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Who must submit a declaration?
As from 1 January 2026, imports exceeding 50 net tonnes per year may only be carried out by importers holding a CBAM authorisation. The application must be submitted in the country that issued the EORI number.
Who may access the Registry to apply for an authorisation?
- An importer declaring their own goods
- An importer whose goods are declared by an indirect customs representative, with two possible scenarios:
- If the customs representative does not offer a CBAM declaration service, the obligation remains with the importer. The importer may also appoint a third-party service provider to carry out the task.
- If the customs representative does offer this service, they may submit the CBAM declaration on the importer’s behalf.
- An indirect customs representative
Many importers do not declare their goods themselves and instead use a customs representative. If you are an importer and wish to delegate this task, you must coordinate with your customs representative. The representative must then hold a CBAM authorisation or apply for one.
Important: An exception applies to any importer not established in Europe. In such cases, the customs representative is obliged to submit the CBAM declaration and assumes the financial liability.
Which types of imports are excluded from the CBAM obligation?
- Imports for which the combined annual volume of CBAM-relevant CN codes is less than 50 net tonnes
- Imports originating from the following countries or territories:
- Switzerland, Iceland, Norway, Liechtenstein, Büsingen, Heligoland, Livigno, Ceuta and Melill
- Goods used for military operations
If, as a CBAM importer, you are uncertain whether you will exceed the 50 tonnes annual threshold, it is recommended to apply for a CBAM authorisation to avoid any potential sanctions.