Regulations •

CBAM registration: authorised declarant status, the CBAM Registry and the deadlines that matter

Since 1 January 2026, only an authorised CBAM declarant may import CBAM goods above the 50-tonne threshold. How the application in the CBAM Registry works, which transitional arrangement ends on 27 September 2026, when certificate sales start and what the 2026 CBAM declaration requires.

Author: myDPP Team

CBAM registration: authorised declarant status, the CBAM Registry and the deadlines that matter

On 1 January 2026 the EU’s carbon border adjustment mechanism changed character. Until the end of 2025, CBAM was a reporting duty: importers of iron and steel, aluminium, cement, fertilisers, hydrogen or electricity filed quarterly reports on quantities and embedded emissions and paid nothing. Since 1 January 2026, CBAM is an authorisation and payment regime. The import itself now depends on an administrative status — that of authorised CBAM declarant — and the emissions behind the goods are paid for, not merely reported.

That moves the bottleneck. The hard question is no longer how to fill in a quarterly form, but whether the company is entitled to import at all on the day the container arrives. And in autumn 2026 there is a hard cut-off: the transitional arrangement that let importers keep going while their application was still pending expires on 27 September 2026. This article walks through the authorisation procedure, the CBAM Registry, the certificate obligations that start in 2027, and the data foundation behind the CBAM declaration — including where that foundation overlaps with the digital product passport.

Key takeaways

  • No authorisation, no import. Since 1 January 2026, CBAM goods above the mass threshold may only be released for free circulation by an authorised CBAM declarant. The status is a precondition of import, not a downstream filing duty.
  • 50 tonnes per year is the new threshold. The omnibus simplification, Regulation (EU) 2025/2083, replaced the old EUR 150 per-consignment de minimis with a mass threshold of 50 tonnes net per calendar year per importer. Stay below it and authorisation, declaration and certificates all fall away — hydrogen and electricity are excluded from this threshold.
  • The transitional arrangement ends on 27 September 2026. Importers who applied by 31 March 2026 could keep importing while awaiting a decision, flagged with TARIC code Y238 — but no later than 27 September 2026.
  • The application is entirely electronic, submitted through the CBAM Registry’s authorisation management module in the member state of establishment. The national competent authority decides, consulting the Commission and other member states.
  • Processing takes months. Up to 120 calendar days for applications filed on or after 15 June 2025, up to 180 calendar days for earlier ones, each extendable by up to 30 days where documents have to be supplemented.
  • Certificates only go on sale on 1 February 2027, through a common central platform, at a price derived from EU ETS allowance auction prices.
  • The first CBAM declaration is due by 30 September 2027 and covers imports made in 2026. The omnibus regulation pushed this date back from the original plan.
  • myDPP is not customs software. It holds the product and supplier data that feed embedded-emissions figures, evidence and product passports — not the customs declaration itself.

Why authorisation, not reporting, is the 2026 bottleneck

During the transitional phase up to the end of 2025, the worst outcome of a late CBAM report was a fine. In the definitive regime, the worst outcome is that the goods do not enter the market. Customs checks at the import declaration whether a valid CBAM status exists for the commodity code; without it, release for free circulation is refused.

That shift hits one group particularly hard: companies that read CBAM as a sustainability topic rather than a customs topic. Where the 2024 and 2025 reporting duty was handled by a sustainability team, the authorisation application was often not classified as a precondition of day-to-day trading. It is exactly that.

The structure of the deadlines compounds the problem. A processing time of up to 120 calendar days means an application filed today is realistically decided towards the end of the year. The transitional arrangement for applications filed by 31 March 2026 expires on 27 September 2026. So a company that discovers in autumn 2026 that it will cross the threshold no longer has a bridge to carry it until a decision arrives — it has to stop importing, restructure, or stay below the threshold.

Who needs authorisation, and who does not

The duty attaches to three features at once: the goods, the quantity and the role.

The goods. In scope are the CBAM product groups in Annex I to Regulation (EU) 2023/956 — iron and steel, aluminium, cement, fertilisers, hydrogen and electricity — each defined by CN code, not by the product description in a quotation. The most common misjudgement concerns downstream articles: screws, profiles, tubes or steel and aluminium containers fall in scope through their commodity code even where the company does not think of itself as a steel importer. So the assessment always starts in the commodity codes of your own import lines.

The quantity. The mass threshold is 50 tonnes net per calendar year, aggregated across all CBAM goods of one importer. It is neither a per-consignment allowance nor a tax-free amount: cross it and the entire import volume becomes subject to the regime, not just the excess. Hydrogen and electricity are excluded from the threshold and remain in scope with no lower limit. The status must be in place before the threshold is crossed — not in the quarter in which it happens.

The role. The party authorised is the importer, meaning whoever lodges the customs declaration for release for free circulation in their own name, or — in the case of indirect representation — the indirect customs representative where they take on the role. A third-country supplier cannot assume the duty. If you import through a service provider, settle contractually who holds the status, because certificate purchases and the declaration hang off it.

