Status of authorised CBAM declarant: next steps by waiting for the definitive regime 2026

From the 1 January 2026, thanks to EU regulation n. 2025/486 UE of 17 March 2025, the importers and indirect customs representative will be in the position to apply for the status of authorised CBAM declarant. On 31 march 2025, to make it possible, the EU Commission will launch the Authorisation Management Module (AMM) in the CBAM registry.

CBAM (definitive regime) in principles:

a) EU importers of goods covered by CBAM will register with national authorities where they can also buy CBAM certificates;

b) EU importers will declare the emissions embedded in their imports and surrender the corresponding number of certificates each year;

c) If the carbon price has already been paid during the production of the imported goods, the corresponding amount can be deducted;

d) (Omnibus package): CBAM de minimis threshold exemption of 50 tonnes mass.

It is interesting, in anycase, to keep in mind which are the goods covered by the CBAM. The list, below summarized, recalls the main role played by the customs classification which is one of the three pillars (with value and origin) of the customs obligation.

In other words, authorised CBAM declarant have to take care of the classification process since:

they risk to infrige CBAM rules;
they reduce our “reliability” (if AEO).

Authorised CBAM declarants have to:

monitor the internal process of customs classification;
check the customs classification made in our behalf by other entities;
discrepancies and audit from customs;
apply for BTI if needed.

LIST WITH GOODS-HS CODE (harmonized customs code)-GREENHOUSE GAS RELATED

Cement (25070080 – Kaolin and other kaolinic clays, calcined; 25231000 – Cement clinkers; 252321 00 – White Portland cement, whether or not artificially coloured; 25232900 – Other Portland cement; 25233000 – Aluminous cement; 25239000 – Other hydraulic cements); greenhouse GAS related: carbon dioxide;
Electricity (27160000 – Electrical energy); greenhouse GAS related: carbon dioxide;
Fertilisers (28080000 – Nitric acid; sulphonitric acids; 2814 – Ammonia, anhydrous or in aqueous solution; 28342100 – Nitrates of potassium; 3102 – Mineral or chemical fertilisers, nitrogenous; 3105 – Mineral or chemical fertilisers containing two or three of the fertilising elements nitrogen, phosphorus and potassium); greenhouse GAS related: carbon dioxide; nitrous oxide;
Iron and Steel (72 – Iron and steel [with exceptions]; 7301– Sheet piling of iron or steel; 7302 – Railway or tramway track construction material of iron or steel, the following; 730300 – Tubes, pipes and hollow profiles, of cast iron; 7304 – Tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel; 7305 – Other tubes and pipes; 7306 – Other tubes, pipes and hollow profiles (for example, open seam or welded, riveted or similarly closed), of iron or steel; 7307 – Tube or pipe fittings; 7308 – Structures of iron and steel; 7309 – Reservoirs, tanks, vats and similar containers for any material of iron and steel; 7310 – Tanks, casks, drums, cans, boxes and similar containers of iron and steel; 7311 – Containers for compressed or liquefied gas, of iron or steel; 7318 – Screws and other items; 7326 – Other articles of iron or steel); greenhouse GAS related: carbon dioxide;
Aluminium; (7601 – Unwrought aluminium; 7603 – Aluminium powders and flakes; 7604 – Aluminium bars, rods and profiles; 7605 – Aluminium wire; 7606 – Aluminium plates, sheets and strip; 7607 – Aluminium foil; 7608 – Aluminium tubes and pipes; 76090000 – Aluminium tube or pipe fittings; 7610 – Aluminium structures; 76110000 – Aluminium reservoirs; 7612 – Aluminium casks; 76130000 – Aluminium containers for compressed or liquefied gas; 7614 – Stranded wire; 7616 – Other articles of aluminium); greenhouse GAS related: Carbon dioxide and perfluorocarbons
Chemicals (hydrogen): HS code: 2804 10 000; gas: carbon dioxide;

These goods require-in advance- an authorization for their import.