CBAM Compliance in Germany: DEHSt Requirements
Last reviewed: 4 August 2026 · Author: Kadim Rammahi, Founder, AllMarketZones
For CBAM in Germany the competent authority is the DEHSt (Deutsche Emissionshandelsstelle), the German Emissions Trading Authority based at the Umweltbundesamt, which reviews authorised declarant applications for importers established in Germany. Applications are submitted in the EU-wide CBAM registry, which German users access via the customs portal of the German customs authorities (source: DEHSt, "CBAM Definitive Regime from 2026").
The core definitive-regime provisions apply from 1 January 2026 (Article 36(2), point (b), Regulation (EU) 2023/956). Importers established in a Member State are required to apply for authorised CBAM declarant status before importing goods in scope (Article 5(1)), including where they expect to exceed the 50-tonne threshold of Article 2a (Article 5(1b)), under the Regulation as amended by Regulation (EU) 2025/2083 ("Omnibus I"). This guide explains the DEHSt's role, the application route, and German-specific practicalities.
AllMarketZones provides a fixed-fee CBAM Scope Assessment: a written determination of scope and obligations. We do not provide authorised declarant representation, emissions verification, or binding customs classification advice; where those are required we coordinate accredited partners. For the full picture, see our CBAM compliance guide.
Which authority handles CBAM in Germany?
The DEHSt (Deutsche Emissionshandelsstelle) handles CBAM in Germany as the designated national competent authority. It sits within the Umweltbundesamt (the Federal Environment Agency) and already administers the EU Emissions Trading System for Germany, which is why it was designated for CBAM. The DEHSt receives and decides authorised declarant applications from importers established in Germany, monitors compliance, and liaises with German customs. Its official CBAM information is published by the DEHSt.
The DEHSt's role under CBAM Germany DEHSt rules
The DEHSt is the competent authority that grants authorised CBAM declarant status for German-established importers: applications submitted in the CBAM registry are reviewed by the DEHSt and, if the requirements are met, the status is granted (source: DEHSt, "CBAM Definitive Regime from 2026"; Article 17(1), Regulation (EU) 2023/956). The status is assessed against the criteria in Article 17(2), and the Commission — not the DEHSt — assigns each authorised declarant its unique CBAM account number (Article 16(1)). Certificates can be purchased on the centralised common platform through the CBAM registry from February 2027 (source: DEHSt), while the competent authority applies the penalty provisions of Article 26.
The German application route
German-established importers submit the application for authorisation in the CBAM registry, which is accessed via the customs portal of the German customs authorities; a detailed description of how to access the CBAM registry is published on the Customs (Zoll) website (source: DEHSt, "CBAM Definitive Regime from 2026"). The DEHSt reviews the application as competent authority (Article 17(1), Regulation (EU) 2023/956). Once granted, the status of authorised CBAM declarant is recognised in all Member States (Article 17(1)), and the Commission assigns the declarant a unique CBAM account number (Article 16(1)), so a German authorisation covers imports into any Member State.
Because the underlying rules are set at EU level, the substantive steps mirror those anywhere in the Union — see our step-by-step guide to becoming an authorised CBAM declarant. The German-specific element is the access route via the German customs portal and the fact that the DEHSt, rather than another body, makes the decision.
| Touchpoint | Body | What it covers |
|---|---|---|
| Declarant authorisation | DEHSt (at Umweltbundesamt) | Assesses and grants authorised CBAM declarant status |
| CBAM registry access | Customs portal of the German customs authorities | Access route to the EU CBAM registry (source: DEHSt) |
| Annual declaration | CBAM registry; DEHSt as competent authority | Submitted in the CBAM registry by 30 September each year (Article 6(1)) |
| Certificate purchase | EU common central platform | Sale of CBAM certificates; DEHSt supervises surrender |
| Customs clearance | German customs (Zoll) | Checks declarant status at import of covered goods |
| Penalties | Competent authority (DEHSt) | Article 26 penalties: the Article 16(3) ETS excess emissions penalty (EUR 100 per tonne of CO2e, indexed) per certificate not surrendered; three to five times that for unauthorised imports (Article 26(1)–(2)) |
German-specific practicalities
The main German-specific practicality is the access route: the CBAM registry is reached via the customs portal of the German customs authorities, and a detailed description of the access procedure is published on the Customs (Zoll) website (source: DEHSt, "CBAM Definitive Regime from 2026"). The DEHSt publishes CBAM guidance in German and English on dehst.de. CBAM authorisation is an application in its own right, distinct from any existing EU ETS registration, and is submitted in the CBAM registry where the DEHSt reviews it (source: DEHSt).
A Hamburg-based trading company imports 400 tonnes of aluminium sheet (CN 7606, listed in Annex I) a year from suppliers in the UAE. Because it is established in Germany and exceeds the 50-tonne threshold (Article 2a(1); Annex VII, point 1), it submits the application for authorisation in the CBAM registry, accessed via the customs portal of the German customs authorities, and the DEHSt reviews it (source: DEHSt; Article 17(1)). Once authorised, it submits its first annual CBAM declaration in the CBAM registry by 30 September 2027 for 2026 imports (Article 6(1)) and surrenders CBAM certificates corresponding to the declared embedded emissions (Article 22(1)).
The belief: Because the DEHSt is the German authority, German importers apply on a purely German system separate from the rest of the EU.