Out of scope are imports below the threshold, goods in customs warehousing or inward processing as long as they do not enter free circulation, returned Union goods, and imports from countries integrated into the EU emissions trading system — Iceland, Liechtenstein, Norway and Switzerland.

The application: procedure, documents, processing time

Authorisation is a separate administrative procedure under Article 5 of the CBAM Regulation and has to be applied for explicitly. Registration in the transitional CBAM registry during 2024 and 2025 did not replace it, and it does not follow automatically from having filed CBAM reports. That is one reason many companies found themselves without a status in spring 2026 while believing they were registered.

The application is filed electronically in the CBAM Registry, in the authorisation management module, with the competent authority of the member state where the applicant is established. Access runs through the member states’ customs portals and presupposes an EORI number.

In substance, the application calls for:

  • Identification and place of establishment of the applicant, including the EORI number and details of the economic activity.
  • A declaration of reliability: no serious or repeated breaches of customs, tax, market abuse or CBAM rules in the last five years.
  • Evidence of financial and operational capacity, proportionate to the planned import volume — in practice annual accounts and, where required, a guarantee.
  • Estimated import volumes and types of goods for the current calendar year, broken down by CN code and country of origin.
  • Details of the representative, where the applicant acts through one.

The competent authority reviews the file, consults the Commission electronically and, where necessary, the authorities of other member states, and then decides. The time limit is up to 120 calendar days for applications filed on or after 15 June 2025 and up to 180 calendar days for earlier ones, extended by up to 30 calendar days where documents are requested. The decision lands in the registry inbox; on approval, the CBAM account is activated.

The practical consequence: processing time, not filing date, is the number to plan against. A company that wanted to start CBAM imports in the fourth quarter of 2026 should have applied in early summer. Anyone starting now is realistically planning for 2027.

Who decides, and where

Competence follows the place of establishment, not the place of import. A company established in Germany that imports through Rotterdam applies in Germany. Depending on the member state, the deciding body is the customs administration, the environment agency or the climate authority.

Germany is worth a note because its structure is unusual and a frequent source of failed attempts. The national technical authority is the German Emissions Trading Authority (DEHSt) at the Federal Environment Agency. Authorisation decisions themselves, however, have since 4 July 2025 been taken by KPMG Law Rechtsanwaltsgesellschaft mbH as a delegated body of the Federal Environment Agency, under DEHSt’s legal and technical supervision. Applications still run technically through the CBAM Registry and the customs portal, but the substantive counterpart is the delegated body — while DEHSt publishes guidance and interpretation. Answering a request for documents through the wrong channel costs processing time you cannot recover.

What the CBAM Registry holds

The CBAM Registry is not just an application portal. It is the account through which the whole definitive regime is run, and it brings three things together.

The status. Authorisation number, scope of the authorisation and the link to the EORI number. This record is checked electronically against customs systems, which is why a customs declaration fails without a valid entry.

The emissions data. Embedded emissions of the imported goods, broken down by installation, product and country of origin, including any carbon price already paid in a third country that can be set off. Operators in third countries can deposit their installation data in a dedicated area, so several importers can rely on the same verified values — practically the single most effective way to cut data-collection effort.

The certificate account. From February 2027: purchase, holdings, surrender and repurchase of CBAM certificates.

The annual declaration is also filed in the registry. Whatever goes in there has to be reproducible from your own data — including the question of which emissions value was reported by which supplier and when.

After authorisation: certificates from February 2027 and the 50% rule

For 2026 imports there is nothing to buy during 2026. Sales of CBAM certificates only begin on 1 February 2027, through a common central platform. The price is not negotiable: it derives from auction prices for EU emissions trading allowances and is published by the Commission. One certificate corresponds to one tonne of CO2 equivalent.

Two obligations follow from this.

Quarterly coverage. From 2027, an authorised CBAM declarant must hold, at the end of each quarter — 31 March, 30 June, 30 September and 31 December — certificates covering at least 50% of the embedded emissions of all goods imported since the start of the calendar year. This is a liquidity question, not only a filing question: heavy imports in the first half of the year tie up capital before the goods are sold.

Surrender with the declaration. The certificates matching the embedded emissions reported are surrendered with the annual CBAM declaration. Limited repurchase of surplus certificates is possible, but over-buying does not simply convert back into cash. Estimating the quantity without knowing your own emissions data is therefore expensive twice over.

The product carbon footprint is related here but not equivalent: CBAM requires installation-level embedded emissions under its own methodology, verified by accredited verifiers — not a life-cycle result under ISO 14067. Feeding both from the same data foundation saves collection effort; treating them as the same number does not work.

The 2026 CBAM declaration: due 30 September 2027

The first declaration of the definitive regime covers import year 2026 and must be filed in the CBAM Registry by 30 September 2027. The omnibus regulation moved this date back from the original plan to leave room for data collection and verification.

The declaration sets out imported quantities per type of goods, the associated embedded emissions, evidence of verification by an accredited verifier and, where claimed, the set-off of a carbon price paid in the country of origin. Where actual installation values are unavailable, default values may be used under the conditions of the regulation — they are deliberately conservative, so using actual values is usually cheaper.

