Your Roadmap to Becoming an Authorised CBAM Declarant

The EU's Carbon Border Adjustment Mechanism is entering a crucial new phase. Starting March 28, 2025, businesses importing regulated goods like aluminium, steel, iron, cement, fertilisers, electricity, and hydrogen must apply for Authorised CBAM Declarant status to continue operations seamlessly in the EU.

This isn't just another checkbox in your compliance list—it's a significant hurdle that adds layers of administrative, financial, and risk assessment obligations. If you're not prepared, you could find yourself locked out of the EU market come January 1, 2026.

Let's break down what you need to know and do.

No Authorization = No Imports: Understanding the Stakes

CBAM's goal is to prevent carbon leakage—ensuring that emissions-intensive production doesn't simply shift to regions with weaker environmental regulations. By requiring importers to hold Authorised CBAM Declarant status, the EU is making sure that only verified entities can manage CBAM certificate purchases, emissions reporting, and compliance monitoring.

Without this status, you'll face import restrictions for covered goods. In other words, no authorization = no imports.

The Five-Step Authorization Journey: From Application to Approval

The application process has five key steps, outlined in Commission Implementing Regulation (EU) 2025/486. Here's what you need to do:

Electronic Application Submission: What You Must Provide

You'll need to apply electronically via the CBAM registry in the EU Member State where you're established. Your application must include:

• Company details (legal name, registered address)
• EORI number (Economic Operators Registration and Identification number)
• Estimated import volumes of CBAM-covered goods
• Proof of financial and operational capacity to comply with CBAM obligations

If you're not based in the EU, you'll need to submit your application through a representative authorized to act on your behalf within an EU Member State.

The 120-Day Review Window: What Happens During Assessment

Authorities will have up to 120 days (or 180 days for applications submitted before June 15, 2025) to review your submission.

If they need more details, you may get an extension of up to 30 additional days to provide the information. During this period, you can also adjust submitted information if necessary, as long as you provide justification.

Proving Financial & Operational Readiness: The Compliance Gauntlet

This is where things get serious. You'll need to demonstrate:

• Financial stability (no ongoing bankruptcy proceedings, ability to pay CBAM certificate costs)
• Legal compliance (no history of serious or repeated tax/customs infringements)
• Administrative capacity (sufficient internal controls to manage CBAM declarations)

To prove these qualities, you'll need:

• An administrative organization that can fulfill the estimated obligations for CBAM certificates
• Internal controls that can prevent, detect, and correct errors in CBAM declarations
• Systems to identify and prevent illegal or irregular transactions

You'll also need to establish key internal documents and processes, including:

• Standard Operating Procedures
• Mechanisms to calculate and determine CBAM liability
• Clearly defined roles and responsibilities for managing CBAM declarations, certificate procurement, reporting, and supplier engagement
• Internal controls to identify, manage, and mitigate incorrect, illegal, or irregular transactions

For new businesses or those deemed high-risk, additional guarantees may be required.

Approval: Your CBAM Account Number and Database Registration

If approved, you'll receive a CBAM account number and be registered in the CBAM database. If rejected, you have the right to appeal.

Maintaining Authorization Status: Continuous Compliance Requirements

Getting authorized isn't the end—it's the beginning. Authorised CBAM Declarants must ensure continuous compliance with CBAM rules. EU authorities may reassess your authorization status at any time, and non-compliance or major infringements can result in revocation.

Critical Dates You Cannot Miss

• March 28, 2025 – CBAM Authorised Declarant applications open
• June 15, 2025 – Early application deadline for 180-day review period
• January 1, 2026 – Only Authorised CBAM Declarants can import regulated goods

Rejection Scenarios & Recovery Options

If you're denied Authorised CBAM Declarant status, you have two options:

1. Appeal the decision and provide additional supporting documentation
2. Reapply with corrected or additional information

Businesses without authorization by January 1, 2026, will be unable to import CBAM-covered goods into the EU. That's not a risk worth taking.

Pre-Application Preparation Checklist

To ensure a smooth application process, take these steps before March 28:

• Gather required documentation – Make sure company details, financial records, and emissions data are readily available
• Assess compliance risk – Conduct an internal review to confirm financial stability and legal compliance history
• Plan for potential guarantees – High-risk applicants may need to provide additional financial assurances
• Engage with suppliers – Ensure upstream suppliers are providing accurate emissions data to avoid reporting risks
• Monitor CBAM price dynamics – Since CBAM certificate costs are linked to the EU Emissions Trading System (ETS), closely track ETS price trends

The Bottom Line: Act Now to Secure EU Market Access

The introduction of Authorised CBAM Declarant status marks a major shift in how businesses must manage carbon compliance. Companies that fail to act now risk losing access to EU markets when CBAM enforcement begins in 2026.

By preparing applications early, ensuring internal compliance, and securing the necessary financial and administrative resources, you can protect your supply chains, mitigate risk, and stay competitive in a low-carbon economy.

At EnCarbonSys, we help businesses navigate the entire CBAM compliance journey—from application preparation to ongoing reporting and verification support.