Getting your CBAM Authorization

Are you importing CBAM classified goods and wondering what to do to be compliant with the new regulations? Below is a short step-by-step guide on what to do:

What is of utmost importance first, is to apply for your CBAM Authorization and obtain your unique CBAM account number to be able to declare the CBAM goods. The absolute deadline for sending in your application is 31^st of March 2026.

If you are using an indirect custom representative (ICR), they may handle the CBAM declaration on your behalf if agreed. If the ICR is to handle your CBAM declaration, it is them who needs to hold a CBAM Authorization.

How to Apply

1. Apply by contacting your National Competent Authority (NCA) and register to access the Uniform User Management & Digital Signatures (UUM&DS).
   
   
2. When having the UUM&DS profile you can access the Authorization Management Module to submit your CBAM application (a module in the CBAM Registry). Submit your application in the Authorization Management Module no later than 31^st of Match 2026.
   
   
3. If your application is approved by the NCA, you will be assigned a unique CBAM account number. This number allows you to act as an authorized CBAM declarant, access the CBAM Registry and submit the necessary declarations required going forward.

CBAM Declaration & Reporting for 2026

The first annual CBAM declaration for the goods imported in 2026 needs to be submitted no later than the 30^th of September 2027 in the CBAM Registry. The annual CBAM declaration must include:

• Type of Goods (defined by Combined Nomenclature (CN) codes)
• Quantity of Goods (expressed in Mwh for electricity and tons for other goods)
• Data on embedded emissions of the goods, using actual verified values verified by accredited verifiers, and/or EU’s default values put forward by the Commission (expressed in tons of CO2e)
• Copies of verification reports issued by the accredited verifiers, in case actual verified values for the emissions are being used.
• Right amount of CBAM certificates to be surrendered corresponding to the amount of embedded emissions of the goods imported after potential deduction from carbon prices paid in the third country (if any).

Thus, during 2026 no CBAM declaration needs to be reported nor CBAM certificated needs to be bought and surrendered. However, importers should prepare for the 2026’s CBAM declaration that will be reported in 2027. For example, prepare by gathering information on the emission data for the CBAM classified imported goods in 2026 (using actual verified values verified by accredited verifiers and/or EU’s default values). Please note that the verification reports obtained alongside other information required to calculate the embedded emissions need to be kept for a period of four years after the verification has been completed.

Going forward the deadline for submitting the annual CBAM declaration will be the 30^th of September annually.

Buying CBAM Certificates

From 1^st of February 2027 declarants can start buying CBAM certificates for the embedded emissions of the imported goods in 2026. CBAM certificates are bought through the Common Central Platform (CCP) managed by the Commission and are recorded in the CBAM Registry. To access the CCP you login via the CBAM Registry. The price of the certificates will correspond to the price of EU ETS allowances (auction price) and will be priced per emitted ton of CO2e.

Please note that from 2027, declarants must ensure that the number of CBAM certificates on its account in the CBAM Registry at the end of each quarter corresponds to at least 50% of the embedded emissions imported in that calendar year. This means that the declarant must purchase certificates on an ongoing basis during the year and in parallel with its imports.

If the importer holds excess of CBAM certificates after the annual CBAM declaration has been submitted, the Commission can repurchase those certificates if the declarant submits a repurchase request no later than the 31^st of October each year during which CBAM certificates were surrendered.  

From 1^st of November each year, excess certificates that were purchased during the year before the previous calendar year will be cancelled by the Commission without any compensation. However, the year 2027 is an exception and all excess certificates remaining at the declarant’s CBAM Registry on the 1^st of November 2027 will be cancelled without any compensation.

Important Take Aways

• You need to apply to become an Authorized CBAM declarant no later than the 31^st of March 2026 or make sure that your indirect custom representative has applied to become an Authorized CBAM declarant.
• The first CBAM declaration is due the 30^th of September 2027 for the imported CBAM goods in the calendar year 2026.
• From 2027 onward, the declarant needs to hold CBAM certificates for at least 50% of the year-to-date embedded emissions at the end of each quarter (e.g. the declarant needs to continuously purchase CBAM certificates corresponding to at least 50% of the year-to-date embedded emissions at the end of each quarter).
• The Commission can repurchase excess CBAM certificates if the declarant sends in a request no later than the 31^st of October annually.
• 1^st of November 2027, excess certificates that were not repurchased and remained in the declarant’s CBAM Registry will be cancelled by the Commission without any compensation. Going forward excess certificates can be kept and used for two years prior to the annual automatic cancellation of 1^st of November.

HOW CAN WE SUPPORT YOU?

We will keep you informed about any updates on the Carbon Border Adjustment Mechanism. Feel free to contact sustainability@berting.com if you have any questions

Extract of available sources from EU for further information

• EU’s Website for CBAM
• EU’s Guide CBAM Compliance Essentials for Importers and Indirect Customs Representatives
•  Regulation:
  • Regulation 2023/956
  • Amending Regulation 2023/956, Regulation 2025/2083
• List of EU’s NCAs