As of 1 January 2026, importers of goods subject to CBAM will be required to obtain the status of authorised declarant.

Only importers whose CBAM-covered imports remain below the threshold of 50 tonnes in 2026 will be exempt from this requirement.

In this context, Regulation (EU) 2025/2083 introduces certain simplifications that will allow operators who have not yet obtained the authorisation to continue importing CBAM goods during 2026 and subsequent years, provided that the application is submitted before 31 March 2026.

Please note that the competent authorities have 120 days to process authorisation requests.

We therefore urge all importers who exceeded the threshold in 2025, or expect to exceed it in 2026, to submit their CBAM authorisation application as soon as possible.

The application can be submitted at the following link:

https://cbam.ec.europa.eu/authorised-declarant

In addition, the Carbon Markets Unit of the OECC has published on its website a guidance document and a video tutorial to support applicants throughout the process.

Emissions declaration

A key element of the system is the emissions calculation methodology, for which importers must choose between two options:

1. Declaration of actual emissions

A verification report issued by an accredited independent verifier will be mandatory.

Verification must ensure that the data complies with the methodological requirements established by the European Commission.

Details regarding accreditation, control, supervision and mutual recognition are currently under parliamentary discussion.

2. Declaration using default values

Applicable when it is not possible to obtain actual data from the production facility.

No verification is required; however, default values will likely be significantly higher than those used during the transitional period (2023–2025), which will increase the cost of CBAM certificates.

Key obligations timeline

Date    Obligation

1 January 2026    Imports will only be allowed for CBAM authorised declarants.

Throughout 2026    Monthly monitoring of emissions (actual or default).

31 May 2027    Submission of the first annual CBAM declaration with certificate surrender.

Should you have any questions, please do not hesitate to contact us.