Who is an authorised CBAM declarant?
An authorised CBAM declarant is an importer established in the EU, or an indirect customs representative acting for an importer, that has been granted the status by the competent authority of the Member State where it is established. The status is recognised in every Member State.
Since 1 January 2026, CBAM goods above the 50-tonne threshold may only be imported by an authorised CBAM declarant. Importers of electricity and hydrogen need the status whatever the quantity they import.
Who needs the status of an authorised CBAM declarant?
You need the status if you are established in an EU Member State and expect to import more than 50 tonnes of CBAM goods in a year. Below that threshold you are exempt and state the exemption in the customs declaration instead.
The status is also needed by:
- an indirect customs representative that acts as the CBAM declarant for an importer;
- the indirect customs representative of an importer that is not established in the EU, since that importer cannot hold the status itself;
- importers of electricity or hydrogen, whatever the quantity, because the 50-tonne threshold does not apply to them.
If you import electricity using cross-border capacity allocated to you explicitly, you are treated as an authorised CBAM declarant and the competent authority registers you in the CBAM Registry.
How do I apply?
You apply through the CBAM Registry, the Commission's system for CBAM, and the application goes to the competent authority of the Member State where you are established. How you sign in to the Registry depends on your Member State, so your national authority's CBAM page is the place to start.
The authority grants the status if you:
- have an EORI number;
- are established in the Member State where you apply;
- have not been involved in serious or repeated infringements of customs, tax, market abuse or CBAM rules, and have no record of serious criminal offences relating to your business in the five years before applying;
- can show the financial and operational capacity to meet your CBAM obligations.
If your business has not been established for the whole of the two financial years before you apply, the authority will ask for a guarantee, such as a bank guarantee. Its amount is based on the certificates you would have to surrender for the imports you expect.
Can I import while my application is pending?
Only if you applied by 31 March 2026. Those applicants may keep importing until the authority decides. If the application is then refused, the authority works out the emissions in the goods imported since 1 January 2026 using default values, and those imports are penalised as imports without the status.
If you apply now, you need the status before your imports of CBAM goods pass the 50-tonne threshold.
What happens if I import without the status of an authorised CBAM declarant?
Importing CBAM goods beyond the threshold without the status is penalised for each certificate that should have been surrendered. The penalty is based on the excess emissions penalty under Article 16(3) of Directive 2003/87/EC, as increased under Article 16(4) of that Directive, applicable in the year of import. For an importer over the threshold, the emissions in all the goods imported that year count towards it.
What does the status involve afterwards?
As an authorised CBAM declarant you:
- use your CBAM account number in customs declarations for CBAM goods;
- submit a CBAM declaration by 30 September each year, for the previous year's imports;
- surrender the matching number of CBAM certificates by the same date;
- from 2027, hold certificates for at least 50% of the year's embedded emissions at the end of each quarter.
The authority can revoke the status if you no longer meet the criteria for it, or for serious or repeated failures to surrender certificates or to keep the quarterly holding. The dates for each year are on the CBAM deadlines page.