Skip to content
← CBAM guide

Filing 6 min

How to become an authorised CBAM declarant

In the definitive period you cannot bring CBAM goods into free circulation without authorised declarant status. Who applies, where, what's assessed, and why to start early.

Last updated 20 August 2026

Since the start of the definitive period, authorised CBAM declarant status is the gate to the EU market for covered goods: without it, iron & steel, aluminium, cement, fertilisers, hydrogen and electricity cannot be released into free circulation in your name. It is not a report you file — it is a status you hold, and it has to exist before the goods arrive.

Who applies

The applicant is the person who will lodge the CBAM declaration:

  • an importer established in the EU, declaring for its own imports, or
  • an indirect customs representative, where the importer is not established in the EU (and, where agreed, also for EU-established importers).

If a customs consultant files for several importers, it is the consultant’s own status that carries those clients — one authorisation, many files. (Who plays which role is its own question — see importer of record vs indirect representative.)

Where and how

Applications go through the CBAM Registry, to the national competent authority of the Member State where you are established. The assessment looks at things a customs authority would recognise:

  • you are established in the Member State where you apply,
  • you have the financial and operational capacity to meet the obligation — buying and surrendering certificates against your declared embedded emissions,
  • you have no record of serious or repeated infringements of customs legislation, taxation rules or market-abuse rules,
  • you hold an EORI number — it is an authorisation criterion, not just a form field.

Once granted, the status is recognised in all Member States.

The criteria sit in Article 17(2) of Regulation (EU) 2023/956 as amended by the 2025 Omnibus simplification (Regulation (EU) 2025/2083); the evidence requests around them are your national authority’s practice. Treat this as the current shape and confirm specifics with your competent authority before relying on them.

Why “early” is the whole strategy

Authorisation is a prerequisite, not a formality you can backfill:

  1. Clearance stops without it. A shipment of covered goods with no authorised declarant behind it has no lawful route into free circulation.
  2. Authorities take time. The assessment involves another institution’s queue — you do not control it.
  3. The obligation is already accruing. Embedded emissions on definitive-period imports turn into certificates to surrender; the status is what makes that surrender possible.

If your cumulative imports of covered goods stay at or under the 50-tonne de minimis threshold for the year, the obligation — and the status — may not apply to you at all (check the exemption). Near the line, measure before you assume.

What to have ready when you apply

  • Your EORI number and establishment details.
  • A realistic picture of your annual covered imports — CN codes, net mass, origins.
  • Evidence of capacity to meet the certificate obligation as your authority requests it.
  • A plan for the data behind the declaration itself: a clean read of every customs line, and embedded-emissions figures — actual where you can prove them, EU default where you can’t.

The status opens the door; the declaration still has to be right once you’re through it.

Next: see the deadlines that shape the definitive period, or estimate a shipment with the free CBAM calculator.