CBAM Authorised Declarant: What importers need to know before the March 28 application opening

The EU’s Carbon Border Adjustment Mechanism (CBAM) is entering a crucial new phase. From March 28, 2025, businesses importing regulated goods such as aluminium, steel, iron, cement, fertilisers, electricity, and hydrogen must apply for Authorised CBAM Declarant status to continue operations seamlessly in the EU.

This new requirement is a significant compliance hurdle for importers, adding layers of administrative, financial, and risk assessment obligations. For businesses that are not yet prepared, the time to act is now.

The EU Commission recently released guidance on becoming an Authorised CBAM Declarant, but like all EU Commission publications, it’s difficult to parse. Here, we’ve simplified the guidance, explaining what steps businesses need to take to become Authorised CBAM Declarants, key compliance considerations, and what to do before the January 1, 2026 deadline, when CBAM officially comes into full effect.

Why do importers need Authorised CBAM Declarant status?

CBAM’s goal is to prevent carbon leakage—ensuring that emissions-intensive production does not simply shift to regions with weaker environmental regulations. By requiring importers to hold an Authorised CBAM Declarant status, the EU is ensuring that only verified entities can manage CBAM certificate purchases, emissions reporting, and compliance monitoring.

Failure to obtain this status will result in import restrictions for covered goods, effectively barring non-compliant businesses from selling into the EU.

How to become an Authorised CBAM Declarant

The application process has five key steps, outlined in Commission Implementing Regulation (EU) 2025/486:

1. Submit an application

Businesses must apply electronically via the CBAM registry in the EU Member State where they are established. The application must include:

• Company details (legal name, registered address)
• EORI number (Economic Operators Registration and Identification number)
• Estimated import volumes of CBAM-covered goods
• Proof of financial and operational capacity to comply with CBAM obligations

For companies not based in the EU, applications must be submitted through a representative authorised to act on their behalf within an EU Member State.

2. Application review and additional information requests

• Authorities will have up to 120 days (or 180 days for applications submitted before June 15, 2025) to review the submission.
• If additional details are required, businesses may receive an extension of up to 30 additional days.
• During this period, applicants may also adjust submitted information if necessary, provided justification is given.

3. Compliance checks & risk assessment

Applicants must demonstrate:

• Financial stability (no ongoing bankruptcy proceedings, ability to pay CBAM certificate costs)
• Legal compliance (no history of serious or repeated tax/customs infringements)
• Administrative capacity (sufficient internal controls to manage CBAM declarations)

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To demonstrate these qualities, you’ll need:

• An administrative organisation that can fulfill the estimated obligations for CBAM certificates
• Internal controls that can prevent, detect, and correct errors in CBAM declarations and identify and prevent illegal/irregular transactions

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You’ll also need to establish key internal documents and processes, including:

• Standard Operating Procedures
• Mechanisms to calculate and determine CBAM liability
• Clearly defined roles and responsibilities for managing CBAM declarations, CBAM certificate procurement, reporting, and supplier engagement
• Internal controls to identify, manage, and mitigate incorrect, illegal, or irregular transactions

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For new businesses or those deemed high-risk, additional guarantees may be required.

4. Decision and authorisation

• If approved, the declarant will receive a CBAM account number and be registered in the CBAM database.
• If rejected, applicants have the right to appeal.

5. Ongoing compliance & monitoring

• Authorised CBAM Declarants must ensure continuous compliance with CBAM rules.
• EU authorities may reassess authorisation status at any time.
• Non-compliance or major infringements can result in revocation of authorisation.

Key deadlines for importers

• March 28, 2025 – CBAM Authorised Declarant applications open
• June 15, 2025 – Early application deadline for 180-day review period
• January 1, 2026 – Only Authorised CBAM Declarants can import regulated goods

What happens if an application is rejected?

If a company is denied Authorised CBAM Declarant status, it has two options:

1. Appeal the decision and provide additional supporting documentation.
2. Reapply with corrected or additional information.

Businesses without authorisation by January 1, 2026, will be unable to import CBAM-covered goods into the EU.

How can businesses prepare now?

To ensure a smooth application process, importers should take the following steps before March 28:

• Gather required documentation – Ensure company details, financial records, and emissions data are readily available.
• Assess compliance risk – Conduct an internal review to confirm financial stability and legal compliance history.
• Plan for potential guarantees – High-risk applicants may need to provide additional financial assurances.
• Engage with suppliers – Ensure upstream suppliers are providing accurate emissions data to avoid reporting risks.
• Stay updated on CBAM price dynamics – Since CBAM certificate costs are linked to the EU Emissions Trading System (ETS), businesses should closely monitor ETS price trends.

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Act now to secure EU market access

The introduction of Authorised CBAM Declarant status marks a major shift in how businesses must manage carbon compliance. Companies that fail to act now risk losing access to EU markets when CBAM enforcement begins in 2026.

By preparing applications early, ensuring internal compliance, and securing the necessary financial and administrative resources, businesses can protect their supply chains, mitigate risk, and stay competitive in a low-carbon economy.

If you need support with CBAM compliance, talk to CarbonChain today.

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