The reality: The DEHSt decides German applications, but the application itself is submitted in the single EU-wide CBAM registry (source: DEHSt). The status, once granted, is recognised in all Member States (Article 17(1), Regulation (EU) 2023/956), with the unique CBAM account number assigned by the Commission (Article 16(1)) — not a Germany-only permission.
Who counts as a German-established importer
A German-established importer is a legal entity with its registered seat, central administration or a fixed place of business in Germany. Such an entity applies to the DEHSt because Germany is its Member State of establishment, even if it imports covered goods into other EU countries. A company established elsewhere in the EU applies to that Member State's authority instead, not the DEHSt. A UK company with no EU establishment cannot apply to the DEHSt in its own name: Article 5(1) of Regulation (EU) 2023/956 reserves the application to importers established in a Member State, and where the importer is not established in a Member State, the indirect customs representative obtains the status (Article 5(2)). This mirrors the general position set out in our guide on whether a UK company can be a CBAM declarant.
Sectors and goods the DEHSt supervises
The DEHSt supervises CBAM across all six covered sectors for German-established importers: iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. Aluminium is a common case for German manufacturing and construction supply chains, covering CN Chapter 76 headings such as unwrought aluminium, bars and profiles, plates and sheets, and foil. The Article 2a de minimis exemption does not apply to electricity and hydrogen (Article 2a(4), Regulation (EU) 2023/956), while goods in the other sectors count towards the 50-tonne threshold by net mass (Article 2a(1)). The DEHSt does not change what is in scope — scope is set by EU law — but it is the body that checks German importers have declared and covered the emissions of these goods correctly.
Records and verification expected by the DEHSt
The annual CBAM declaration states the total quantity of each type of goods, the total embedded emissions, and the total number of certificates to be surrendered (Article 6(2), Regulation (EU) 2023/956). Substantiating those figures in practice involves supplier emissions data, calculation methods and evidence of the quantities and CN classifications imported. Because the declaration and certificate surrender depend on emissions data, German importers commonly begin collecting figures from suppliers well before the first declaration is due, rather than at the point of filing.
How the DEHSt fits the wider CBAM timetable
The DEHSt applies the same EU deadlines that bind every competent authority. The core definitive-regime provisions apply from 1 January 2026 (Article 36(2), point (b), Regulation (EU) 2023/956); the first annual CBAM declaration is submitted in the CBAM registry by 30 September 2027 for the year 2026 (Article 6(1)); and the certificate-sales provisions apply from 1 February 2027 (Article 36(2), point (d)). For the full sequence of dates, see our guide to CBAM deadlines for 2026 and 2027. The broader mechanism is documented by the European Commission — CBAM.
Frequently asked questions
Which authority handles CBAM in Germany?
The DEHSt (Deutsche Emissionshandelsstelle), the German Emissions Trading Authority at the Umweltbundesamt, is the competent authority for CBAM in Germany (source: dehst.de). Applications for authorisation are submitted in the EU-wide CBAM registry, where the DEHSt reviews them and, if the requirements are met, grants the status (source: DEHSt; Article 17(1), Regulation (EU) 2023/956).
How do I apply for CBAM authorisation in Germany?
The application is submitted in the CBAM registry, which German users access via the customs portal of the German customs authorities (source: DEHSt, 'CBAM Definitive Regime from 2026'), and the DEHSt decides the application as competent authority (Article 17(1), Regulation (EU) 2023/956). Once granted, the status is recognised in all Member States (Article 17(1)) and the Commission assigns a unique CBAM account number (Article 16(1)).
Does the DEHSt sell CBAM certificates?
No, CBAM certificates are sold through the EU common central platform, not directly by the DEHSt. The DEHSt supervises whether German-established importers have surrendered the correct number of certificates against their declared embedded emissions. It acts as the supervisory and enforcement authority for Germany.
Is a German CBAM authorisation valid in other EU countries?
Yes. The status of authorised CBAM declarant is recognised in all Member States (Article 17(1), Regulation (EU) 2023/956), and the Commission assigns each authorised declarant a unique CBAM account number (Article 16(1)). The application is decided by the competent authority of the Member State of establishment — the DEHSt for Germany.
When must German importers file their CBAM declaration with the DEHSt?
The annual CBAM declaration is submitted 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; confirmed by DEHSt: 'due for the first time on 30/09/2027 for the year 2026'). Certificates corresponding to the declared embedded emissions are surrendered under Article 22(1).
Do EU ETS registrations with the DEHSt cover CBAM automatically?
No. CBAM authorised declarant status requires its own application, submitted in the CBAM registry in accordance with Article 5 of Regulation (EU) 2023/956, where the DEHSt reviews it (source: DEHSt, 'CBAM Definitive Regime from 2026'). An existing EU ETS registration does not confer the status.
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About this guidance. Prepared from Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083 ("Omnibus I"), Commission implementing regulations, and published guidance from the German Emissions Trading Authority (DEHSt). Primary sources: European Commission — CBAM and DEHSt. Author: Kadim Rammahi, Founder, AllMarketZones — full bio.
Limitations. AllMarketZones provides cross-border marketplace expansion and trade governance advisory, including a fixed-fee CBAM Scope Assessment. We do not provide authorised declarant representation, emissions verification, or binding customs classification advice; where those are required, we coordinate accredited partners.