How to Apply as an Authorised CBAM Declarant: A Practical Guide for EU Importers 

Who actually needs the authorisation?

• EU-established importers that act as the customs declarant for CBAM goods.
• Indirect customs representatives (e.g. freight forwarders) if they lodge the customs declaration in their own name.

There is no tonnage or value exemption for the ACD status. Even occasional, low-volume importers must apply if they intend to bring CBAM goods into the Union after 1 January 2026.

Eligibility check-list

Before you hit “apply”, make sure you can tick all six boxes: 

Requirement	Proof you will need
EU establishment	Valid EORI number registered in an EU Member State
Financial capacity	Latest financial statements or bank guarantee if requested
Operational capacity	CBAM compliance procedures & responsible person on record
Good conduct	No serious/repeated customs, tax, market-abuse offences in the last 5 years
Registry access	EU Customs Trader Portal login (same as ICS2 & POSEIDON)
Security (if requested)	Bank or insurance bond covering your projected CBAM certificate needs

Application timeline & important dates 

Milestone	What it means	Practical advice
28 Mar 2025	EU CBAM Registry opens for authorisation requests	Portal: Customs Trader Portal → CBAM > Authorisation Management Module (AMM)
15 Jun 2025	End of the “early batch” window	Applications submitted before this date can take up to 180 days to be processed.
After 15 Jun 2025	Standard processing time applies	Decisions must arrive within 120 days.*
31 Aug 2025	Recommended latest safe filing date	Gives the authority the full 120 days before 1 Jan 2026.
1 Jan 2026	Start of the definitive CBAM phase	Only ACDs may import CBAM goods.

* If the authority asks for additional information you will have 30 days to respond; the clock pauses in the meantime. 

Step-by-step: Filing your application 

1. Log in to the Customs Trader Portal and open the CBAM Registry. 

      2. Go to Authorisation Management Module → New authorisation.       3. Fill in the on-screen form and upload supporting documents (financials, compliance procedure, contact details, any requested security).  4. Submit. Your National Competent Authority (NCA) reviews the file and electronically consults the Commission and other NCAs if needed. 5. Track the status under “My authorisations”. The final decision arrives in the portal inbox. 6. If approved, your CBAM account is activated automatically—no extra action required.

After approval: ongoing obligations

• Quarterly – keep at least  50 %P of the CBAM certificates you will need for the current year in your account.
• Annually – submit the CBAM declaration and surrender the exact number of certificates by 31 May (first declaration due in 2027 for calendar year 2026 imports).
• Records – retain all import and emissions data for five years.
• Change management – tell your NCA within 30 days if your company merges, changes legal form, or ceases CBAM imports.

Frequently asked questions 

Question	Answer
Is there a deadline for applying?	No fixed cut-off, but you must be authorised before the first arrival of CBAM goods from 1 Jan 2026 onward. Apply by 31 Aug 2025 to be safe.
Do I need to reconfirm the application after submission?	No. The authority will come back to you only if it needs extra information.
I import < 50 t a year—do I still need to declare?	No. Following the adoption of the Omnibus package, importers bringing in less than 50 tonnes per year are exempt from reporting requirements.
What if I expected to stay below 50 t but later exceed it?	Because the threshold is not in the law, you should already have the ACD status. Importing CBAM goods without it is a breach. Apply immediately and include all earlier 2026 imports in your first annual CBAM report. Penalties are set by each Member State.
Can I register retroactively?	The regulations do not provide for retroactive authorisation. Applications are only valid from the approval date forward.
Our goods enter through multiple EU countries—how do we report?	File one consolidated annual CBAM declaration in the Member State where your company is established, regardless of where customs clearance took place.
Is direct customs representation allowed?	Yes, indirect representatives may act as the declarant. If you use direct representation, your company (the importer of record) must hold the ACD status.

Practical tips for a smooth application

• Start early: internal due-diligence (compliance check, financial capacity, emissions data readiness) often takes longer than filling in the form, especially when needing to provide sufficient proof for sufficient financial capacity.
• Automate data capture: align invoicing systems and customs brokers on CBAM codes early; mistakes in HS codes can void declarations later. (Mistakes or inconsistencies in HS codes between customs declarations and CBAM filings can invalidate your CBAM declaration, leading to penalties or re-submissions.)
• Budget for certificates: It’s important to have a clear picture of your potential CBAM certificate needs and carbon tax exposure for 2026—our team can help you forecast and prepare accordingly.
• Audit trail: keep a single, auditable spreadsheet or database linking every import entry number to its embedded-emission figure; this makes the annual declaration a two-hour job instead of two weeks.

Resources  

• Regulation (EU) 2023/956 establishing the Carbon Border Adjustment Mechanism (CBAM) 

• Implementing Regulation (EU) 2025/486 — application process & registry rules 

• European Commission, CBAM Registry User Manual (April 2025) 

• DG TAXUD, Default values for the transitional period (Annex 2 tables) 

• CREA (2024), China Steel Brief 

• IEEFA & JMK Research (2023), Steel Decarbonisation in India 

• EBRD (2024), Low-Carbon Pathway for the Steel Sector in Türkiye 

• IEA (2024), Ammonia Technology Roadmap 

• MDPI (2024), Decarbonising China’s Primary Aluminium Industry 

• Energy Cities (2024), 50 Shades of Hydrogen