, the risk posed by the transaction to the customs broker is a risk that cannot be contained, and therefore not to be hired'.

The fact that the issue is very much felt by the category has been highlighted by the the president of Assosped Venezia, Andrea Scarpa, noting that the A large number of participants in the conference testifies that it is "a An issue that is crucial for us customs officers and always becomes so more as we get closer to 2026 when the will be fully operational. There, he warned, are the knots They will all come to a head, but now we are in a transitional phase As has emerged today, it is a norm to be approached with great care: to take on such imponderable risks, How to determine the amount of direct emissions and indirect taxes that are related to the production of a good of which we follow the import," Scarpa pointed out, "it is a source of A lot of concerns. We are customs officers, we cannot enter the merit of what the producers tell us compared to what they They release into the atmosphere to produce, for example, a pen. And therefore, if you want to make CBAM declarations, you will have to have a solid insurance and contract protection behind them, Otherwise, my idea is that the importers, we will give you the assistance but then the responsibility They will have to take it on themselves."

From the conference, also introduced by the speeches of Massimo De Gregorio, president of ANASPED, and Franco Letrari, director interregional Customs and Monopolies Agency of Veneto and Friuli Venezia Giulia, the crucial issue has emerged of the responsibility one assumes in being a declarant CBAM: first and foremost the correct identification of the goods subject to to the CBAM regulation, which is not as simple as it could be appear to an outside observer; then the difficulty, if not the impossibility, of having certainty about the goodness of the Declarations of direct emission quantities and indirect related to the production of the object import. A question that is not easy to resolve, involves not only importers, but also the producers of the often reluctant to divulge data through which they think it is critical or confidential aspects of their manufacturing processes.