EU CBAM Authorised Declarant Status Application Guidance

By Ahmed Medhat · Published11 April 2026 · Updated 3 September 2026

EU CBAM Authorised Declarant Status Application Guidance

The Exporter’s Complete Guide to Securing Your Buyer's Legal Compliance

The transition from the initial reporting phase of the Carbon Border Adjustment Mechanism (CBAM) to its definitive phase on January 1, 2026, brings a strict new requirement to the European border. From this date forward, any EU-based entity importing in-scope CBAM goods above the 50-tonne annual threshold of Article 2a (which does not apply to electricity or hydrogen) must hold the legal status of an "Authorised CBAM Declarant".

While it is your European buyer (the importer) who formally applies for this status, the embedded emissions they declare for your goods come from the data your installation provides, or from default values where it provides none.

---

1. What is an Authorised CBAM Declarant?

Above the Article 2a threshold, CBAM goods are imported only by an authorised CBAM declarant (Regulation (EU) 2023/956, Article 4). The importer, or an indirect customs representative, applies to the competent authority of the Member State where it is established, through the CBAM registry (Article 5).

The status is granted where the applicant meets the criteria in Article 17(2):

• no serious infringement or repeated infringements of customs legislation, taxation rules, market abuse rules or the CBAM rules;
• the financial and operational capacity to fulfil its obligations under the regulation;
• establishment in the Member State where the application is submitted;
• an EORI number.

The declarant then submits a CBAM declaration each year, by 30 September, for the first time in 2027 for 2026 (Article 6(1)), and surrenders CBAM certificates priced by the Commission from EU ETS auction clearing prices — a quarterly average for goods imported in 2026 (IR (EU) 2025/2548, Art. 1(1)), a weekly average from 2027 (Regulation (EU) 2023/956, Article 21(1)).

Without this authorisation, an importer above the threshold cannot import these goods.

---

2. The Exporter's Dilemma: Why Your Buyers Rely on You

Your EU buyers carry the CBAM obligation, and the penalties for not meeting it (Regulation (EU) 2023/956, Article 26). As a non-EU producer supplying in-scope goods, your facility is the origin of the embedded emissions. Your installation holds the data needed to determine its actual emissions.

If your buyer has no verified actual data from you, or the data is inaccurate, two things follow:

• The default value applies: Default values are not installation estimates. Annex IV, point 4.1 of Regulation (EU) 2023/956 sets them at the average emission intensity of the exporting country for the good, increased by a mark-up, with a fallback to the average of the 10 highest-intensity exporting countries where country data is not reliable. The EU applies a 10% markup to default values in 2026 for cement, iron and steel, aluminium and hydrogen, rising to 20% in 2027 and 30% from 2028 onwards; fertilisers carry 1% throughout (Implementing Regulation (EU) 2026/1740, Annex I).
• The declaration can be reviewed: The competent authority may review a CBAM declaration and correct the number of certificates to be surrendered (Regulation (EU) 2023/956, Article 19).

---

3. The Data Your Buyer Needs for Actual Values

If your buyer is to declare actual emissions for your goods, it needs the following from you. Where it does not, default values remain lawful (Article 7(2)).

A. The Installation

An installation is "a stationary technical unit where a production process is carried out" (Regulation (EU) 2023/956, Article 3(30)). The data is per installation, not per company, country or sector average.

B. Activity Data and Emissions

Each figure needs a unit, a period and a source a verifier can check. The data covers:

• Production Volumes: Measured in tonnes per goods type and specific CN code for the full annual reporting period.
• Fuel Consumption: The exact type, quantity, net calorific value, and carbon content per fuel stream used on-site.
• Process Emissions: Emissions originating directly from chemical reactions during manufacturing.
• Precursors: If you use relevant precursors (e.g., pig iron or direct reduced iron to make steel), their embedded emissions are counted in your goods' embedded emissions (Annex IV).

C. A Monitoring Methodology

Actual emissions are determined under the monitoring rules of Implementing Regulation (EU) 2025/2547 and verified under Implementing Regulation (EU) 2025/2546.

D. Free Allocation and Carbon Price Adjustments

Two things you provide change what your buyer's final CBAM certificate bill is calculated on:

• Production route and precursor data: the production route and any verified precursor values you provide set which CBAM benchmark is applied to your buyer's free allocation adjustment (IR (EU) 2025/2620, Annex).
• Local Carbon Pricing: Where actual emissions are used and a carbon price (tax or ETS) has been effectively paid in your country for those emissions, your buyer needs documentary evidence of it (Article 9(2)). The buyer can then claim a reduction in the number of CBAM certificates to be surrendered (Regulation (EU) 2023/956, Article 9(1)).

---

4. Preparing for Verification

From 2026, the use of actual emissions values under CBAM is conditional on verification by an accredited verifier (Article 8(1)).

Two steps help:

1. Keep one data set: Enter production data once and share the same data set with every buyer, so each receives the same figures.
2. Consider a pre-verification: A pre-verification by an independent third party, which the regulation does not require, can highlight gaps and non-conformances in your methodology before your 2026 data is verified.

Preparing your installation's data now means your buyers have verified actual values to declare for your goods.