CBAM entered its definitive phase on 1 January 2026. From that date, importing CBAM-covered goods above the de minimis threshold requires not just a customs declaration but an active authorised declarant status. Without it, you cannot legally import steel, aluminium, cement, fertilisers, electricity, or hydrogen into the EU in commercial quantities.
Who must register as an authorised declarant
The obligation falls on the person lodging the customs import declaration, not necessarily on the beneficial owner of the goods. In practice, this means:
- EU-established importers who act as declarant in their own name must register individually.
- EU-established customs brokers or agents who lodge declarations on behalf of clients as indirect representatives become the declarant of record and must register.
- Non-EU businesses cannot register. If your company is established outside the EU, you need an EU-established indirect customs representative who is themselves an authorised declarant.
An important practical consequence: if your European supply chain runs through a customs broker who files declarations on your behalf as indirect representative, confirm that broker is registered as an authorised CBAM declarant. If they are not, your imports are non-compliant.
The registration process
Registration is done through the CBAM Registry, which is part of the EU Customs Single Window. You access it with your national customs identity credentials. In the Netherlands, this is your Douane portal login.
What you need before you start
- A valid EORI number. If you do not have one, apply through the national customs authority first.
- Your legal entity details: registered name, address, VAT number, legal form.
- An overview of the CBAM goods you intend to import, including CN codes and estimated annual volumes.
- Contact details for the person responsible for CBAM compliance in your organisation.
Review by the competent national authority
After submission, the competent national authority (in the Netherlands: Dutch Customs; in Belgium: the FOD Financien customs division) reviews your application. They assess whether you are an established, legitimate importer and whether your EORI number is in good standing. The review period is typically a few weeks, though in practice it can take longer during peak periods.
Article 17, Regulation (EU) 2023/956 (CBAM Regulation): authorised declarant status is granted by the competent national authority of the member state where the applicant is established. The authority may refuse registration if the applicant has a history of customs infringements or does not meet the financial solvency requirements.
Grounds for refusal
The competent authority can refuse your application if:
- You have serious or repeated customs, tax, or regulatory infringements on record.
- Your EORI number is inactive or suspended.
- You cannot demonstrate financial solvency, particularly if you are importing large volumes and the CBAM certificate obligation is substantial.
- Your application contains inaccurate or incomplete information.
Maintaining your authorised declarant status
Registration is not a one-time step. You must keep your details in the CBAM Registry current. If your company name, address, or responsible contact changes, update the registry. If your import volumes change significantly, the competent authority may request an updated assessment.
Authorised declarant status can be suspended or revoked if you fail to submit an annual CBAM declaration by the 30 September deadline, fail to surrender the required number of certificates, or accumulate customs infringements after registration.
Delegation to a customs representative
You can delegate CBAM declaration responsibilities to a third party (a customs consultant or broker) acting as your direct representative. In this case, you remain the authorised declarant and the legal responsibility stays with you. The representative acts in your name and on your behalf.
This differs from indirect representation, where the representative becomes the declarant of record and takes on the CBAM obligations themselves. Make sure you and your broker are aligned on which arrangement applies, because the compliance exposure differs significantly.
Direct representation: you are the declarant, broker files in your name. Indirect representation: the broker is the declarant and holds the CBAM obligation. Clarify this before your first shipment.
Timeline: when to register
Register before your first CBAM import in a calendar year, not after. The CBAM Registry does not have an emergency lane. If you are already importing CBAM goods and have not yet registered, get this done immediately. Imports made without valid authorised declarant status are non-compliant and you risk penalties that compound with each month you continue importing.