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This page provides guidance on becoming an authorised CBAM declarant. Please see links below to the different sections on this page:

Becoming an Authorised CBAM Declarant

The NCA of the Member State of establishment is responsible for assessing the application and ensuring compliance with the criteria to become an authorised CBAM declarant. Applicants must meet the following criteria:

  • Applicants have not been involved in a serious infringement or in repeated infringements of customs legislation, taxation rules, market abuse rules or the CBAM Regulation.
  • Applicants demonstrate financial and operational capacity.
  • Applicants are established in the Member State where an application is submitted and have been assigned an EORI number.

 

Who is required to apply for the status of Authorised CBAM Declarant?

An application to become an authorised CBAM declarant may be submitted either directly by the importer (i.e. the person lodging a customs declaration for release for free circulation of goods in its own name and on its own behalf) or by an indirect customs representative (ICR) (i.e. a person acting in his or her own name, but on behalf of the importer) assuming CBAM obligations for an importer.

 

It is important to note, that if you (as an importer or indirect customs representative) apply for authorisation, but do not import above the 50-tonne threshold throughout the calendar year, there will be no financial or reporting obligations.

 

Importers:

An importer established in a Member State must apply for the status of authorised CBAM declarant to continue importing 50 tonnes or more of CBAM goods into Ireland from 1st January 2026. 

Please note, importers who do not expect to exceed the within a calendar year are not required to apply for the status of authorised CBAM declarant.  In this case, Y137 should be the TARIC document type on the customs declaration – an account number or application reference number is not required for this TARIC Document Code. Further information on TARIC document codes can be found here. 

Importers of CBAM goods are expected to monitor their import quantities and ensure they apply for authorisation in good time if they think the threshold may be reached or exceeded. If they do not have authorisation and exceed the threshold, CBAM import restrictions laid down in Article 4 and related provisions of the CBAM Regulation and penalties will apply.  

The legislation allows 120 days for the NCA to assess the application and make a decision, or 180 days where additional information is required.

 

Indirect customs representatives:

If you are an Indirect Customs Representative (established in an EU Member State), you should apply for authorisation now, regardless of whether those you represent are importing above the threshold of 50 tonnes of CBAM goods per calendar year.

If you are an importer not established in an EU Member State, you must appoint an Indirect Customs Representative (ICR) (established in an EU Member State) to obtain the status of authorised CBAM Declarant on your behalf. The Indirect Customs Representative will assume the reporting and financial liabilities and ultimately act as the "importer" for those they represent. 

 

How to apply

The authorisation process assesses whether importers or indirect customs representatives have sufficient financial and operational capacity to comply with their CBAM obligations when importing CBAM goods. The information submitted as part of your application is used to assess this. 

The application for an authorisation is submitted via the Authorisation Management Module (AMM). In order to access the AMM, you will require a valid ROS certificate, Customs and Excise registration and an Economic Operator Registration and Identification (EORI) number. 

Note: In order to access the portal should the PC/Laptop that has the ROS cert saved to it is required. Please select Customs as the domain of the application you request access to.

Note: Please ensure that the relevant individual/individuals who are managing CBAM have a ROS Cert on their device for easy access to the necessary platforms. Further information on sub-user or linked certificates can be found here - Sub-user or linked certificate.

  1. Before starting, ensure you have not attempted to log in previously and close your browser.
  2. Click on this link to access the AMM - https://cbam.ec.europa.eu/authorised-declarant
  3. The first page you see will be a TAXUD Authentication Portal page.
  4. Make the selections as follows:
  • Domain - “Customs” - not Carbon Border Adjustment Mechanism
  • Country - “Ireland”
  • Actor - “Economic Operator”
  1. When you click submit, you will be brought to a ROS page. Here, load your ROS cert (associated with the EORI number) by clicking the “Manage my certificates” link and enter the associated password.
  2. Then click “Return to login” – you will see your cert has been loaded in the box above. Re-enter the ROS password and you will be brought into the AMM portal.

 

What information is required for the application for authorisation?

We have created some tools to assist you in applying for authorisation.

  1. Step-by-step guide: Download our helpful step-by-step guide here for applying for the status of authorised CBAM declarant here.
  2. Checklist:  Download our checklist hereto make sure you have included all the required information in your application.
  3. CN Code spreadsheet: Complete this spreadsheet to inform us of your expected import quantities of CBAM goods according to CN Code and country or origin - this will help us in assessing your application for authorisation. Simply complete this spreadsheet and upload to your application under any section where you can "Add Documents"

 

