The authorised CBAM declarant is the EU established importer of record, the only party permitted to bring CBAM goods into the Union from 1 January 2026, granted status by the competent authority of its Member State of establishment through the Authorisation Management Module and the CBAM registry, with the initial application window closed 31 March 2026.
The declarant is the EU importer of record
Only a party holding authorised CBAM declarant status may import CBAM goods into the Union from 2026, under Regulation (EU) 2023/956, Article 5. This status attaches to the EU established importer of record, not to the overseas producer. The definitive regime, live since 1 January 2026, converts transitional quarterly reporting into a financial obligation, so covered goods may cross the EU customs border only through an authorised declarant. GreenSutra supports this transition as a consultant through its CBAM advisory services, calculating embedded emissions and preparing the declaration while an accredited verifier confirms the data.
How authorisation and registration work
Applications run through the Authorisation Management Module, which has accepted submissions since 31 March 2025, and go to the competent authority of the Member State of establishment, independently of where goods physically enter. That authority runs a consultation process before granting status. For the definitive period the Commission operates a central CBAM registry, through which authorised declarants file the single annual declaration and buy and surrender certificates. The registry also holds the account through which certificates are purchased from 1 February 2027 and surrendered by 30 September each year.
| Party | Role | Registry action |
|---|---|---|
| Authorised CBAM declarant (EU importer) | Imports covered goods, files declaration | Applies via Authorisation Management Module, files annual declaration in the CBAM registry |
| Non-EU operator (producer) | Runs the installation, monitors emissions | Supplies monitored emissions data to the declarant |
| Accredited verifier | Independent third party | Approves declared embedded emissions |
Timing and shared emissions data
The application window for uninterrupted importing from 1 January 2026 closed on 31 March 2026, and applicants whose requests were pending may continue importing provisionally. Once authorised, the declarant depends on the exporting installation to supply monitored, source level emissions and activity data, which an independent accredited verifier then approves. Goods brought in by a party that is not an authorised declarant attract a higher penalty, set at three to five times the standard rate, so registration readiness rests on a reliable data chain from the overseas producer. In GreenSutra engagements, importers frequently find that authorisation readiness depends less on the paperwork than on securing dependable emissions data from overseas suppliers. Further practical detail sits in the CBAM compliance guide.
Sources: Regulation (EU) 2023/956 · Regulation (EU) 2025/2083 (Omnibus I) · European Commission CBAM