Becoming an authorised CBAM declarant

The authorisation obligation

Since 1 January 2026, no CBAM goods may be released for free circulation in the European Union unless the importer is registered as an authorised CBAM declarant with the competent authority of their Member State (Art. 4).

This obligation is an absolute prerequisite: customs authorities will not release CBAM goods if the authorised CBAM declarant number is not entered in the customs declaration (Art. 25). Goods will be blocked at the border until the situation is regularised.

Who must register?

The authorised CBAM declarant is:

• The importer who lodges the customs declaration in their own name and on their own behalf
• The indirect customs representative who lodges the declaration on behalf of the importer, if the importer is established outside the EU
• Any person who has the obligation to declare CBAM goods for free circulation

Important: A freight forwarder or direct customs representative does not need to be an authorised CBAM declarant, unless they act in the capacity of indirect representative. In most cases, the CBAM obligation rests with the importer of record.

Multiple Member States: If you import through customs offices in multiple Member States, you need only one authorised CBAM declarant registration -- it is valid across the entire EU. However, the application must be submitted to the competent authority of the Member State where you are established.

Application procedure

The authorisation procedure is defined in Article 5 of Regulation 956/2023 and detailed by Implementing Regulation 2025/486.

Step 1: Application submission

The application is submitted to the competent authority of the Member State where the operator is established. Key competent authorities include:

• France: Direction Generale des Douanes et Droits Indirects (DGDDI)
• Germany: Deutsche Emissionshandelsstelle (DEHSt) at the Federal Environment Agency
• Netherlands: Nederlandse Emissieautoriteit (NEa)
• Belgium: Service Changements Climatiques (SPF Sante publique)
• Italy: Ministero dell'Ambiente
• Spain: Agencia Estatal de Administracion Tributaria (AEAT)

The application file must contain:

• Identification of the applicant (EORI number, legal name, registered address)
• Description of import activities (sectors, estimated annual volumes, countries of origin)
• Evidence of financial capacity and operational capability
• Commitment to comply with CBAM obligations (annual declaration, verification, certificate surrender)
• Designation of a CBAM contact person within the organisation
• Information on any previous customs or environmental infringements

Step 2: Assessment of the application

The competent authority assesses the application by verifying the conditions set out in Article 17 and Regulation 2025/2549:

1. No serious infringements of customs, tax, or environmental regulations in the past 5 years. This includes criminal convictions, repeated customs penalties, and significant environmental non-compliance
2. Financial capacity to fulfil CBAM obligations (certificate purchases). The authority may request financial statements, bank guarantees, or evidence of creditworthiness
3. Establishment in the European Union (registered office or branch). Non-EU entities must act through an indirect representative established in the EU
4. Valid EORI number -- the Economic Operators Registration and Identification number is a prerequisite

The assessment period is in principle 90 days from receipt of a complete file. Incomplete applications may be returned with a request for additional information, which resets the clock.

Step 3: Issuance and registration

The authorisation is issued in the form of an authorised CBAM declarant number, registered in the CBAM registry (Art. 14, established by Regulation 2024/3210). This number is:

• Unique per operator
• Valid throughout the entire European Union
• Required for any customs operation involving CBAM goods
• To be entered in customs declarations (specific data element)
• Linked to the declarant's certificate account in the registry

The CBAM registry

The CBAM registry (Art. 14) is the centralised electronic system managed by the European Commission. It constitutes the technical infrastructure of CBAM and fulfils several functions.

Registry functions

1. Declarant management: registration, modification, suspension, revocation of authorisations
2. Certificate management: individual accounts for purchase, holding, surrender, and buyback of CBAM certificates
3. Installation registration: third-country production installations registered under Art. 10
4. Annual declarations: submission, validation, and archiving
5. Interoperability: interface with national customs systems for real-time verification of authorised declarant status during clearance
6. Price publication: weekly CBAM certificate prices based on EU-ETS auction results

Accessing the registry

Access to the CBAM registry is via the European Commission portal. The authorised CBAM declarant has a personal workspace where they can:

• View their certificate account balance
• Purchase CBAM certificates at the current weekly price
• Submit their annual declaration
• Upload verification reports
• Track the status of their obligations
• Communicate with the competent authority
• Request buyback of surplus certificates

Obligations of the authorised CBAM declarant

Annual obligations

1. Annual CBAM declaration by 31 May (Art. 6) -- covering all CBAM imports from the previous calendar year
2. Verification of emissions by an accredited verifier (Art. 8) -- see chapter 5 for details
3. Surrender of certificates corresponding to the declared emissions (Art. 22)
4. Interim compliance: hold at least 80% of required certificates by 31 December for the first three quarters' imports

Ongoing obligations

• Maintain records of CBAM goods imported (CN codes, quantities, emissions, origins, installations)
• Retain supporting documents for a minimum of 5 years after the year of import
• Inform the competent authority of any change affecting the conditions of authorisation (e.g. change of address, legal form, bankruptcy)
• Cooperate with authorities in the event of an audit or review (Art. 19)
• Ensure customs declarations correctly reference the CBAM declarant number

Penalties

Article 26 provides for penalties in case of non-surrender of certificates:

• Financial penalty of an amount equivalent to 3 times the average certificate price of the previous year, per tonne of CO2 not covered
• Obligation to surrender the missing certificates in addition to the penalty
• In case of repeated non-compliance: suspension or revocation of the authorised CBAM declarant status
• The penalty regime is enforced by national competent authorities and is designed to be dissuasive

Example: If an operator fails to surrender certificates covering 500 tCO2 and the average 2026 certificate price is EUR 70, the penalty would be 500 x 70 x 3 = EUR 105,000, plus the obligation to still surrender the 500 certificates (approximately EUR 35,000 additional). Total exposure: approximately EUR 140,000.