The critical path is not the filing but the sourcing. A third-country supplier will not produce verified installation data on request in September 2027. The data requirement belongs in purchasing terms and supplier qualification, using the same mechanisms needed for EUDR and supply chain due diligence: named data fields, format, deadline, contact person, consequence for non-delivery.

What happens without authorisation

Three levels are worth separating.

In customs terms, release for free circulation is refused. The goods stand still, with all the follow-on costs: storage, demurrage, late delivery, possibly return shipment. This is the immediately most expensive consequence, and it hits sales rather than compliance.

In penalty terms, the regulation and its national implementation provide for fines keyed to the volume of uncovered emissions and set well above the certificate price; they can be increased where goods were imported without authorisation. Paying up later at market price is not an option you can elect.

In practical terms, a reliability record is created. A company logged as unreliable has a harder time with future authorisations, permits and customs simplifications. The link to other status questions in product law — such as the verified economic operator in the DPP registry — is legally separate, but not in how authorities read a company.

The data side: what the definitive regime demands of your data

The application itself can be handled with corporate paperwork. What comes afterwards is a data problem, and it has the same shape as the data problems in ESPR, PPWR and EUDR: values from the supply chain that must be versioned, dated and traceable to a source, because years later they will be defended in front of an authority.

Concretely, the definitive regime needs, per import line:

  • Commodity code and net mass per consignment, aggregated per calendar year — the basis for the threshold calculation and for the quantities in the declaration.
  • Installation attribution: which production installation in the third country made the goods. Without it, no actual emissions value is usable.
  • Embedded emissions per product, direct and, where covered, indirect, stating the method and the reference period.
  • Verification evidence from the accredited verifier, with date and scope.
  • Carbon price paid in the third country, with evidence, where a set-off is claimed.

The recurring mistake is keeping these values in spreadsheets and email attachments. They go stale silently: a supplier switches installation, an emissions value is corrected after the fact, a verification report expires. When the question arrives in 2029 about which value underpinned the 2026 declaration, the state as it then stood has to be reconstructible. Our article on DPP and PIM describes the same requirement for product data generally — CBAM is the case where it costs money first.

Five steps for the rest of 2026

1. Reconcile commodity codes against Annex I. Not the product range, but the CN codes actually declared over the last twelve months. Output: a list of CBAM lines with net masses.

2. Do the 50-tonne calculation for 2026 and 2027. Aggregated, not per consignment. If you sit just below, you need monitoring with an early warning, not a year-end review — the threshold gets crossed mid-year.

3. Check your status and, if it is missing, apply now. With the processing time of up to 120 calendar days in mind, and the transitional arrangement expiring on 27 September 2026. If the threshold will not be reached in 2026, still plan the application so the status is in place before the first crossing in 2027.

4. Put supplier data into contracts. Installation identification, embedded emissions, verification evidence, carbon price in the country of origin — with format and deadline. This belongs in framework agreements and purchase terms, not in an emailed request.

5. Plan 2027 liquidity. Certificate purchases from February 2027, 50% coverage at each quarter end, surrender with the declaration. The capital requirement arises before the goods are sold and belongs in pricing, not in hindsight.

Step four and the data behind it are where myDPP fits. It replaces neither customs software nor legal advice; it holds product, material and supplier data in one versioned place, so emissions values, evidence and product data share a single source — for CBAM, for the digital product passport and for the reporting duties alongside them. Our DPP implementation checklist describes what a practical start looks like.

Frequently asked questions

How do I apply for authorised CBAM declarant status?

Electronically, in the CBAM Registry’s authorisation management module, with the competent authority of the member state where you are established. You need an EORI number and access through the national customs portal. The application calls for details of establishment, a declaration of reliability, evidence of financial and operational capacity, and estimated import volumes by CN code.

How long does CBAM authorisation take?

Up to 120 calendar days for applications filed on or after 15 June 2025 and up to 180 calendar days for earlier ones, extendable by up to 30 calendar days where documents are requested. Plan against the maximum, not the average.

What does TARIC code Y238 mean?

It flags imports by a company whose application for authorised declarant status was filed by 31 March 2026 and not yet decided. It made importing possible without a completed status on a transitional basis — until 27 September 2026 at the latest.

Does CBAM apply below 50 tonnes?

No, with one exception. If your CBAM imports stay below 50 tonnes net in the calendar year, authorisation, declaration and certificates all fall away. Hydrogen and electricity are excluded from this threshold. The threshold is not an allowance: once crossed, the entire volume becomes subject to the regime.

When do I have to buy CBAM certificates?

Sales start on 1 February 2027. From 2027 you must hold certificates for at least 50% of the embedded emissions imported since the start of the year at the end of each quarter; surrender happens with the annual declaration.

When is the first CBAM declaration due?

For import year 2026, by 30 September 2027, filed in the CBAM Registry, with embedded emissions verified by an accredited verifier.

Does the digital product passport replace the CBAM declaration?

No. They are separate regimes with different audiences: CBAM addresses customs and climate authorities and settles emissions, while the DPP addresses market surveillance, buyers and consumers and describes the product. They do share data fields — material composition, origin, emissions values — which is why it makes sense to feed them from one source.

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