How to Become an Authorised CBAM Declarant

Last reviewed: 4 August 2026 · Author: Kadim Rammahi, Founder, AllMarketZones

Authorised CBAM declarant status is applied for by an importer established in a Member State, prior to importing goods into the EU customs territory (Article 5(1), Regulation (EU) 2023/956), and is granted by the competent authority of that Member State where the criteria in Article 17(2) are met (Article 17(1)). Where the Article 2a de minimis applies, the application is required from an importer that expects to exceed the 50-tonne threshold (Article 5(1b)).

The core definitive-regime provisions apply from 1 January 2026 (Article 36(2), point (b)). This guide sets out the process as a numbered sequence, from establishment check to ongoing obligations.

AllMarketZones provides a fixed-fee CBAM Scope Assessment: a written determination of whether your imports fall within scope and what obligations follow. We do not provide authorised declarant representation, emissions verification, or binding customs classification advice; where those are required we coordinate accredited partners. For the wider context, see our CBAM compliance guide.

Who needs to become an authorised CBAM declarant

An importer whose Annex I goods cumulatively exceed 50 tonnes of net mass in a calendar year is subject to all obligations under the Regulation (Article 2a(1)–(2), Regulation (EU) 2023/956; Annex VII, point 1), and an importer expecting to exceed that threshold is required to submit the application for authorisation (Article 5(1b)). The Article 2a exemption does not apply to electricity and hydrogen (Article 2a(4)). An importer whose Annex I goods stay at or below 50 tonnes for the year is exempted from the Regulation's obligations for that year (Article 2a(1)) — see our 50-tonne CBAM threshold explainer.

The step-by-step authorisation process

Becoming an authorised CBAM declarant follows six practical steps, from confirming EU establishment to meeting ongoing declaration duties. Each step is set out below.

Step 1: Confirm EU establishment

Article 5(1) of Regulation (EU) 2023/956 provides that "any importer established in a Member State" applies for the status of authorised CBAM declarant prior to importing goods. Where an importer is not established in a Member State, the indirect customs representative obtains the status instead (Article 5(2)); an indirect customs representative appointed under Article 18 of Regulation (EU) No 952/2013 may also agree to act as authorised declarant for an established importer (Article 5(1a)). A company with no EU establishment therefore acts through an indirect customs representative or an EU-established group entity.

Step 2: Identify the national competent authority

The application is decided by the competent authority of the Member State in which the applicant is established, which grants the status where the Article 17(2) criteria are complied with (Article 17(1), Regulation (EU) 2023/956). In Germany the competent authority is the DEHSt (Deutsche Emissionshandelsstelle) (source: dehst.de), covered in our guide to CBAM compliance in Germany.

Step 3: Apply through the CBAM Registry

Applications are submitted in the CBAM registry, the standardised electronic database established by the Commission (Article 14(1), Regulation (EU) 2023/956; DEHSt confirms applications "must be submitted in the CBAM registry"). Under Article 5(5), the application includes the applicant's name, address and contact information, its EORI number, its main economic activity in the Union, tax-authority certification that it is not subject to an outstanding recovery order, and a declaration of honour that it was not involved in serious or repeated infringements of customs legislation, taxation rules or market abuse rules in the preceding five years.

Step 4: Meet the criteria assessed under Article 17(2)

The competent authority grants the status where the criteria in Article 17(2) of Regulation (EU) 2023/956 are complied with: (a) the applicant has not been involved in a serious infringement or repeated infringements of customs legislation, taxation rules, market abuse rules or the CBAM Regulation, and has no record of serious criminal offences relating to its economic activity during the five years preceding the application; and (b) the applicant demonstrates its financial and operational capacity to fulfil its obligations under the Regulation. For the purpose of the capacity criterion, the competent authority requires a guarantee in the circumstances set out in Article 17(5).

Step 5: Await the authorisation decision

Procedures and deadlines for processing applications are laid down in implementing acts adopted under Article 17(8) of Regulation (EU) 2023/956. A granted status is recognised in all Member States (Article 17(1)), and the Commission assigns the authorised declarant a unique CBAM account number (Article 16(1)), so separate authorisations per Member State are not needed.

Step 6: Meet ongoing obligations

Authorised status carries continuing duties, not a one-off registration. Each authorised declarant submits an annual CBAM declaration in the CBAM registry by 30 September of each year, for the first time in 2027 for the year 2026 (Article 6(1), Regulation (EU) 2023/956), and surrenders the number of certificates corresponding to the declared embedded emissions (Article 22(1)) — see our guide to CBAM deadlines for 2026 and 2027.

Can a UK company be a CBAM declarant?

No — a UK company cannot itself be an authorised CBAM declarant. Article 5(1) of Regulation (EU) 2023/956 reserves the application for the status to importers established in a Member State, and where an importer is not established in a Member State, the indirect customs representative obtains the status (Article 5(2)). A UK exporter or importer without EU establishment therefore routes imports through an EU-established entity, such as a subsidiary, or an indirect customs representative. The UK company can still supply embedded-emissions data and manage the commercial relationship, but the declarant obligations sit with the EU-established party.

What documents and data you need to apply

Article 5(5) of Regulation (EU) 2023/956 sets out what the application includes: the applicant's name, address and contact information; its EORI number; its main economic activity carried out in the Union; certification by the tax authority of the Member State of establishment that the applicant is not subject to an outstanding recovery order for national tax debts; and a declaration of honour covering the preceding five years' compliance with customs legislation, taxation rules and market abuse rules. Where Article 17(5) requires a guarantee for the financial-capacity criterion, the competent authority fixes its amount. Assembling supplier emissions data early also helps, since the annual declaration must state the embedded emissions of the imported goods (Article 6(2)).

How declarant status relates to customs representation

Authorised CBAM declarant status is distinct from being a customs representative, though the two can coincide. The declarant is the entity that holds the CBAM authorisation and carries the annual declaration and certificate-surrender obligations. A customs representative acts on behalf of an importer for customs formalities; an indirect customs representative established in the EU can itself hold declarant status and act for a non-EU principal. For a UK business with no EU establishment, appointing an EU-established indirect customs representative who is an authorised declarant is often the practical route into the market. The representative then carries the CBAM obligations for the goods it declares, and the commercial terms between the parties allocate the underlying cost.

Applying above 50 tonnes without authorisation

A person other than an authorised CBAM declarant who introduces goods into the EU customs territory without complying with the Regulation is liable to a penalty of three to five times the standard penalty (Article 26(2), Regulation (EU) 2023/956). The standard penalty under Article 26(1) is identical to the excess emissions penalty in Article 16(3) of Directive 2003/87/EC — EUR 100 for each tonne of carbon dioxide equivalent, increased in accordance with Article 16(4) of that Directive — applied per certificate not surrendered, and payment does not remove the surrender obligation (Article 26(3)). Authoritative detail on the mechanism is published by the European Commission — CBAM.

Keeping authorisation in good standing

The status continues while the declarant meets the Article 17(2) criteria; before revoking it, the competent authority gives the declarant the possibility to be heard and may consult other competent authorities or the Commission via the CBAM registry (Article 17, Regulation (EU) 2023/956). Practical good standing means keeping CBAM registry account details current and retaining the records supporting each annual declaration, since the declaration must state the information required by Article 6(2).