Regulation (EU) 486/2025 on obtaining the status of authorised declarant under CBAM has been published

On 18 March 2025, Regulation (EU) no. 486/2025 laying down rules for the application of Regulation (EU) 2023/956 of the European Parliament and of the Council as regards the conditions and procedures related to the status of authorized declarant under the CBAM has been published, applicable from March 28, 2025.

Among the most important aspects, we mention the following:

  • Obtaining the status of authorized declarant
    • The authorization process includes the submission of an application through the CBAM register, in electronic format, the provision of the necessary documentation demonstrating compliance with the criteria set out in the CBAM Regulation, as well as the assessment by the competent authorities.
    • Among the requested information/documents we list: EORI number, affidavit according to which the applicant has not been involved in serious or repeated violations of customs legislation, documents proving financial and operational capacity.
    • 120 calendar days from the date of receipt of the request is the assessment deadline of the competent authority and can be extended up to 180 calendar days if additional information is requested (the economic agent has a period of 30 days to submit the requested information).
    • We remind you that importers must meet several criteria to obtain the status of authorized declarant:
      • compliance with legislation: The applicant must not have been involved in serious or repeated violations of customs, tax, market abuse rules or the CBAM Regulation.
      • financial and operational capacity: The applicant must demonstrate that it can meet the obligations imposed by the CBAM.
      • establishment in the EU: The applicant must be established in the Member State where the application is submitted.
      • EORI number: The applicant must hold an EORI number according to the EU regulations.
  • Establishment and monitoring of the guarantee
    • In the case of economic agents who have not been established during the two financial years preceding the year in which the application was submitted, they will also submit a guarantee calculated as the maximum value of the number of CBAM certificates that they should return.
  • Revocation of CBAM authorization
    • At the request of the declarant or if the authorities consider that the economic agent no longer meets the condition, the CBAM authorization can be revoked;
    • If the revocation of the CBAM authorisation was registered after 31 May of each year, the CBAM declaration for that year shall include information on the goods imported between 1 January of the year in which the revocation was registered and the date of revocation.

We recommend that you analyze the criteria necessary to obtain the status of authorized declarant and initiate the authorization process as soon as possible, as the CBAM authorization process may take more than 6 months, and from 2026, the import of products subject to CBAM is conditioned on holding the CBAM authorization.

The EY team is available for further details on the above.

Prepared by:

  • Daniela Neagoe - Senior Manager, Indirect Tax
  • Mihai Petre - Director, Indirect Tax

For additional information, please contact:

  • Alex Milcev - Partner, Tax & Law Leader Romania & Moldova
  • Georgiana Iancu - Partner, Leader of the Indirect Tax Department
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