CBAM Declarant Authorisation for EU Importers
Quick answer
EU importers of goods subject to the Carbon Border Adjustment Mechanism (CBAM) must obtain authorisation as CBAM declarants before importing into the EU customs territory. This authorisation ensures compliance with carbon emissions reporting and payment obligations. The process involves submitting an application via the CBAM registry to the competent national authority, such as the German customs authority for importers established in Germany, which issues a customs authorisation number germany relevant for CBAM purposes.
Key takeaways
- CBAM declarant authorisation is mandatory for importers exceeding the CBAM single mass-based threshold or acting as indirect customs representatives for such importers [1][2][3].
- Applications must be submitted prior to importation and before exceeding the threshold; late applications may incur penalties [2:1].
- Indirect customs representatives can act as authorised CBAM declarants but must hold an EORI number and be established in an EU Member State [3:1][2:2].
- The customs authorisation number germany is a key identifier granted by German customs authorities upon authorisation, used in CBAM declarations.
- Non-compliance with CBAM declarant authorisation obligations can lead to import refusals and penalties [1:1][2:3].
- Other customs authorisation numbers exist for different customs simplifications and exporter statuses, distinct from CBAM declarant authorisation [4][5][6][7].
Who Needs a CBAM Declarant Authorisation?
Under Regulation (EU) 2023/956, any importer established in an EU Member State intending to import goods subject to CBAM must apply for and obtain the status of authorised CBAM declarant before importing those goods into the Union customs territory [3:2]. This requirement also extends to indirect customs representatives who act on behalf of importers, regardless of whether the importer is exempt under certain provisions, such as Article 2a of the Regulation [3:3].
The obligation is particularly relevant for importers who expect to exceed the annual single mass-based threshold for CBAM-covered goods. Such importers must secure authorisation before crossing this threshold to avoid penalties [2:4]. For importers not established in the EU, their appointed indirect customs representatives must obtain authorisation and assume the declarant responsibilities [3:4].
In practice, for a company operating in Germany, this means that if the business imports CBAM-relevant goods and anticipates exceeding the threshold, it must apply for authorisation from the German customs authority and receive a customs authorisation number germany confirming its status as an authorised CBAM declarant.
Application Process and Deadlines for CBAM Authorisation
The application for CBAM declarant authorisation must be submitted electronically via the CBAM registry established under Article 14 of Regulation (EU) 2023/956 [3:5]. The application must include:
- The applicant’s name, address, and contact details;
- The Economic Operators Registration and Identification (EORI) number;
- The main economic activity carried out within the Union;
- Certification from the relevant tax authority confirming no outstanding national tax recovery orders [3:6].
Importers and indirect customs representatives should submit their applications before exceeding the single mass-based threshold. To mitigate import disruptions due to a potentially high volume of applications at the beginning of 2026, Regulation (EU) 2025/2083 allows applicants who have submitted an application by 31 March 2026 to continue importing CBAM goods even after exceeding the threshold, pending the decision on their authorisation [2:5].
If authorisation is refused or the application is submitted late, the importer or indirect customs representative will be subject to penalties as per Article 26(2a) of Regulation (EU) 2023/956 [2:6].
For importers established in Germany, the application is made to the German customs authority, which will issue a customs authorisation number germany upon approval. This number is essential for customs declarations and CBAM compliance.
Role of Indirect Customs Representatives
Indirect customs representatives (ICRs) can act as authorised CBAM declarants on behalf of importers. An ICR must be appointed by the importer under Article 18 of the Union Customs Code and agree to act as the authorised CBAM declarant [3:7]. The ICR must be established in an EU Member State and hold an EORI number [2:7].
When an ICR acts as an authorised CBAM declarant, it assumes all obligations applicable to the importer under the CBAM Regulation for the goods imported on behalf of that importer [3:8]. This delegation allows importers without direct customs expertise or presence in the EU to comply with CBAM requirements through a qualified representative.
The authorised CBAM declarant, whether the importer or the ICR, remains responsible for submitting accurate CBAM declarations and ensuring compliance with reporting and payment obligations.
Consequences of Non-Compliance
Failure to obtain CBAM declarant authorisation before exceeding the single mass-based threshold results in import refusals and penalties [1:2][2:8]. Customs authorities will not allow the importation of goods by any person who is not an authorised CBAM declarant [1:3].
Additionally, the Commission and competent national authorities will monitor compliance through periodic information exchanges based on customs declarations, including EORI numbers and customs authorisation numbers [1:4]. This surveillance mechanism ensures that only authorised declarants can import CBAM-relevant goods.
Penalties for non-compliance are enforced to prevent circumvention of CBAM obligations and maintain the integrity of the mechanism [2:9].
Other Customs Authorisation Numbers for EU Businesses
Beyond CBAM declarant authorisation, EU businesses may require other customs authorisations linked to different customs simplifications or exporter statuses.
For example, approved exporters who frequently ship products under preferential trade agreements may receive a customs authorisation number from the customs authorities. This number appears on invoice declarations and facilitates customs procedures by certifying the exporter’s status and guarantees regarding product origin [4:1][5:1][7:1].
Similarly, authorisations for the regular use of simplified customs declarations under the Union Customs Code require compliance with certain conditions and are granted by the relevant customs authority. These authorisations come with specific obligations and may also be associated with a customs authorisation number [6:1][8].
It is important for EU businesses to distinguish between these various authorisations and their respective customs authorisation numbers, as the customs authorisation number germany for CBAM declarants is specific to the carbon border adjustment mechanism and its compliance framework.
FAQ
How to check customs authorization number?
Customs authorisation numbers, including the customs authorization number germany, are issued by the relevant national customs authority upon granting authorisation. Businesses can verify their authorisation status and number through their national customs portal or by contacting the competent customs authority directly.
What is a German customs reference number?
A German customs reference number typically refers to the unique identifier assigned by German customs to an authorised declarant or exporter. For CBAM purposes, it corresponds to the customs authorization number germany granted upon authorisation as a CBAM declarant.
Is an EORI number a customs authorisation number?
No. An EORI number (Economic Operators Registration and Identification) is a unique identifier for economic operators in customs procedures across the EU. It is mandatory for customs declarations but distinct from a customs authorisation number, which is granted upon authorisation for specific customs simplifications or regimes such as CBAM declarant status.
What is customs authorisation?
Customs authorisation is the formal approval granted by a national customs authority allowing an economic operator to benefit from specific customs simplifications or to act in a particular capacity, such as an authorised CBAM declarant. It involves meeting certain conditions and obligations and is evidenced by a customs authorisation number.
