How to Become a CBAM Authorized Declarant

The EU’s Carbon Border Adjustment Mechanism (CBAM) is reshaping import regulations for carbon-intensive goods. As the definitive period starts January 1, 2026, securing Authorized CBAM Declarant status becomes essential for businesses importing goods like cement, iron, steel, aluminium, fertilisers, electricity, and hydrogen into the EU.

Need clarity on the process? Join Dubrink’s live webinar on April 29 at 11:00 CEST, hosted by Chief CBAM Officer Marcel Duits, for a practical walkthrough.

Why Authorization is Crucial from 2026

From January 1, 2026, only Authorized CBAM Declarants can import CBAM-covered goods. National authorities will block imports by non-authorized entities. Failing to get authorized means losing market access for these goods. Applications open via the CBAM Registry on March 31, 2025. Apply early to avoid delays.

Who Needs Authorization?

Authorization is required for:

  1. EU Importers: Established in the EU and importing CBAM goods above the potential de minimis threshold (proposed at 50 tonnes/year).
  2. Indirect Customs Representatives: Appointed by non-EU importers, requiring authorization from the first import.

Even if close to the threshold, prepare to apply.

The Application Process

  • When: Submit applications starting March 31, 2025, via the CBAM Registry’s Authorisation Management Module (AMM). Aim for the first half of 2025.
  • Where: Apply electronically via the CBAM Registry to the competent authority in the Member State of establishment.
  • How: Provide applicant details (EORI required ), financial information, proof of compliance, and evidence of operational capacity. Processing takes up to 120 days, potentially longer if more information is needed.

Key Eligibility Criteria

Applicants must demonstrate :

  1. Clean Compliance Record: No serious/repeated violations (customs, tax, market abuse) in the last 3-5 years; no serious business-related criminal offenses in the last 5 years.
  2. Financial Stability: Not undergoing bankruptcy, no significant arrears on duties/taxes, and sufficient financial standing for CBAM obligations.
  3. Operational Capacity: Adequate administrative setup and internal controls to manage CBAM declarations, error correction, and certificate handling accurately.
  4. Possible Guarantee: May be required, especially for newer businesses, to cover potential CBAM certificate liabilities.

Important Considerations

  • AEO Status: Helpful but not mandatory; non-AEOs can qualify by meeting CBAM criteria.
  • Operational Capacity: Requires documented processes and robust data systems. This is often the most demanding part.
  • Data Readiness: Accurate emissions data is crucial for demonstrating capacity and compliance.

Maintaining Your Status

Authorization requires ongoing compliance and is subject to monitoring and potential reassessment or revocation by authorities. Declarants have the right to be heard before revocation. Obligations for goods imported before revocation remain.

Dubrink: Your CBAM Compliance Partner

Navigating CBAM authorization is complex. Dubrink’s platform helps you prepare systems, manage data accurately, and strengthen internal controls to meet the operational capacity requirements. Schedule a demo to see how we can support your application.

Conclusion: Prepare Now

Becoming an Authorized CBAM Declarant is mandatory for importing covered goods from 2026. Start preparing now by understanding requirements, assessing readiness, and implementing necessary systems and controls.