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What is an Authorised CBAM Declarant? Registration Requirements and Obligations

A complete guide to the Authorised CBAM Declarant role — who must register, what the obligations are, and how African exporters can support their EU buyers.

Published April 2026·Last updated April 2026·carbonborderadjustment.co.za

The Authorised CBAM Declarant: The EU Side of the Equation

The legal obligation to purchase CBAM certificates lies with the Authorised CBAM Declarant — an entity registered in the EU. African exporters themselves do not register as CBAM declarants, but they must provide the embedded emissions data the declarant needs.

Who Must Register?

Any entity that imports CBAM-covered goods into the EU must register as an Authorised CBAM Declarant before the first import: EU-based importers, EU customs agents, EU subsidiaries of African companies.

Registration Requirements

  1. Be established in an EU Member State
  2. No serious infringement of customs or tax rules in the past 3 years
  3. Register via the CBAM Registry portal
  4. Obtain a CBAM Account Number (CAN)

The Declarant's Annual Obligations

| Deadline | Obligation | |---|---| | 31 January | Submit CBAM declaration for the previous calendar year | | 31 May | Surrender CBAM certificates equal to declared embedded emissions | | Ongoing | Purchase CBAM certificates from the national competent authority |

What African Exporters Must Provide

  • Actual embedded emissions (tCO₂e per tonne) — verified by an accredited verifier
  • Production country and facility details
  • Carbon price paid in the country of origin (for offset purposes)

Register at the Digital Product Passport Registry to formalise your CBAM data sharing obligations with EU buyers.

Frequently Asked Questions

Who is the Authorised CBAM Declarant?
The Authorised CBAM Declarant is the EU-based entity legally responsible for purchasing CBAM certificates and submitting CBAM declarations. This is typically the EU importer, customs agent, or EU subsidiary — not the African exporter.
Do African exporters need to register as CBAM declarants?
No. African exporters do not register as CBAM declarants. However, they must provide verified embedded emissions data to their EU buyers, who are the declarants.
What happens if an EU importer is not registered as an Authorised CBAM Declarant?
Importing CBAM-covered goods without being registered as an Authorised CBAM Declarant is a violation of EU law. Penalties include fines of 3× the CBAM certificate price for each tonne of unreported emissions.
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