How to Appoint an Authorised CBAM Declarant

What is an Authorised CBAM Declarant?

An Authorised CBAM Declarant (ACD) is the legal entity responsible for the CBAM compliance process on the EU side. Under EU Regulation 2023/956, every importer of CBAM-covered goods must either be an ACD themselves or appoint one to act on their behalf.

The ACD is responsible for:

• ▸Maintaining a CBAM account in the EU CBAM Registry
• ▸Submitting the annual CBAM declaration by 31 May each year
• ▸Purchasing and surrendering CBAM certificates equal to the embedded carbon in imported goods
• ▸Ensuring the embedded carbon data provided by the SA exporter is accurate and verifiable

South African exporters cannot be ACDs. The ACD must be established in the EU. This means your EU buyer, their customs broker, or a specialist CBAM compliance firm must hold the ACD account.

Step 1: Confirm Your EU Buyer's ACD Status

The first step is to contact your EU importer and ask:

1. ▸Do you hold an Authorised CBAM Declarant account in the EU CBAM Registry?
2. ▸If not, have you appointed a customs broker or CBAM compliance firm to act as your ACD?
3. ▸What is your ACD account number?

If your EU buyer does not have an ACD account and has not appointed one, they cannot legally import your goods from 1 January 2026. This is a critical supply chain risk that must be resolved before the first shipment.

Step 2: Find a Qualified ACD

If your EU buyer needs to appoint an ACD, they have three options:

Option A: Apply for ACD status themselves EU-established importers can apply for ACD status directly at cbam.ec.europa.eu. The application requires a valid EORI number and a customs authority account. Processing times vary by member state.

Option B: Appoint their existing customs broker Many EU customs brokers and freight forwarders have obtained or are obtaining ACD status. Your EU buyer should ask their existing logistics partner if they offer CBAM declarant services.

Option C: Engage a specialist CBAM compliance firm A growing number of EU-based compliance firms specialise in CBAM declarant services, particularly for importers from South Africa, Turkey, and other high-exposure countries. These firms act as ACD for multiple importers and typically charge a per-declaration or annual retainer fee.

Step 3: Establish the Data Provision Agreement

Once the ACD is confirmed, the SA exporter must establish a formal data provision agreement with the EU importer covering:

1. ▸Embedded carbon data format — Specify whether you will provide actual measured emission values (from an MRV system) or EU default values. Actual values are lower for most SA sectors and reduce the CBAM liability.
2. ▸Data delivery timeline — The ACD needs your embedded carbon data before the 31 May declaration deadline. Agree on a delivery date (e.g., 31 March each year).
3. ▸Verification requirements — Actual emission values must be verified by an accredited third-party verifier. Confirm who is responsible for engaging the verifier.
4. ▸Penalty allocation — If the ACD incurs a penalty due to inaccurate data from the SA exporter, who bears the cost? This must be explicitly addressed in the supply contract.

Step 4: Provide the Required Embedded Carbon Data

For each shipment of CBAM-covered goods, the SA exporter must provide:

| Data Field | Description | |---|---| | CN Code | 8-digit Combined Nomenclature code for the goods | | Country of Origin | South Africa | | Production Facility | Name, address, and UN/LOCODE of the production site | | Embedded Emissions | tCO₂e per tonne of goods (actual or EU default) | | Emission Methodology | The standard used to calculate emissions (e.g., IPCC, ISO 14064) | | Verification Status | Whether actual values have been third-party verified |

This data is submitted by the ACD to the EU CBAM Registry as part of the quarterly or annual declaration.

Step 5: Register at the Digital Product Passport Registry

The Digital Product Passport Registry provides SA exporters with a structured compliance pathway that includes:

• ▸MRV system setup for actual embedded carbon measurement
• ▸Third-party verification coordination
• ▸ACD data package preparation
• ▸Ongoing CBAM certificate price monitoring

Completing the DPP registration is the fastest way to ensure your data provision obligations are met before the first declaration deadline.

Key Deadlines

| Milestone | Date | |---|---| | Full CBAM enforcement begins | 1 January 2026 | | First annual declaration deadline | 31 May 2027 | | First certificate surrender deadline | 30 September 2027 | | Second annual declaration deadline | 31 May 2028 |

Use the CBAM Compliance Timeline to track all upcoming milestones.