Authorised CBAM declarant: obtaining the status to keep importing

Who must obtain it, and who is exempt

The status is not one more formality alongside the customs declaration: it is a condition of entry. Without it, CBAM goods cannot be released for free circulation.

Only two parties can hold it: the importer established in the Union, or the indirect customs representative declaring on its behalf. Never both at once on the same flow. That is a contractual choice to settle beforehand, not at the moment of shipment.

The simplification package introduced a threshold of 50 tonnes of cumulative net mass per year. Below it, no authorisation, no certificates, no annual declaration. But the exemption is not a permanent status: the threshold is assessed over the full calendar year and on total net mass, so it is a position to monitor continuously, and to declare to customs.

What you need to provide

The application is filled in on screen in the registry, but it rests on documents you are better off having assembled before you open the form.

• The company details and its EORI number, in the name of the entity that actually imports.
• The Member State of establishment. An applicant not established in the Union must also give its address in the third country and the Member State where it files.
• A estimate of the volumes and value of CBAM goods imports for the calendar year, broken down by type of goods.
• Evidence of no serious or repeated breach of customs and tax legislation over the last five years, and no serious criminal offence relating to the economic activity.
• Evidence of financial and operational capacity sufficient to meet the obligations attached to the status.
• A description of the internal CBAM compliance procedure : who collects the data, how it is checked, where the supporting evidence is kept.
• The designation of the persons authorised to act in the registry.

The pitfalls that get an application rejected or delayed

• Estimating volumes by guesswork. The estimate is binding. A wide gap between the estimate and actual imports triggers a review of the status.
• Confusing submission with registration. An incomplete file is submitted without being registered, and the 120-day clock never starts.
• Not having settled who holds the status. Importer or indirect representative: until it is written into the mandate, each assumes it is the other.
• Reducing financial capacity to a set of annual accounts. The authority also looks at the ability to buy the certificates when the time comes.
• Never having established the product scope by nomenclature code. Scope is judged code by code, not by commercial description: two neighbouring references in a catalogue can fall under different codes.
• An EORI attached to a different group entity than the one that imports.

What begins once the status is granted

• CBAM certificate sales start on 1 February 2027. No certificate therefore has to be bought during the 2026 import year itself.
• The quarterly holding obligation only bites from 2027: at the end of each quarter, your account must hold at least 50% of the emissions accumulated since 1 January. The simplification package brought this rate down from 80% to 50%.
• The first annual declaration and surrender of certificates are due on 30 September 2027, for 2026 imports. The 31 May deadline still quoted everywhere is the old one: it was pushed back by four months by Regulation (EU) 2025/2083.
• The penalty is EUR 100 per tonne of CO2e not covered by certificates surrendered at the deadline, and it does not replace the obligation to surrender.
• The data you declare must stay consistent with your customs declarations. It is the easiest cross-check for the administration to run, and the one most often overlooked.

. It is the easiest cross-check for the administration to run, and the one most often overlooked.

The practical consequence: the liability is building up now, on emissions that have to be documented as the imports happen. A company that starts collecting in 2027 will have to reconstruct a full year of data from suppliers who have no reason to hurry.

What we do, and what we do not do

The applicant is always the company. No adviser can hold this status on your behalf.

Included: determining the product scope by nomenclature code, estimating volumes and exposure, assembling the application and its documents, drafting the internal compliance procedure, a collection protocol with suppliers in their working language, follow-up of the examination and of any further questions.

Not included: filing the application on the client's behalf unless expressly mandated, the decision to grant, which belongs to the authority, verification and certification of emissions by an accredited verifier, the purchase of certificates, and the lodging of customs declarations.

CTB Group steers customs compliance and governance; the lodging of declarations remains with the representatives appointed by the company.

Frequently asked questions

Can my freight forwarder hold the status for me?

Only if it acts in indirect representation and is itself an authorised CBAM declarant. It then takes on obligations of its own, and that must be written into the mandate. In direct representation, the obligation stays entirely with you.

I am under 50 tonnes. Do I need to apply for the status?

No. But the threshold is assessed on the cumulative net mass of the full calendar year, across all suppliers and all products. It is a position to check continuously, and to declare to customs, not a status you acquire.

How long does it take to obtain the status?

120 calendar days from a complete application. The clock stops as soon as the authority asks for further information, and you then have 30 days to reply. A poorly prepared file therefore costs not a few days, but several months.

Sheet updated on 14 September 2026, sources checked against the national competent authorities. The definitive regime is still evolving: the applicable rules are revalidated for each file. This sheet is a working reference, not legal advice. See also: the authorisations catalogue, metals and CBAM, our CBAM pack.