Section Information required
Stakeholder Information
  • Applicant information
  • Contact details of the person applying
  • If you have indicated you are acting as an indirect customs representative, enter the importer details of those you represent and validity period in the relevant section.
Activity details 
  • Main economic activity e.g. “Manufacture of basic metals”
  • Type of goods imported – select the sector.
  • In "Description of Goods" please state "CN Codes attached" Please use the CN Code excel spreadsheet to input your CN Codes, an estimate of the tonnes of each good by CN Code you expect to import in the current year, next calendar year and the country of origin if available.
  • Click “Add” to add more than one sector attributable to your application.
  • Note:  Do not make any selection (Yes or No) for the question "Electricity Import Status" unless you are an importer of Electricity This question only becomes mandatory once Electricity is selected as the sector in the field "Type of goods imported"
  • Estimations of the quantity and value of goods for the current year and for next calendar year.
  • Select the EU member states in which you have been or expect to be involved as importer or declarant in customs declarations for CBAM goods (this includes Ireland) i.e. where do you import CBAM goods to. This is not where you outline the countries you import from, but rather where you indicate if you are using your IE EORI number as the importer of record in another EU Member State.
  • Irish tax clearance certificate – e-cert to be uploaded to application, please do not print the results screen. Details on how to obtain a tax clearance certificate can be found on Revenue’s website here -  The electronic Tax Clearance (eTC) System.
  • Declaration of honour – tick box to state you have not been involved in serious or repeated infringements. Please read this question carefully.
Financial & operational details
    • Data access declaration – by selecting this box, you are allowing the EPA, as NCA, to access relevant information from relevant government bodies in relation to your application
    • AEO status (if applicable). Proof of status will be required.
    • Business Registration Number – this is your Companies Registration Office (CRO) number. You can find it at  www.CRO.ie 
    • Financial figures for the preceding three years (profit/loss/turnover/current assets/current liabilities) i.e. 2024 (2025 if available) (Year 3), 2023 (Year 2), 2022 (Year 1)

    Your application must include (these can be uploaded to the "Add Documents" section of the application form):

    • Unabridged Financial Statements for the last two financial years.  (including Income Statement/Profit & Loss, Statement of Financial Position/Balance Sheet and Statement of Cash Flows). Please note these financial statements must be audited (unless an audit exception has been granted) or
    • Management accounts relating to periods subsequent to the most recent Audited Financial Statements.
    • Please also provide details of any post balance sheet events between the date on which the last audited accounts were authorised and date of application.

 

How to make an adjustment to an application

Once you have submitted your application, you can submit additional text and files to your application via an adjustment.  The EPA may request specific information as a result of an initial assessment of your application. Please follow the steps in the How to Submit an Adjustment guidance here. 

 

How to provide additional information after authorisation has been granted

The status of authorised CBAM declarant is granted on the basis of the information and documents provided by the applicant in its application for authorisation, and on the basis of the criteria set out in the CBAM Regulation. If any information changes after the authorisation has been granted, the conditions for the authorisation may no longer be met.

For this reason, Article 5(7) of Regulation (EU) 2023/956 imposes a continuing obligation on every authorised CBAM declarant to notify the EPA, through the CBAM Registry, of any changes that may affect the authorisation decision. This enables the EPA to assess whether the conditions relating to financial or operational capacity continue to be met.

Examples of changes that must be notified 

The following changes typically need to be notified, because they relate to the information provided during the authorisation process: 

  • Identification and contact details of the authorised CBAM declarant. For example, name, legal form, registered address, contact person, EORI number.
  • Main economic activity carried out in the Union.
  • A change in the certification by the tax authority that the declarant is not subject to an outstanding recovery order for national tax debts.
  • Any serious infringement or repeated infringements of customs legislation, taxation rules, market abuse rules, the CBAM Regulation or its implementing or delegated acts, including any record of serious criminal offences relating to economic activity, occurring after the authorisation was granted.
  • Changes affecting the financial and operational capacity of the authorised CBAM declarant to fulfil its CBAM obligations.
  • Significant changes in the estimated quantity of imports, by type of goods, or the Member States of import. Such changes are particularly relevant where a guarantee is required, as they may lead to its adjustment (see below). 
  • The grant, modification or loss of authorised Economic Operator (AEO) status under Article 38 of Regulation (EU) No 952/2013.
  • Changes in the persons on whose behalf the authorised CBAM declarant is acting, where applicable (i.e. if you are an indirect customs representative acting on behalf of an importer, if the importer details change, you must notify the NCA of these changes)

This list is illustrative. Any other change in the information provided in the application that may influence the authorisation decision or its content must also be notified.

 

Guarantee Requirement

If an applicant for CBAM authorisation has not been established during the two financial years preceding the year in which the application is submitted, a guarantee must be provided pursuant to Article 17(5) of Regulation (EU) 2023/956.

The guarantee required is calculated based on the aggregated value of the number of CBAM certificates that the authorised CBAM declarant would be required to surrender for the quantity of goods included in the application for the current and next calendar year.

The guarantee provided shall be a bank guarantee, payable at first demand, by a financial institution operating in the Union or another form of guarantee which provides equivalent assurance. The guarantee will be released immediately after 30 September of the second year in which the authorised CBAM declarant has surrendered CBAM certificates.

For applicants for authorisation requiring a guarantee, the EPA will be in touch once your application has been submitted. Once authorisation is granted, the EPA will monitor the adequacy of the guarantee provided by authorised CBAM declarants based on the quantity of goods declared in customs declarations on an ongoing basis.

 

Importers of Electricity

In the case of electricity importers established in Ireland and importing to Ireland, the normal procedure for authorisation applies. In the case of electricity importers established in Ireland and importing via explicit capacity allocation to another Member State, authorisation will be granted by the NCA of the Member State of establishment, i.e. in Ireland.  In such cases, the following information is required for the application for authorisation, to be submitted via the AMM as part of the application; 

  • name, address and contact information
  • EORI number
  • Main economic activity carried out in the Union
  • Customs declaration for the relevant electricity import, for each interconnector.
  • An indication that capacity for the import of electricity has been allocated to that person and nominated for import & documents supporting the allocation and nomination

Importers within the scope of Article 5(4) of Regulation (EU) 2023/956 who have not yet obtained a CBAM account number are requested to include TARIC code Y195 in their customs declarations until they obtain a CBAM account number.