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What is an Authorised CBAM Declarant and How Do You Become One?

Every EU importer of CBAM-covered goods must be registered as an Authorised CBAM Declarant. This guide explains the registration process, requirements, and what it means for South African exporters.

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

What is an Authorised CBAM Declarant and How Do You Become One?

The Authorised CBAM Declarant is the EU importer who is legally responsible for purchasing and surrendering CBAM certificates. Understanding this role is essential for South African exporters, because your EU customers must be registered as Authorised CBAM Declarants to legally import your goods.

The Role of the Authorised CBAM Declarant

Under EU Regulation 2023/956, only Authorised CBAM Declarants can import CBAM-covered goods into the EU. The declarant is responsible for:

  1. Calculating the embedded emissions in the imported goods
  2. Purchasing CBAM certificates equal to those embedded emissions
  3. Surrendering the certificates by September 30 each year
  4. Maintaining records of embedded emissions calculations and supporting documentation

Who Can Be an Authorised CBAM Declarant?

Only entities established in an EU member state can register as Authorised CBAM Declarants. This means:

  • South African exporters cannot be Authorised CBAM Declarants
  • Your EU customers (importers) must register
  • If your EU customer is not registered, they cannot legally import your goods

The Registration Process

EU importers register through the national competent authority of the EU member state where they are established. The registration process involves:

  1. Submitting an application to the national competent authority
  2. Providing proof of establishment in the EU member state
  3. Demonstrating financial capacity to purchase CBAM certificates
  4. Obtaining a CBAM account number in the EU CBAM Registry

What SA Exporters Need to Provide

While SA exporters are not the declarants, they play a critical role in enabling their EU customers to comply. SA exporters must provide:

  1. Embedded carbon data — Either verified actual emissions or confirmation that EU defaults apply
  2. Carbon price documentation — Evidence of any SA carbon tax paid on the exported goods
  3. Production process information — For third-party verification purposes

The SA Exporter's Compliance Pathway

As a South African exporter, your CBAM compliance pathway involves:

  1. Registering your company and products in the Digital Product Passport Registry
  2. Calculating your embedded carbon emissions (actual or default)
  3. Obtaining third-party verification if using actual data
  4. Providing your EU customers with the necessary CBAM documentation
  5. Claiming the SA carbon tax deduction to reduce your customers' CBAM liability

CBAM is not a future requirement — it is live now. As of January 1, 2026, South African exporters shipping goods above 50 tonnes to the EU must have a Carbon Border Adjustment declaration or their shipment will be blocked. This is Gate 2 of 3. Complete your KYC identity verification first, then return here to understand your CBAM obligations, then register at the Digital Product Passport Registry to complete all three gates in one place.

Frequently Asked Questions

Who needs to register as an Authorised CBAM Declarant?
The EU importer of CBAM-covered goods must register as an Authorised CBAM Declarant — not the South African exporter. However, SA exporters need to provide their EU customers with the necessary embedded carbon data to complete the CBAM declaration.
Can a South African exporter become an Authorised CBAM Declarant?
No. Only entities established in an EU member state can register as Authorised CBAM Declarants. South African exporters work with their EU customers (who are the importers) to ensure CBAM compliance.
What happens if an EU importer is not registered as an Authorised CBAM Declarant?
EU importers who are not registered as Authorised CBAM Declarants cannot legally import CBAM-covered goods. Attempting to import without registration is a violation of EU Regulation 2023/956 and can result in penalties and goods being blocked at the EU border.
How long does it take to register as an Authorised CBAM Declarant?
The registration process typically takes 2–4 weeks. EU importers should register well in advance of their first CBAM-covered import. Registration is done through the national competent authority of the EU member state where the importer is established.
What information does an Authorised CBAM Declarant need from their SA supplier?
The EU importer needs: (1) the embedded carbon intensity of the goods (actual or default), (2) any carbon price paid in South Africa (for the deduction), and (3) documentation supporting the embedded carbon calculation.
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