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Authorised CBAM declarant: application, rejection and recovery.

Since 1 January 2026, only an authorised CBAM declarant may import CBAM goods above the de-minimis threshold into the EU. If your CBAM authorised declarant application is still not lodged, or came back rejected, this page tells you where you stand and what to do next. It is part of Habitat's CBAM compliance services.

Who needs it

Authorisation is now the licence to import.

Regulation (EU) 2023/956 makes authorised-declarant status the precondition for importing CBAM goods under the definitive regime. Whether you need it depends on where you are established and how much you import.

EU importers above 50 tonnes

An importer established in a Member State that brings in more than 50 tonnes net mass of iron and steel, aluminium, fertilisers or cement per calendar year must hold authorised CBAM declarant status before importing.

Non-EU importers, via a representative

Where the importer is established outside the EU, the indirect customs representative becomes the CBAM declarant under Article 5 of Regulation (EU) 2023/956, and it is the representative who must hold the authorisation.

→ Below 50 tonnes: exempt

Under the threshold there is no authorisation, declaration or certificate duty for those goods. Electricity and hydrogen never qualify for the exemption.

The 50-tonne threshold is reviewed annually by the Commission. Treat it as a yearly check on your import volumes, not a permanent status.

The application

How to become an authorised CBAM declarant.

STEP 01Scope the obligationConfirm your CN codes, your net mass per good per calendar year, and which legal entity will act as the declarant.
STEP 02Prepare the fileCompile what the competent authority assesses under Implementing Regulation (EU) 2025/486, the act that sets the conditions and procedure for authorisation.
STEP 03Lodge in the AMMSubmit through the Authorisation Management Module of the CBAM Registry, in the Member State where you are established. Applications have been open since 31 March 2025.
STEP 04Track and respondAnswer the competent authority's follow-up questions quickly and keep your import records clean. A pending application no longer protects imports: that tolerance ended on 31 March 2026.
Missed the window

What if you missed 31 March 2026?

Regulation (EU) 2025/2083 gave importers one piece of breathing room: anyone who lodged an authorisation application by 31 March 2026 could keep importing while the decision was pending. That window is closed. An application filed today protects nothing retroactively. It simply starts the clock on getting you legal.

The exposure is defined in Article 26 of Regulation (EU) 2023/956. The base penalty for failing to surrender certificates is aligned with the EU ETS excess-emissions penalty: EUR 100 per tonne of CO2e, indexed to inflation. Importing CBAM goods without authorised-declarant status is treated more severely, at three to five times the standard penalty, and paying a penalty does not cancel the obligation to surrender the outstanding certificates.

The playbook is unglamorous, and it works. First, verify you are genuinely above the 50-tonne threshold; many smaller importers are not, and below it the obligation falls away for the mass-based goods. Second, lodge the application now: every further import above the threshold without status widens the exposure, and authorisation is also what you need for the first annual CBAM declaration on 30 September 2027, which covers 2026 imports whether or not your paperwork was in order. Third, quantify what has already happened — which consignments, which goods, which embedded emissions — so that any conversation with the competent authority starts from facts rather than estimates.

If CBAM itself is new territory, perhaps because a new product line or an acquisition brought it in the door, start with what CBAM is under the definitive regime, then come back to the declarant question.

Key dates

The declarant timeline at a glance.

DateWhat happens
31 March 2025Applications open via the Authorisation Management Module (AMM) of the CBAM Registry, under Implementing Regulation (EU) 2025/486
1 January 2026Definitive regime applies: only authorised CBAM declarants may import CBAM goods above the de-minimis threshold
31 March 2026Tolerance cut-off: only applications lodged by this date preserved the right to keep importing while pending (Reg. (EU) 2025/2083)
1 February 2027Certificate sales open on the common central platform, covering the 2026 import year retroactively
30 September 2027First annual CBAM declaration and certificate surrender, for 2026 imports

Sources: Regulation (EU) 2023/956 as amended by Regulation (EU) 2025/2083; Implementing Regulation (EU) 2025/486.

How we help

Habitat takes the application off your desk.

One team handles the authorisation, the rescue work if things went wrong, and the emissions data you will need once the status is granted.

On the data side, Habitat runs Karbon360°, our platform for turning installation and supplier data into declaration-ready embedded-emissions figures — so authorisation is followed by a declaration you can actually file.

Before you apply

Have these answers ready.

  • Your CN codes and the net mass per good per calendar year. The 50-tonne threshold counts per importer, per year, across iron and steel, aluminium, fertilisers and cement.
  • The declarant entity: your EU-established company, or the indirect customs representative where you are established outside the EU.
  • Your 2026 import record to date, because the first annual declaration, due 30 September 2027, covers 2026 imports.
  • Your emissions-data route: actual verified figures from your suppliers, or Commission default values under Implementing Regulation (EU) 2025/2621, which carry a 10% mark-up for 2026 imports, 20% for 2027 and 30% from 2028.
  • A certificate provisioning plan: sales open on 1 February 2027 and cover 2026 retroactively. The Q1 2026 certificate price, EUR 75.36, was published on 7 April 2026, and declarants must hold certificates against a share of their estimated annual emissions each quarter.
FAQ

Frequently asked.

How do I become an authorised CBAM declarant?
You apply through the Authorisation Management Module (AMM) of the CBAM Registry, in the EU Member State where you are established. The conditions and procedure are set by Implementing Regulation (EU) 2025/486, and applications have been open since 31 March 2025. The competent authority of your Member State assesses the file and issues the decision.
What happens if I import CBAM goods without being an authorised declarant?
Article 26 of Regulation (EU) 2023/956 treats it as the serious case: a penalty of three to five times the standard penalty, whose base is aligned with the EU ETS excess-emissions penalty of EUR 100 per tonne of CO2e, indexed to inflation. Paying the penalty does not remove the obligation to surrender the outstanding certificates. The practical answer is to pause, check the 50-tonne threshold, and if you are above it, apply immediately and quantify the exposure on imports already made.
My authorised CBAM declarant application was rejected — can I appeal?
The decision comes from the competent authority of your Member State, so a formal challenge runs through that Member State's own review procedures. In practice there are two tracks worth weighing: contest the decision, or fix the grounds the authority named and reapply. Which is faster depends on what the rejection actually says — we start every rescue engagement by reading it line by line.
Can an indirect customs representative act as the CBAM declarant?
Yes. Where the importer is established outside the EU, Article 5 of Regulation (EU) 2023/956 places the declarant role on the indirect customs representative, who must then hold the authorisation and carries the declaration and certificate obligations. Representatives should weigh that responsibility consciously before accepting the role, because it is theirs in law, not the foreign importer's.
Do I need authorisation if I import less than 50 tonnes a year?
No. Regulation (EU) 2025/2083 introduced a de-minimis threshold of 50 tonnes net mass per importer per calendar year for iron and steel, aluminium, fertilisers and cement. Below it there are no authorisation, declaration or certificate obligations for those goods. The threshold does not apply to electricity and hydrogen, and the Commission reviews it annually, so re-check your position every year.
When do I have to buy CBAM certificates?
Sales open on 1 February 2027 on the common central platform and cover the 2026 import year retroactively. During 2026 the cost accrues and should be provisioned: the Q1 2026 certificate price, EUR 75.36, was published on 7 April 2026. Certificates for 2026 imports must be surrendered with the first annual declaration by 30 September 2027.
Talk to Habitat

Get your declarant status sorted.

Tell us what you import and where the application stands — not started, pending or rejected. You get a straight read on your exposure, and a scope, timeline and price in writing within 48 hours.