CBAM Regulation: authorised declarant status, registration and default values explained

The carbon border adjustment mechanism (CBAM) has been in its definitive regime since 1 January 2026. For an EU importer that changes the job from filing a quarterly spreadsheet to holding a status: authorised CBAM declarant status, a CBAM account number, and one annual declaration backed by verified emissions data.

This guide follows that workflow, and the single decision that drives the cost: default values or actual supplier data.

CBAM in force: the link to the EU emissions trading system, and what changed

CBAM is the border-side counterpart to the EU emissions trading system. As free allowances for EU installations are phased out, importers of the same goods are asked for a comparable carbon cost, so production does not simply move to a jurisdiction with a weaker carbon price. If emissions trading is new territory, start with the European carbon market guide or with ETS2.

What changed, and when:

• 1 October 2023: the transitional phase opens. Quarterly reports, no certificates, default values broadly accepted.
• 31 December 2025: the transitional phase ends. The Q4 2025 report was the last quarterly one.
• 1 January 2026: the definitive regime applies. Only authorised declarants may release covered goods for free circulation, a de minimis mass threshold takes small importers out of scope, and indirect emissions leave the scope for iron and steel, aluminium and hydrogen.
• 2027: the first annual declaration covers calendar year 2026, and certificate sales begin. The 2025 simplification package moved both dates, so confirm them against the Commission's CBAM pages before planning cash flow.

My reading of the shift: the burden did not arrive with the certificates, it arrived with declarant status. A weak emissions figure only makes an import expensive, a missing authorisation stops it.

Which goods and which importers are covered

Scope is decided by Combined Nomenclature code, not by sector description, the same discipline an EUDR scope check needs. Annex I of Regulation (EU) 2023/956 is the binding list, the table below is the orientation.

Two filters sit in front of that list. CBAM attaches to release for free circulation, so goods in transit or in a customs warehouse are not caught. And importers below the de minimis mass threshold, currently 50 tonnes of CBAM goods per year, fall out of the obligation.

Registering in the CBAM registry: declarant status and the account number

Authorised declarant status is not granted with the goods, it is applied for, and the application runs through your own member state rather than through Brussels. The chain has four links.

1. EORI number. Everything hangs off it. Established importers have one; if the importing entity is new, this is the first filing, with the national customs administration.
2. Identify the competent authority. Each member state names one for CBAM, and it is not always the customs authority. In Germany it is the German Emissions Trading Authority (DEHSt) at the Federal Environment Agency, reached through the customs portal.
3. Apply for authorised declarant status in the CBAM portal, the definitive-regime system that took over from the transitional registry used for the quarterly reports: legal entity and address, VAT and EORI, the CN codes you expect to import, a named CBAM contact, a declaration of no serious infringements of customs or tax rules, and evidence that you can cover the certificate obligation.
4. Receive the CBAM account number. The authority issues it on approval. Customs declarations for covered goods refer to it, and it is what makes the release for free circulation lawful.

Three things stall an application more often than the form does. The first is a mismatch between the member state that issued the EORI number and the one where the company is established for VAT, which sends the file to the wrong authority. The second is an unclear split between the importer and the indirect customs representative: only one of them holds the authorisation, and that choice decides who carries the declaration duty for every consignment afterwards. The third is financial evidence. Showing that you can cover the certificate obligation, including any guarantee or security deposit the authority asks for, is a finance task rather than a customs one, and it is usually the item still open when the authority comes back with questions.

In practice: an engineering firm with around 200 employees in western Germany imports steel sections a handful of times a year, has no customs department, and the application landed with the person who books the freight. The paperwork is not the hard part, the lead time is. Authorisation is a decision by an authority with a queue behind it, and a shipment cannot wait at the border for it.

The annual CBAM declaration: data, verification and certificate surrender

The quarterly report is gone. One declaration now covers a full calendar year of imports, and it is only accepted if the data behind it holds.

1. Collect per installation, not per invoice. For each CN code: quantity imported, embedded emissions per tonne or per MWh, the producing installation, the method used, precursors for complex goods, and any carbon price already paid at origin.
2. Have actual data verified. Accredited verifiers check whether the calculation follows the CBAM method, whether activity data and emission factors are complete, and whether the audit trail carries. Commission default values are the exception, they need no verification.
3. Deduct what is already priced. A carbon price genuinely paid at origin under a tax or a trading system is deductible, capped at the certificate price, and you need payment evidence at installation level.
4. Buy and surrender certificates. Certificates are bought through the registry across the year and surrendered against the declaration. The price tracks EU ETS allowances, so the carbon cost of an import is not fixed when the order is placed.

Default values or actual supplier data: how the choice plays out

CBAM's embedded emissions are narrower than a product carbon footprint. They track what the emissions trading system covers, essentially production emissions at the installation, plus consumed electricity for cement and fertilisers. Lifecycle factors overstate the figure and are not an accepted substitute. Where actual data is missing, Commission default values apply, and they are set deliberately high. The choice is a pricing decision, not a compliance one: defaults can be expensive, they are never wrong.

A first round of supplier requests tends to split three ways. Some suppliers do not answer, most often smaller producers with no monitoring in place. Some return a usable installation-level figure, typically those already inside a domestic monitoring or trading scheme. And some send a lifecycle or corporate-level number that CBAM cannot accept, which costs a second round to correct.

So send the request early enough that the second round still fits inside the year, and decide per supplier rather than per policy. For a low-volume flow the default value is cheaper than the chase. For a steel line that repeats every quarter, the gap between a good installation and a punitive benchmark funds the data work. The same figures feed Scope 3 Category 1 under ESRS E1.

Frequently asked questions about CBAM