Authorised CBAM Declarant: Who Needs It and How to Apply

Since 1 January 2026, CBAM goods may be brought into the EU customs territory only by an authorised CBAM declarant. That is the plain instruction in Article 4 of the CBAM Regulation, and it is a customs status, not a registration form: without it, above the threshold, the import is not lawful.

Most importers do not need it. The rest need it well before they think they do, because the decision takes months. This guide covers which group you are in, what the application asks for, what the authority checks, and where the forms actually live.

First: the 50-tonne exemption

The simplification package adopted as Regulation (EU) 2025/2083 replaced the old €150-per-consignment carve-out with a single mass-based threshold. An importer is exempt from the obligations of the CBAM Regulation where the net mass of the CBAM goods it imports in a calendar year does not cumulatively exceed 50 tonnes. The Commission's own estimate is that this drops roughly 90% of importers out of CBAM while keeping over 99% of the embedded emissions inside it.

Three things people get wrong about it:

It is cumulative, not per consignment. Every CBAM good you import in the year counts towards the same 50 tonnes, across iron and steel, aluminium, cement and fertilisers.
Electricity and hydrogen are outside it. The threshold article does not apply to them at all, so there is no small-volume exemption for either.
It is measured in mass, not value. Fifty tonnes of steel is a modest order. If you are anywhere near it, assume you will cross it and start the application.

If you expect to exceed the threshold, you must apply for authorisation before you exceed it. Not on crossing it, and not at year end.

Who does the applying

An importer established in a member state applies in its own name. An importer not established in a member state cannot: authorisation requires establishment in the member state of application, so the indirect customs representative applies and holds the status instead. If you are a non-EU exporter selling DDP into the EU, that is the arrangement you are relying on, and it is worth confirming in writing that your representative actually holds the status rather than intends to.

What the application asks for

Under Article 5, an application submitted through the CBAM Registry carries:

name, address and contact details, and your EORI number;
your main economic activity in the Union;
certification from your tax authority that you have no outstanding tax debt, and a declaration of honour that you committed no serious or repeated infringements in the previous five years;
evidence of financial and operational capacity — profit and loss accounts and balance sheets for up to the three most recent financial years;
your estimated import quantities by goods type and by member state for the current and following calendar year;
your AEO authorisation number, if you hold one, and the parties you represent, if any.

The import estimates are the part that catches people out. They are not a formality: they feed the guarantee calculation, so a number produced carelessly can cost real money.

What the authority checks

Under Article 17, the competent authority grants the status where the applicant:

has no record of serious or repeated infringements of customs, tax, market abuse or CBAM rules in the previous five years, and no serious criminal offence related to its economic activity;
demonstrates financial and operational capacity to meet its CBAM obligations;
is established in the member state where it applies; and
holds an EORI number.

A guarantee is required where the applicant was not established throughout the two financial years preceding the application. The authority sets it at the aggregate value of the CBAM certificates the declarant would be expected to surrender, based on those declared import estimates.

Once granted, the status is recognised in all member states. It can also be revoked — on request, where the criteria stop being met, or on serious or repeated failure to surrender certificates — with notice and a right to be heard first.

How long it takes, and the window that has closed

Commission Implementing Regulation (EU) 2025/486 gives the competent authority 120 calendar days from receipt of the application to assess it, extendable by a further 30 days where it requests additional information. There is a consultation step in which the Commission and other member states can comment, and the decision is communicated in the CBAM Registry.

There was a grace arrangement, and it is gone. Regulation (EU) 2025/2083 allowed an importer or indirect customs representative that had applied by 31 March 2026 to provisionally continue importing until its authority decided. That date has passed. An application filed today buys no provisional right to import: you wait for the decision.

Where to apply

Applications go through the CBAM declarant portal, which sits behind the EU's UUM&DS login:

Access to the Registry is requested through the national competent authority of the member state where you are established, so that list is the practical starting point rather than the portal itself.

The calendar once you are in

Authorisation is the entry ticket, not the obligation. The annual CBAM declaration for 2026 imports is due by 30 September 2027, and certificates covering 2026 emissions go on sale on 1 February 2027 and are surrendered with that declaration. From 2027 there is also a quarterly holding requirement: at each quarter end a declarant must hold certificates covering at least 50% of the embedded emissions of the goods it has imported so far that year.

If you are still working out whether any of this applies to you, start with the goods rather than the paperwork: check your commodity code against the in-scope list.

Frequently asked questions

Do I need to be an authorised CBAM declarant?

Only if you import more than 50 tonnes of CBAM goods into the EU in a calendar year, counted as cumulative net mass across iron and steel, aluminium, cement and fertilisers. Below that you are exempt from the obligations of the CBAM Regulation entirely. The threshold does not exist for electricity or hydrogen: any import of those needs authorisation.

How long does authorisation take?

The competent authority has 120 calendar days from receiving a complete application to decide, under Commission Implementing Regulation (EU) 2025/486, and can add 30 days if it asks for more information. Plan on roughly four to five months, and apply before you expect to cross the threshold rather than after.

Can I keep importing while my application is being assessed?

Not any more. The omnibus regulation let importers who had applied by 31 March 2026 provisionally continue importing until their competent authority decided. That window has closed. An application filed now gives you no right to import CBAM goods above the threshold before it is granted.

I am based outside the EU. Can I apply?

No. Authorisation is granted by the competent authority of the member state where the applicant is established, and being established there is one of the criteria. An importer not established in a member state has to act through an indirect customs representative, and it is the representative who applies for and holds the authorised CBAM declarant status.

Do I need a separate authorisation for each EU country I import into?

No. You apply once, to the competent authority of the member state where you are established, and the status is recognised in all member states. The application does ask you to estimate your import volumes per member state for the current and the following year.

Will I have to post a guarantee?

Only if you were not established in the EU throughout the two financial years before your application. In that case the competent authority sets a guarantee based on the value of the CBAM certificates it estimates you would need to surrender, given your declared import estimates.

Authorised, and now need the numbers? Look up the official default values for your product and country of origin, or price a whole import list at the current certificate price. If you would rather cut the bill than estimate it, the supplier data request templates are what you send your mill to get verified actual emissions instead of defaults.

Sources: Regulation (EU) 2023/956 Articles 4, 5 and 17, as amended by Regulation (EU) 2025/2083; Commission Implementing Regulation (EU) 2025/486; European Commission CBAM definitive regime and CBAM Registry pages. Checked 19 September 2026. Informational, not legal or tax advice.