From 1 April 2026, a key milestone in the Carbon Border Adjustment Mechanism (CBAM) implementation will take effect. Companies importing CBAM-covered goods above 50 tonnes per year must now comply with stricter requirements regarding their authorized declarant status.
CBAM Declarant Status: New Requirements Explained
As of this date, companies that have not submitted an application for authorized CBAM declarant status before 31 March 2026 will no longer be allowed to clear their goods through customs.
Three situations may arise for importers subject to CBAM regulation:
Application submitted and approved: Customs clearance can proceed normally.
Application submitted before 31 March but not yet approved: Customs clearance remains possible.
No application submitted by 1 April 2026: The importer must submit an application and wait for approval before being able to clear goods.
This regulatory shift marks the end of the transitional tolerance period and reinforces the EU’s objective to ensure full compliance with CBAM obligations ahead of the definitive phase.
How RM Boulanger can support your company with CBAM obligations?
RM Boulanger supports companies at every stage of their CBAM compliance process, helping them anticipate regulatory changes and ensure full alignment with European requirements.
Our experts can assist you with:
Assessing whether CBAM applies to your products
Estimating CO₂ emissions to anticipate future costs linked to certificate purchases in 2027 for 2026 imports
