How does an importer in the European Union (EU) apply to become an authorised Carbon Border Adjustment Mechanism (CBAM) declarant, and what happens if the importer is outside the EU?

The importer applies online in the CBAM Registry to the authority of the EU country where it is established, before it imports. An importer outside the EU cannot apply for itself. An indirect customs representative in the EU takes the status for it. The authority grants it if the importer clears the criteria.

What the status is, in plain words

An authorised Carbon Border Adjustment Mechanism (CBAM) declarant is the one party allowed to bring CBAM goods into the European Union (EU). Regulation (EU) 2023/956 (the CBAM Regulation) says goods shall be imported only by an authorised declarant. Think of a gate that opens only for a named driver with a licence. The application is how that driver gets the licence.

Who applies

• An importer established in an EU country shall apply before it imports goods into the EU.
• An importer that is not established in an EU country does not apply for itself. The indirect customs representative shall obtain the status. A representative acts as declarant where an importer appoints it under the Union Customs Code and it agrees to act as declarant.
• An importer of steel, aluminium, cement or fertiliser that brings in 50 tonnes or less a year in total is exempt. Hydrogen and electricity have no such exemption. An importer that expects to go above 50 tonnes shall apply before it does.

The steps

1. Get an Economic Operators Registration and Identification (EORI) number. One of the criteria is that the applicant has been assigned one.
2. Find the authority for your country. The Commission publishes a list of national competent authorities for CBAM.
3. Log in to the CBAM Registry with an EU Login account that has two-factor authentication set up, and open the Authorisation Management Module. The Commission's page urges importers and representatives to apply there.
4. Fill in the application. The Commission's training video names three tabs: Stakeholders details, Activity details, and Financial and operational details.
5. The application shall include: name, address and contact details, the EORI number, the main economic activity in the EU, a certification from the tax authority that no recovery order for national tax debts is outstanding, a declaration of honour on infringements in the five years before, information that shows its financial and operational capacity (the authority may ask for supporting documents such as accounts), and the estimated imports by type of goods and EU country of import, for this year and the next.
6. Add the Authorised Economic Operator (AEO) certificate number if you hold one, and the names of any people you act for.
7. Answer any request from the authority. The Registry lets you give extra information, adjust or withdraw the application. The applicant may withdraw at any time.
8. Receive the decision. A grant is recorded in the Registry with your CBAM account number and any guarantee. A refusal gives reasons and says how to appeal.

The criteria and the guarantee

The authority shall grant the status if four things hold. The applicant has no serious or repeated infringements of customs, tax or market abuse rules, or of the CBAM rules, and no record of serious criminal offences in the five years before. It shows financial and operational capacity. It is established in the country where it applies. It has an EORI number. The status is then recognised in all EU countries.

The authority shall require a guarantee if the applicant was not established throughout the two financial years before the year of application. Think of the deposit a landlord asks from a tenant with no rental history. The amount is the value of the certificates the applicant would have to surrender for the imports it estimated in its application, adjusted for free allocation. It is a bank guarantee payable at first demand, or an equivalent form. It is released immediately after 30 September of the second year in which the declarant has surrendered certificates.

Timing and what the Regulation leaves open

• The authority may consult other authorities or the Commission through the Registry before it grants. That consultation shall not exceed 15 calendar days.
• An importer or representative that applied by 31 March 2026 may provisionally continue to import until the authority decides. If it is then refused, the authority has one month to set the embedded emissions of goods imported since 1 January 2026, using default values and any other relevant information. Those figures are used to work out penalties.
• The Regulation leaves processing deadlines to later implementing rules, so there is no fixed time to quote. Ask the authority.

What an Indian exporter does with this

You do not apply. Ask your EU buyer for its CBAM account number, or the name of the representative who will act for it, before the first order ships. The CBAM account number is the Commission's identifier, assigned when the grant is made.

Three examples, same rule, different outcome

• Example A: a Lyon trading company founded in 2019 expects 300 tonnes of steel in 2027 and applies in 2027 to the French authority in the Registry. Established throughout the two prior financial years (2025 and 2026, taking financial years as calendar years), so no guarantee under that rule.
• Example B: a Hamburg start-up founded in March 2026 expects 120 tonnes of aluminium in 2027. It applies in 2027 to the German authority. It was not established throughout 2025 and 2026, so a guarantee shall be required, sized on its own estimated imports.
• Example C: an exporter in Pune sells on delivered duty paid (DDP) terms to a customer in Poland, so the Pune company is the importer. It is not established in an EU country, so an EU indirect customs representative it appoints shall obtain the status and act as declarant if it agrees.

These companies and tonnages are examples. The two-year test reads the financial years of the applicant, which may not be calendar years. This is our reading of the two-year test, so check with the national authority.

What Senseible does here

Senseible reads fuel invoices and electricity bills into monthly records. It does not apply for declarant status, register declarants or file CBAM declarations. Your EU buyer or its representative does that.

• What is an authorised CBAM declarant?
• Check your EU buyer is authorised
• Which EU authority handles your buyer
• Selling DDP: can your company be the declarant?
• CBAM authorised declarant guide

Sources: Regulation (EU) 2023/956, consolidated, Articles 2a, 4, 5, 16 and 17, European Commission, CBAM Registry page (Authorisation Management Module), European Commission, list of national competent authorities for CBAM (26 June 2026)

Last reviewed 2026-11-07. Facts are from the consolidated Regulation dated 20 October 2025 and the Commission Registry page. Re-check for later amendments and for the implementing acts on processing deadlines.