EU companies need an authorization as CBAM declarant to import CBAM goods into the EU in 2026. Applications are open since March 2025. They are to be submitted via the new CBAM Registry. An assessment period of 120 days applies. Provisional import is possible if the application is submitted by 31/3/2026.
(Last update on 03/12/2025)
The status of authorized CBAM declarant
In 2026, the import of CBAM goods into the EU will only be possible for authorized CBAM declarants. Then the definitive rules for the EU’s Carbon Border Adjustment Mechanism (CBAM) will come into effect.
During the transitional period, which has been running since October 2023, it is still possible to import CBAM goods without such an authorization. However, reporting obligations already apply to importing companies.
The authorization as a CBAM declarant is a central element in the CBAM framework – established by the overarching CBAM Regulation 2023/956. Just in October this regulation was amended to simplify the implementation – also to exempt smaller importers with less than 50 t of imported CBAM goods per year.
The Implementing Regulation 2025/486 lays out the conditions and procedure for authorization based on Articles 5 and 17 in the overarching regulation. While a draft for public consultation was already made available on October 30, 2024, the final regulation was only published on March 17. It started to apply on March 28, 2025.
The Implementing Regulation 2024/3210 had already entered into force before. This regulation outlines the set-up of the CBAM Registry. Importers can access it through the CBAM Declarant Portal. Applications for authorization as CBAM declarant can be submitted via this portal – starting March 31.
The authorization is carried out by the National Competent Authority (NCAs) of the member states where the importer is established. For companies in Germany, this is the German Emissions Trading Authority (DEHSt).
Authorization procedure for CBAM declarant
Authorization as a CBAM declarant results in CBAM rights (i.e., importing goods into the EU) and obligations (i.e., purchasing CBAM certificates for the embedded emissions in imported goods). The status of an authorized CBAM declarant will be recognized in all member states.
Who can apply for an authorization?
An application can be submitted by companies that are established in a member state and import CBAM goods into the EU:
- for themselves;
- for another company, but act as an indirect customs representative in their own name.
Special provisions apply for the import of electricity.
What are the requirements for authorization?
The following criteria must be met for authorization:
- No serious or repeated infringement of customs legislation, taxation rules, market abuse rules or the CBAM regulations, and in particular no record of serious criminal offenses in the course of business activities during the 5 years prior to the application;
- Proof of financial and operational capacity to fulfill the obligations under this Regulation;
- Establishment in the Member State in which the application is made;
- Existence of an EORI number.
Authorization may be refused if these criteria are not met, or the necessary information is not provided.
Where to apply for authorization?
Applications can be submitted via the Authorization Management Modul (AMM) in the Declarant Portal of the CBAM Registry. This new registry complements the Transitional Registry through which CBAM reports are submitted.
In Germany access is managed via the customs portal, as for the Transitional Registry. Companies with access to the Transitional Registry will automatically be activated.
What information is required for authorization?
The following information must be submitted as part of the application for authorization:
- Name, address and contact information;
- EORI number;
- Main economic activity carried out in the Union;
- Certification by tax authority of no outstanding recovery order for national tax debts;
- Declaration of honor that there have been no serious or repeated infringements of customs legislation, taxation rules or market abuse rules in the five years prior to the year of application, including no serious criminal offenses in the course of business activities;
- Proof of financial and operational capacity to fulfil the obligations under this Regulation;
- Estimated monetary value and volume of imports of goods into the EU by type of goods, for the calendar year during which the application is submitted, and for the following calendar year;
- Names and contact information of the persons on behalf of whom the applicant is acting, if applicable.
Additional information on the form and content of the required information is published by the NCAs. For example, the requirements for the necessary tax certificates vary from country to country.
The proof of financial and operational capacity in accordance with Article 10 of the Implementing Regulation 2025/486 is also handled differently. In Germany, for example, the submission of annual statements is compulsory.
How does the authorization process work?
Once the application for authorization has been submitted, it is reviewed by the NCA. If there are any changes prior to the decision, these must be indicated immediately via a request for adjustment.
NCAs initiate a consultation procedure with the other member states and the EU Commission no later than 45 days after receipt of the application. In this process, it is checked whether there are any objections to the authorization. If there are no responses, the authorization criteria are deemed to have been fulfilled.
NCAs have a total of 120 days to assess the application to make a decision (before June 15, this period is 180 days). If additional information is required, the review period may be extended by 30 days – also when if applications are subsequently adjusted.
The authorization process is organized by the country’s NCA. In Germany, another legal entity is to run this task until end of 2026. On July 4, DEHSt has assigned KPMG Law Rechtsanwaltsgesellschaft mbH to handle the authorizations. They will process and assess the received applications and run the communication.
Applications for authorization
The adopted CBAM amendments also relaxed the deadline for authorization. The applications need to be submitted by 31 March 2026 at the latest to ensure the release of imported CBAM goods without penalties.
CBAM goods may be imported into the EU from 1 January 2026 in the following cases:
i. If an authorization has been granted after the application has been submitted
ii. If an application for authorization has been submitted by 31/3/2026, provisionally until a decision has been made: If the application is then rejected, the national authority will impose sanctions in the form of penalties for the goods imported up to that point;
iii. Without authorization for an annual quantity of CBAM goods of <50t: When the quantity limit is exceeded in the course of a year, the import of goods is stopped and an application for authorization must be initiated.
New TARIC document coding will have to be provided in the customs declaration for goods imported from 1 January 2026 onwards.
First companies, who submitted applications earlier this year, have already been granted the CBAM declarant status. Importers should not wait too much longer to hand in their applications to get the authorization in time.
For most companies, this is likely to be a formal step. However, responsibilities for this step need to be assigned – also with a view to manage the coming CBAM certificates. As this is a new task, roles and responsibilities still need to be figured out in many companies.
Sources and further information:
- DEHSt: Authorization for CBAM Definitive Phase
- EU: Implementing Regulation for authorization of CBAM Declarants (2025/486)
- EU: Regulation establishing CBAM (2023/956)
- EU: Regulation for Simplifying and Strengthening CBAM (2025/2083)
- EU Commission: Authorization Management Module in the CBAM Registry
- EU Commission: CBAM Declarant Portal – User Manual
Photo by Alexander Grey on Unsplash
