Deadline for Authorized CBAM Declarant Status
CBAM Weekly – Issue 85
March 31 is not just any deadline
In a few weeks, the deadline expires by which companies must have submitted their application for authorization as a CBAM declarant. Without this status, they risk delays in the delivery of CBAM-liable goods after March 31. The definitive phase of CBAM has been in effect since January 1, 2026. CBAM now directly impacts customs processing. In principle, the obligation to hold authorized CBAM declarant status has existed since January 1. However, following an operational issue with access to the CBAM registry, the European Commission granted affected companies a grace period. This grace period expires on March 31. Companies that have not submitted an application by then and exceed the 50-tonne threshold will no longer be able to import CBAM goods. Those who submit their application on time may continue to import provisionally until a decision on the application is made. But be warned: if the application is rejected, retroactive sanctions may apply.
What needs to be done now
The first point concerns the application status. Has the application for authorization as a CBAM declarant actually been submitted? In Germany, the application process has been available since March 2025, but many companies have postponed this step, and some only discovered that CBAM is in force when they carried out their first import transaction in 2026. Since January 1, 2026, specific TARIC document codes must be declared when filing customs declarations for CBAM goods. Code Y128 represents the CBAM account number for already granted authorizations. Y238 confirms that an application was submitted before March 31, 2026, and a decision is still pending. In addition to the respective codes, it is necessary to provide either the CBAM account number received upon successful application or at least the application number.
Preparing for the application
Companies that have not yet submitted an application but already know they will exceed the 50-tonne threshold this year should begin preparations as soon as possible. The application includes, among other things, details on goods imported in the current and following year by customs tariff number, including their estimated quantity and value. You must also provide a declaration on your honor that you have not committed any serious legal violations in the course of your business activities. A potential blocker can be the so-called certificate of good standing, as this must be requested from the responsible tax office. In Germany, the balance sheets of the last three completed financial years are also required. Finally, some information about your internal processes for handling CBAM must be provided.
Risk of long delays
It is essential to note that the deciding authority is granted a long processing period of up to 120 calendar days. This means that if you have exceeded the import threshold but have not submitted an application by March 31, you will have to wait for the authority's decision before you can resume imports of CBAM-liable goods.
Outlook
March 31, 2026, is the last point at which companies can still prevent a delayed CBAM implementation from becoming an acute customs and supply chain problem. Companies that have clarified their application and TARIC logic by then can use the definitive phase as a manageable system. All others must be prepared for long delays once the threshold is exceeded.
Support
If you would like to check whether your CBAM setup is complete before March 31, or whether your CBAM compliance management and internal responsibilities are aligned, feel free to write to me at helge@kolum.earth. We will help you start the next phase prepared.