CBAM: Get Ready for New Mandatory Procedures!

💡 Don’t forget to regularise your CBAM declarations as the end of the transitional period approaches!​

The status of "Authorised CBAM Declarant" can be requested from the end of March 2025.

An application must be submitted to the Customs Authorities of the importer’s country of establishment.

This application must include:

 Information about the company,

 Proof of tax compliance,

 Financial capacity,

 Evidence of no serious breaches of customs legislation,

 Annual estimates of import volumes.

​ According to the latest DGEC webinar dated 29/01/2025, companies less than two years old will also be required to provide a financial guarantee based on their projected import volumes to obtain this status. 

Starting 1 January 2026, importers of products subject to CBAM regulations must first obtain the status of "Authorised CBAM Declarant" and purchase the necessary certificates to clear these products within the European Union. Annual CBAM declarations must be submitted to the Customs Authorities, with the surrender of certificates corresponding to the emissions of imported products for the previous year.


Key Information:


Once granted the "Authorised CBAM Declarant" status, importers must, from 1 January 2026, acquire CBAM certificates entitling them to import products subject to the regulation. The DGEC has indicated that importers should be able to guarantee each quarter the availability of a sufficient stock of CBAM certificates covering at least 80% of emissions imported since the beginning of the calendar year.

Furthermore, importers will also need to submit an annual CBAM declaration (instead of the current quarterly declaration during the transitional phase), detailing all imports and the associated CO2 emissions. 


 The DGEC has indicated that importers may choose to use actual CO2 emission values or default values, with the latter incurring a surcharge.

 Annual declarations will need to be verified by an accredited auditor.  

 At the same time as submitting the annual CBAM declaration, the importer must surrender the corresponding number of certificates for the tonnes of CO2 emitted during the previous year. These certificates must have been purchased at the market price, which matches the price of EU-ETS quotas on the auction platform (the price is published weekly by the customs administration)

RMB remains at your full disposal for any assistance regarding the preparation of CBAM declarations and regularisation procedures.