Authorised CBAM declarant: who needs it and how to apply

• An importer established in an EU Member State that expects to import more than 50 tonnes net of CBAM goods in a calendar year. The 50 tonnes are counted per importer and per year, all CN codes added together (Article 2a, Annex VII; Article 5(1b)).
• An indirect customs representative acting for an importer that is not established in the EU, always, even when that importer stays under 50 tonnes (Article 5(2)).
• An indirect customs representative that agrees to act as authorised CBAM declarant for an importer. It then carries that importer's CBAM obligations for the goods it imports on its behalf (Article 5(1a) and (2a)).

Under 50 tonnes, no status is needed: the importer declares the exemption in each customs declaration (Article 2a(1)). The threshold does not apply to electricity or hydrogen (Article 2a(4)).

An importer without the status that passes 50 tonnes during the year owes CBAM on all goods imported that year, and a penalty of three to five times the EU ETS excess emissions penalty for each certificate not surrendered; the authority may reduce it for a small excess (Article 26(2) and (2a)). The CBAM product checker tells you whether a CN code counts.

The application goes through the CBAM registry. The competent authority of the Member State where you are established decides, and the status is then recognised in all Member States (Articles 5(3) and 17(1)).

The application asks for (Article 5(5)):

• name, address and contact details, and your EORI number;
• your main economic activity in the EU;
• a certificate from your tax authority that you have no outstanding recovery order for national tax debts;
• a declaration of honour that you had no serious or repeated infringements of customs, tax or market abuse rules in the five years before, and no record of serious criminal offences linked to your business;
• information showing your financial and operational capacity, such as profit and loss accounts and balance sheets for up to the last three closed financial years if the authority asks for them;
• the estimated quantity of CBAM goods you will import, by type and Member State, this year and next;
• your AEO certificate number, if you have one;
• the names and contact details of the importers you act for, if you are a representative.

The authority grants the status when you meet four criteria: no serious or repeated infringements (including of CBAM itself) in the five years before, the financial and operational capacity to meet the obligations, establishment in the Member State where you apply, and an EORI number (Article 17(2)).

Guarantee. A company that was not established throughout the two financial years before the year of its application must provide a guarantee: a bank guarantee payable at first demand, or an equivalent. Its amount is the value of the certificates for the imports you estimated in the application (Article 17(5)).

How long it takes. The authority assesses the application within 120 calendar days of receiving it. It may ask for more information, which you must send within the time it sets (at most 30 days), and it may then extend its own deadline by up to 30 days (Implementing Regulation (EU) 2025/486, Articles 4 and 5). The decision is entered in the CBAM registry with your CBAM account number (Article 17(4)).

Applied by 31 March 2026: you may go on importing provisionally until the authority decides. If it refuses, it sets the emissions of everything you imported from 1 January 2026 to the decision with the EU default values, and those emissions are the basis for penalties (Article 17(7a)).

Applying now: there is no provisional right to import. Until your status is granted, you can import CBAM goods only within the 50-tonne exemption, or through an indirect customs representative that holds the status and agrees to act for you (Articles 4, 5(1a) and 2a). Apply well before you expect to pass 50 tonnes: the assessment alone can take four months.

• Certificates are on sale from 1 February 2027.
• At the end of each quarter, your CBAM account must hold certificates for at least half of the embedded emissions of the goods imported since the start of the year.
• By 30 September each year you declare the previous year's imports and surrender certificates; the first declaration, for 2026, is due by 30 September 2027.
• Tell the authority through the CBAM registry about any change to the information in your application (Article 5(7)).
• The status is revoked if you stop meeting the criteria, or after serious or repeated failures to surrender certificates or to hold enough at a quarter end (Article 17(8)).

Every date in a calendar file: the CBAM deadline planner. To ask your non-EU suppliers for their emissions data, use the supplier data request; to see how many certificates to hold each quarter, the certificate planner.

• Regulation (EU) 2023/956, consolidated text of 20 October 2025 (as amended by Regulation (EU) 2025/2083): Articles 2a, 4, 5, 17, 26 and Annex VII.
• Commission Implementing Regulation (EU) 2025/486 on the authorised CBAM declarant, as amended by Implementing Regulation (EU) 2025/2549: Articles 4 and 5.