Authorised CBAM declarant: who needs it, how to apply and how long it takes

If your company is established in the EU and imports more than 50 tonnes a year of steel, aluminium, fertilisers or cement, added together, you need the status of authorised CBAM declarant before you go past those 50 t: without it, customs will not let you import. You apply in the EU CBAM registry, the authority of your Member State decides (in Spain, MITECO), and the decision can take 120 days, up to 180 if it asks for more information. The 31 March 2026 transition is over, so a new application needs months of margin, or you import meanwhile through a customs representative that is already authorised.

Check what applies to you

Who needs the status

• An importer established in the EU that exceeds 50 t a year. The net mass of all CN codes of iron and steel, aluminium, fertilisers and cement is added together (Article 2a of Regulation (EU) 2023/956). How it adds up is in the 50-tonne threshold guide.
• An importer that expects to exceed them. The regulation asks you to apply when you expect to cross the threshold, not once you have (Article 5(1)).
• An indirect customs representative importing CBAM goods for others, even if its client stays under 50 t (Article 5(1a)).
• Not needed by an importer that stays at or below 50 t. In Spain it declares code Y137 in the customs declaration: importer not authorised, under 50 t (AEAT note NI 02/2026).

How to apply

1. An EU Login account with two-step verification, for each person who will use the registry.
2. The application in the CBAM registry, in the authorised declarant module. The competent authority of the Member State where the company is established decides; in Spain, MITECO, whose Climate Change Office has a guide (October 2025) and a video tutorial.
3. The data and documents of Article 5(5): they are in the checklist above. The slowest are usually the tax authority’s certificate of no outstanding tax debts and, if the authority asks, the accounts for the last three years.
4. The criteria the authority checks (Article 17(2)): no serious or repeated infringements of customs, tax, market abuse or CBAM rules in five years, financial and operational capacity, establishment in that Member State and an EORI number.

The status is valid across the EU and comes with a CBAM account number, which goes on every import.

How long it takes

• 120 calendar days to decide, under Implementing Regulation (EU) 2025/486.
• Up to 180 days if the authority asks for more information. You have up to 30 days to answer each request.
• The transition no longer helps a new application. Whoever applied by 31 March 2026 may keep importing provisionally until the decision (Article 17(7a)). Whoever applies now cannot go past 50 t until it is granted.

In practice: if you will exceed 50 t this year or next, apply at least four months before the order that would take you over (inferred from those deadlines).

When a guarantee is required

If your company was not established throughout the two financial years before the year of the application, the authority requires a guarantee to show financial capacity (Article 17(5) and (6)). Its amount is the value of the CBAM certificates you would have to surrender for the imports you estimate in the application, after the free-allocation adjustment, and it is usually a first-demand bank guarantee. MITECO says it will publish a specific document on the guarantee regime.

Importing through a representative

If your customs agent acts as an indirect customs representative, is an authorised declarant and agrees to act as one, it takes on the CBAM obligations for what it imports for you: the declaration and the certificates (Article 5(1a) and (2a)). It is the way out for an importer starting while it waits for its own status, and for an importer not established in the EU, which can only import CBAM goods this way (Article 5(2)).

If you go this way, agree in writing who pays the certificates, who asks each supplier for its emissions data, and by when. Someone still has to get the data: the letter to your Chinese supplier works the same.

Importing without it

• Customs will not release the goods to a person who is not an authorised declarant, unless it is exempt under the threshold (Article 25(1)).
• If you exceed 50 t without the status, the penalty is three to five times the EU ETS excess emissions penalty (€100 per tonne of CO₂, indexed to inflation) for each certificate not surrendered, calculated on all the emissions of what you imported in the year, not only the excess (Article 26(2) and (2a)).
• It can be reduced if the excess is no more than 10 % of the threshold, but never below the basic penalty.
• The Commission watches: it cross-checks customs data and flags importers above 90 % of the threshold to the authorities (Article 25a).

Once you are authorised

• Every import carries your CBAM account number; in Spain, with code Y128 in the customs declaration.
• 1 February 2027: certificates go on sale.
• From 2027, at the end of each quarter you must hold certificates for 50 % of the year’s emissions (quarterly holding guide).
• 30 September 2027: declaration of 2026 imports and surrender of certificates. With your supplier’s verified figure you pay less than at the default value (CBAM cost per tonne).

HeavyDeals adds up the CBAM tonnes you import in the year from the purchase order and warns you before an order takes you close to the threshold, so the authorisation arrives in time. And with your Chinese suppliers we prepare the verified figure that lowers the bill (CBAM at HeavyDeals).

Every figure and rule was checked against the sources above, on the date shown next to each; last review of this guide: 27 October 2026. The examples use illustrative figures, not today’s quotes. This is not legal or tax advice. Written with the help of AI and reviewed by the HeavyDeals team.