Have questions? Our expert AI can assist with CBAM queries.
How to Become an Authorised CBAM Declarant

How to Become an Authorised CBAM Declarant

2025-05-15•By Víctor Pérez Prieto

What Is CBAM and Why It Matters

The EU CBAM is a major environmental policy designed to address carbon leakage. It ensures that imported goods are subject to the same carbon costs as those produced within the EU, thereby maintaining a level playing field.

Currently in its transitional phase (until 31 December 2025), CBAM requires importers of covered goods to report embedded emissions. From 2027, businesses will also need to surrender CBAM certificates—but only if they have been granted authorised declarant status.

To import CBAM goods legally during the definitive phase (beginning in 2026), businesses must obtain authorisation and become authorised CBAM declarants.

Who Needs CBAM Authorisation?

CBAM authorisation is required for:

  • Importers established in an EU Member State
  • Indirect customs representatives acting on behalf of non-EU businesses

Once authorised, entities will be permitted to import CBAM goods into the EU and fulfil their obligations, including the surrender of CBAM certificates.

When to Apply

Businesses planning to import more than 50 tonnes of CBAM goods in 2026 should apply as early as possible. Processing times may vary:

  • Up to 180 days for applications submitted before 15 June 2025
  • Up to 120 days for applications submitted after that date

Additional delays may occur if the authorities request further information. Hence, missing these windows could delay your ability to import CBAM goods by months. All applications must be submitted electronically via the CBAM registry.

Authorities Involved

The CBAM authorisation process involves several key bodies:

  • National Competent Authority (NCA): Responsible for processing applications and making final decisions
  • Other National Authorities: Provide input without decision-making power
  • European Commission: Ensures consistency across Member States and participates in the consultation process

CBAM Authorisation Criteria

To be granted CBAM authorisation, applicants must meet the following requirements:

  • No serious or repeated customs, tax, or CBAM-related infringements in the past three years
  • No serious criminal offences in economic activities in the past five years
  • Not subject to bankruptcy proceedings
  • Financially stable and not in material arrears on duties or taxes
  • Have effective internal controls and administrative capacity for managing CBAM obligations

Authorities may request supporting documentation such as criminal records or financial audits to verify compliance. If the applicant was not established for the two financial years preceding the application, a financial guarantee may also be required. This guarantee must cover the estimated value of CBAM certificates and will be subject to monitoring and adjustment.

The Consultation Process

After receiving an application, the competent authority initiates the consultation procedure electronically via the CBAM registry within 45 days.

As part of this process, the competent authority consults with:

  • Other national competent authorities
  • The European Commission

The consultation covers whether:

  • The applicant has submitted an application for authorisation in any other Member State
  • An authorisation has already been granted to or revoked from the applicant in another Member State
  • There are any objections to granting the applicant the status of authorised CBAM declarant

The consultation must be concluded within 15 working days, unless specific conditions justify an extension.

If the Application Is Refused

If the competent authority intends to refuse the application, it must:

  • Provide the applicant with a detailed explanation for the refusal
  • Allow up to 30 days for the applicant to submit observations
  • Allow the applicant to appeal the decision

Revocation of a CBAM Authorisation

A CBAM authorisation may be:

  • Revoked if the authorised declarant fails to comply with regulatory requirements
  • Reassessed if the competent authority believes that the conditions for authorisation are no longer met
  • Amended due to organisational or structural changes affecting the authorised declarant

In the case of revocation, the competent authority will initiate a consultation procedure via the CBAM registry, involving relevant national authorities and the European Commission.

Before making a final decision, the authority must:

  • Inform the authorised CBAM declarant of its intent to revoke
  • Give the declarant an opportunity to respond
  • Allow up to 10 working days to provide additional information or observations

If the authorisation is revoked, the declarant remains responsible for:

  • Submitting CBAM declarations for goods imported prior to the revocation
  • Surrendering any outstanding CBAM certificates

Once all pending obligations are fulfilled, the importer or indirect customs representative may reapply for authorisation at any time.

Final Thoughts

CBAM compliance isn't just a regulatory requirement—it's a competitive edge for importers who act early. Delays could mean disrupted supply chains, blocked imports, and unnecessary costs.

Need help becoming an authorised CBAM declarant?

At Carbon Glance, we simplify CBAM for importers and manufacturers—minimising your risk, cost, and compliance burden.