What is an Authorised CBAM Declarant?

The Authorised CBAM Declarant is the central compliance role in the CBAM framework. Understanding this role is essential for South African exporters, because while the registration obligation falls on EU importers, the data obligations fall squarely on SA producers.

Definition

An Authorised CBAM Declarant is an EU-based importer who has:

1. Been approved by their national competent authority (customs authority) in an EU member state
2. Registered in the EU CBAM Registry at cbam.ec.europa.eu
3. Accepted legal responsibility for purchasing and surrendering CBAM certificates
4. Committed to annual CBAM declarations covering embedded emissions in imported goods

The Registration Process

EU importers must apply for Authorised CBAM Declarant status through their national competent authority. The application process requires:

• Company registration details and tax identification
• Proof of financial standing (ability to purchase CBAM certificates)
• Declaration of compliance with CBAM obligations
• Appointment of a responsible representative if required

Once approved, the declarant receives a unique CBAM Declarant Identification Number (CDIN) which must appear on all CBAM declarations.

What SA Exporters Must Provide

While SA exporters do not register as CBAM Declarants themselves, they have critical data obligations:

Option 1: Verified Actual Emissions (Recommended)

• Commission an accredited verifier to certify your embedded emissions
• Provide the verification report to your EU importer
• EU importer uses actual data in their CBAM declaration
• Result: Lower CBAM cost (actual emissions typically below default values)

Option 2: Accept EU Default Values (Costly)

• If no verified data is provided, EU importer uses EU Commission default values
• Default values carry a 10% markup penalty in 2026, rising to 30% by 2028
• Result: Significantly higher CBAM cost

The Cost Differential

The financial incentive to provide verified actual emissions is substantial:

For a SA steel exporter shipping 50,000 tonnes per year to the EU, the difference between verified actual emissions and 2028 default values could exceed EUR 2.5 million annually.

Accredited Verifiers in South Africa

SA exporters need to engage accredited verifiers to certify their embedded emissions. Verifiers must be accredited under ISO 14065 and approved by the European Commission. Key verification bodies operating in SA include:

• Bureau Veritas
• SGS South Africa
• TUV Rheinland
• Lloyd's Register

References

• European Commission CBAM Registry
• Regulation (EU) 2023/956 Article 5
• Dubrink — How to Become a CBAM Authorized Declarant