Becoming an authorised CBAM declarant

Without authorised CBAM declarant status, companies above the 50-tonne threshold may no longer import CBAM goods into the EU. The competent authority of the Member State where the importer is established decides – in Germany the German Emissions Trading Authority (DEHSt) at the German Environment Agency.

At a glance

Required for importers above 50 t of CBAM goods per calendar year – for electricity and hydrogen from the first import.
Indirect customs representatives need authorisation regardless of quantity.
Application in the CBAM registry; the authority has 120 days, longer if it requests more information.
First CBAM declaration for 2026 by 30 September 2027.

Who needs the authorisation?

Anyone who imports CBAM goods and exceeds the 50-tonne threshold in the calendar year must be an authorised CBAM declarant. There is no threshold for electricity and hydrogen. Anyone declaring CBAM goods as an indirect customs representative needs the authorisation regardless of quantity.

Importers not established in the EU cannot become CBAM declarants themselves. An authorised indirect customs representative must handle the import for them – no mass threshold applies to the representative either.

Application and processing time

The application is filed electronically in the CBAM registry. The authority has 120 days to decide (Art. 4 Implementing Regulation (EU) 2025/486); if it requests more information, the period is extended. Anyone who had applied by 31 March 2026 could provisionally continue importing until the decision. Anyone approaching the threshold later should apply as soon as it is foreseeable that 50 t will be reached.

Obligations after authorisation

The CBAM declaration for imports in 2026 must be submitted by 30 September 2027; the certificates must also be surrendered by then. Certificates are sold from 1 February 2027 on the common central platform. From 2027, at the end of each quarter at least 50% of the embedded emissions imported since the start of the year must be covered by certificates.

annual CBAM declaration with quantities, embedded emissions and producers' installations
purchase and surrender of CBAM certificates
obtain suppliers' emission data – otherwise default values with a mark-up apply
actual emissions only with confirmation from an accredited verifier

How CBAMfix helps

In the CBAM Declarant plan, CBAMfix manages suppliers and installations, requests emission data via a supplier portal (English and German; only verified values go into the declaration), calculates embedded emissions and certificates with the official default values and benchmarks, and prepares the data for the annual declaration.

Frequently asked questions

What happens if I import more than 50 tonnes without authorisation?

Anyone who exceeds the 50-tonne threshold without authorisation faces a penalty of 3 to 5 times the EU ETS excess emissions penalty (EUR 100 per tonne, inflation-indexed) per certificate not surrendered; a milder rule applies up to 55 t.

Can my forwarder take over the authorisation for me?

Only if it acts as indirect customs representative and is itself authorised. For importers established in the EU, the indirect representative can decline the CBAM obligations; they then remain with the importer. With direct representation the obligations lie with the importer anyway.

When do I have to submit the first CBAM declaration?

For imports in 2026 by 30 September 2027, then every year by 30 September for the previous year.

Stay on top of the 50-tonne threshold

CBAMfix reads your import documents, checks every CN code against Annex I, keeps count and warns you in time before the authorisation deadline.

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