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.
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.
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.
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.
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.
How to become an authorised CBAM declarant.
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.
The declarant timeline at a glance.
| Date | What happens |
|---|---|
| 31 March 2025 | Applications open via the Authorisation Management Module (AMM) of the CBAM Registry, under Implementing Regulation (EU) 2025/486 |
| 1 January 2026 | Definitive regime applies: only authorised CBAM declarants may import CBAM goods above the de-minimis threshold |
| 31 March 2026 | Tolerance cut-off: only applications lodged by this date preserved the right to keep importing while pending (Reg. (EU) 2025/2083) |
| 1 February 2027 | Certificate sales open on the common central platform, covering the 2026 import year retroactively |
| 30 September 2027 | First 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.
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.
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.
Frequently asked.
How do I become an authorised CBAM declarant?
What happens if I import CBAM goods without being an authorised declarant?
My authorised CBAM declarant application was rejected — can I appeal?
Can an indirect customs representative act as the CBAM declarant?
Do I need authorisation if I import less than 50 tonnes a year?
When do I have to buy CBAM certificates?
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.