Insights / CBAM
CBAM Authorisation: Who Needs It and the 31 March 2026 Window
Can we keep importing CBAM goods while our application for authorisation is pending?
Only if you applied by 31 March 2026. Article 4 lets only an authorised CBAM declarant import CBAM goods. Under Article 17(7a), an importer or indirect customs representative that applied for authorisation by 31 March 2026 may keep importing while the authority decides. That window has closed: an importer that did not apply by then must be authorised before importing above the threshold.
What the act says
- Article 4: CBAM goods are imported only by an authorised CBAM declarant.
- Article 5(1): An importer applies for the status before importing.
- Article 17(7a): The provisional route covered only applications made by 31 March 2026.
- Article 26(2): Importing without authorisation draws a penalty of three to five times the EU ETS excess emissions penalty on the embedded emissions.
What to do
- If you import Annex I goods above 50 t a year and have not applied, apply now and hold imports above the threshold until you are authorised.
- If you applied by 31 March 2026, keep the proof of the application date.
Sources
- Regulation (EU) 2023/956 (CBAM), consolidated text (CELEX 32023R0956)
- Regulation (EU) 2025/2083 amending the CBAM Regulation (CELEX 32025R2083)
Last checked against the act text on 2026-10-20. For information only, not legal advice.