The plain-English explainer

Who is the CBAM declarant?

The authorised CBAM declarant is the only entity allowed to import CBAM goods above the threshold from 1 January 2026. It is the party that files the annual CBAM declaration and surrenders certificates. It can be the EU importer itself, or an indirect customs representative acting on a non-EU importer's behalf. DG TAXUD

Last updated · 8 June 2026

TL;DR

  • Who: the only party allowed to import CBAM goods above the threshold from 1 Jan 2026.
  • Who must register: EU importers above 50 t/yr of cement, steel, aluminium or fertilisers — and any importer of electricity or hydrogen, at any volume.
  • Three set-ups: EU importer as declarant, indirect customs representative (required for non-EU importers), or a delegated filer (declarant stays liable).
  • How: apply in the Registry AMM; EORI required; the NCA assesses within up to 120 days.
  • Deadline: the 31 March 2026 grace date has passed — apply now if you import above the threshold.
Check if you are in scopeHow the Registry works

Since 1 January 2026

Only an authorised CBAM declarant may import CBAM goods above the threshold.

This is the headline rule of the definitive period. If you import cement, iron & steel, aluminium or fertilisers above 50 tonnes a year, or any electricity or hydrogen, either you hold authorised-declarant status or an EU-established indirect customs representative holds it for you. DG TAXUD: 2025 simplifications. See the deadline tracker.

Who must register

You must become an authorised CBAM declarant (or use a representative who is) if you are an EU-established importer expecting to import more than 50 tonnes per year — cumulative net mass across cement, iron & steel, aluminium and fertilisers. The threshold is the 2025 Omnibus de minimis that replaced the old €150-per-consignment rule. DG TAXUD

There is one big exception: electricity and hydrogen have no de minimis. If you import either, you must register regardless of quantity. Not sure where you stand? Use the scope checker.

Three ways the role can sit

Who actually holds declarant status depends on where the importer is established and how it chooses to operate.

EU importer as declarant

If the importer is established in the EU, it is normally the authorised CBAM declarant itself, carrying the full obligations: declaration and surrender.

Indirect customs representative

An EU-established agent who can — and for a non-EU importer must — act as the authorised declarant, taking on the same obligations and penalties.

Delegated filer (Omnibus)

Under the 2025 Omnibus a declarant may delegate filing to an EU-established third party with an EORI — but the declarant stays legally liable.

If you are a customs broker or indirect representative wondering when you become the liable party, the short answer is: the moment you act as the authorised declarant for an importer, you assume the same obligations and penalties as the importer would. The compliance checklist walks the whole sequence. DG TAXUD: CBAM hub

How to apply, step by step

Authorisation is handled in the Authorisation Management Module (AMM) of the CBAM Registry, reached through the EU Customs Trader Portal.

  1. 1

    Confirm you need to register

    Above 50 t/yr of cement, steel, aluminium or fertilisers, or any electricity or hydrogen? Then you must hold declarant status or use a representative who does.

  2. 2

    Get an EORI and Registry access

    Secure a valid EORI number and access to the CBAM Registry via the EU Customs Trader Portal with your national customs login.

  3. 3

    Submit in the AMM

    In the Registry, open the AMM and submit your application: financial and operational information, and a description of your compliance procedures.

  4. 4

    Wait for the NCA decision

    The National Competent Authority of your Member State of establishment assesses the application within up to 120 days, ending in a grant or refusal.

The 31 March 2026 grace deadline has passed

Importers who applied before 31 March 2026 could keep importing while their application was pending. That date is now behind us. If you missed it and you import above the threshold, apply through the AMM as soon as you can and take advice: importing above the threshold without authorisation carries an enhanced 3x to 5x penalty (reduced if you exceeded the threshold by no more than 10%). Confirm your exact position with your National Competent Authority. DG TAXUD

Liability follows the declarant, not the filer

An indirect customs representative acting as declarant takes on the same obligations and penalties. Where filing is delegated under the Omnibus, the declarant remains legally responsible for the declaration and the surrender of certificates.

FAQ

People also ask

What is an authorised CBAM declarant?
An authorised CBAM declarant is the only entity allowed to import CBAM goods into the EU above the threshold from 1 January 2026. It is the party responsible for filing the annual CBAM declaration and surrendering CBAM certificates. The role is granted by a National Competent Authority through the Authorisation Management Module in the CBAM Registry.
Who has to register as a CBAM declarant?
Any EU-established importer expecting to import more than 50 tonnes per year (cumulative net mass) of cement, iron & steel, aluminium or fertilisers must become an authorised CBAM declarant. Any importer of electricity or hydrogen must register regardless of quantity, because there is no de minimis exemption for those two. Below 50 tonnes (excluding electricity and hydrogen), you are exempt.
What is the difference between the importer, an indirect customs representative and a delegated filer?
If the importer is EU-established, it is normally the authorised declarant itself. A non-EU importer must act through an EU-established indirect customs representative, who becomes the authorised declarant and takes on the same obligations and penalties. Under the 2025 Omnibus, an authorised declarant may also delegate the filing of declarations to an EU-established third party with an EORI — but the declarant remains legally liable.
How do I apply to become an authorised CBAM declarant?
You apply through the Authorisation Management Module (AMM) in the CBAM Registry, reached via the EU Customs Trader Portal. You need a valid EORI number, and you submit financial and operational information and a description of your compliance procedures. The National Competent Authority of your Member State of establishment assesses the application, with an assessment period of up to 120 days.
What was the 31 March 2026 deadline, and what if I missed it?
Importers who applied for authorisation before 31 March 2026 could keep importing CBAM goods while their application was pending, under a transitional grace mechanism. That date has now passed. If you did not apply in time and you import above the threshold, you should apply through the AMM as soon as possible and seek advice, because importing above the threshold without authorisation carries an enhanced 3x to 5x penalty. Confirm your exact position with your National Competent Authority.
Is the declarant liable even if someone else files?
Yes. The authorised CBAM declarant is the legally responsible party. An indirect customs representative who acts as declarant assumes the same obligations and penalties. Where filing is delegated to a third party under the Omnibus, the declarant still remains legally liable for the declaration and the surrender of certificates.

This is guidance, not legal advice

This is an independent guide to help you understand the CBAM declarant role, not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser. We cannot guarantee compliance, and you should be wary of anyone who says they can.

Sources

  1. [1]European Commission (DG TAXUD): CBAM hubretrieved 8 Jun 2026
  2. [2]European Commission (DG TAXUD): CBAM Registry and reportingretrieved 8 Jun 2026
  3. [3]DG TAXUD: Officially published — simplifications for CBAM (20 Oct 2025)retrieved 8 Jun 2026
  4. [4]DG TAXUD: CBAM successfully entered into force on 1 January 2026retrieved 8 Jun 2026
  5. [5]EUR-Lex: CBAM summary, Regulation (EU) 2023/956retrieved 8 Jun 2026
  6. [6]German DEHSt: CBAM definitive regime and authorisationretrieved 8 Jun 2026

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