CBAM Declarant: Registration, Liability & Duties

A CBAM declarant is the person or entity responsible for submitting CBAM reports to the national competent authority. Understanding the declarant role is essential for legal compliance.

"An authorised CBAM declarant is a person or legal entity established in the EU that has been authorised to submit CBAM declarations." — EU Regulation 2023/956, Article 3

Declaration Timeline

Import Year	CBAM Factor	Declaration Deadline	First Certificate Purchase
2026	2.5%	September 30, 2027	February 1, 2027
2027	5%	September 30, 2028	February 1, 2028
2028	10%	September 30, 2029	February 1, 2029
2029	22.5%	September 30, 2030	February 1, 2030
2030	48.5%	September 30, 2031	February 1, 2031

Who Can Be a CBAM Declarant?

The CBAM declarant can be:

• The importing company itself (most common)
• An authorised customs representative
• A third-party compliance service provider

The declarant must be established in the EU and registered with the CBAM Transitional Registry. They must hold a valid EORI number.

Legal Responsibilities

The CBAM declarant is legally responsible for:

• Accuracy of all data submitted in CBAM reports
• Timely submission of annual CBAM declarations
• Retention of supporting documentation (minimum 4 years)
• Payment of any penalties resulting from non-compliance
• Cooperation with audits and investigations

These responsibilities cannot be transferred or outsourced. Even if a third party prepares the report, the named declarant bears ultimate legal liability.

Registration Process

Step	Action	Details
1	Obtain EORI number	From your national customs authority
2	Register with CBAM Registry	Online application
3	Designate declarant	Individual or legal entity
4	Provide documentation	Contact info + proof of establishment
5	Receive confirmation	Access credentials issued

Registration typically takes 2–4 weeks. Start early — you cannot submit reports without it.

Common Registration Pitfalls

From monitoring CBAM registrations across member states, the most frequent delays stem from three causes: EORI number mismatches (company name or address differs from customs records), incomplete documentation of EU establishment, and underestimating the 2–4 week processing window. We have seen cases where registrations started two weeks before the first deadline resulted in automatic penalty exposures simply because the competent authority needed more time to verify documentation. Our recommendation: begin the registration process at least 60 days before your first expected submission.

Liability and Risk Management

CBAM declarants face real legal and financial risks:

• Financial liability — Penalties for incorrect or late reports
• Legal liability — Potential legal action for fraudulent reporting
• Reputational risk — Audits and enhanced scrutiny for repeated errors

Mitigate these risks by:

• Using automated calculation tools
• Maintaining thorough documentation
• Implementing internal review workflows
• Staying updated on regulatory changes

Best Practices for Declarants

Practice	Benefit
Centralise data collection	Single system for all emission data
Automate calculations	Reduce human error with software
Maintain audit trail	Document every data source
Review before submission	Double-check all reports
Stay informed	Monitor regulatory updates

FAQ

What is CBAM reporting?

CBAM reporting is the mandatory process where EU importers declare the embedded emissions in goods they import from outside the EU. Each declaration must include product quantities, CN codes, direct and indirect emissions, country of origin, and carbon price paid. Annual declarations are submitted by September 30 each year to the national competent authority via the CBAM Registry, supported by quarterly data collection. Accurate reporting determines how many CBAM certificates you need to purchase.

Who needs to register as a CBAM declarant?

Any company or individual that imports CBAM-covered goods (steel, aluminium, cement, fertilisers, hydrogen, or electricity) into the EU must register as a CBAM declarant. This includes direct importers, indirect customs representatives, and authorised third parties. Registration requires an EORI number and must be completed through the Authorisation Management Module (AMM) of the CBAM Registry.

Can a non-EU company be a CBAM declarant? No. The declarant must be established in the EU. Non-EU companies must appoint an EU-based representative.

Can I change my declarant mid-year? Yes. Update your registration with the national competent authority. Previous reports remain the responsibility of the declarant at the time of submission.

What happens if my declarant leaves the company? The company must designate a new declarant and update the registry immediately. Reports must still be submitted on time.

Sources

• EU Regulation 2023/956 — CBAM main regulation (declarant requirements in Article 3)
• IR (EU) 2025/2621 — Default emission values and methodology
• IR (EU) 2025/2548 — Registration and submission rules
• European Commission CBAM page

Last updated: July 2026 | Sources: EU Regulation 2023/956, European Commission CBAM publications

Managing Declarant Responsibilities with CbamTrack

CbamTrack helps declarants fulfil their obligations with automated data collection, built-in validation, complete audit trails, and one-click report generation. Start with our free CBAM reporting template, try the software free, or compare alternatives.