From 1 January 2026, only authorized declarants will be able to import goods covered by the CBAM mechanism into the European Union. Here's a comprehensive guide to the new requirements and procedures.

What is CBAM and why is it important?

The Carbon Border Adjustment Mechanism (CBAM) is the EU's carbon border adjustment mechanism. Its primary goal is to establish a price on CO₂ emitted during the production of carbon-intensive goods entering the EU and to encourage cleaner industrial production in non-EU countries.

This mechanism is a key element of the EU's Fit for 55 package and is intended to prevent so-called carbon leakage – i.e., the transfer of high-emission production outside the EU in order to avoid the costs associated with the EU ETS system.

Key change from January 1, 2026

From 1 January 2026, goods covered by the CBAM mechanism may only be imported into the customs territory of the Union by an authorised CBAM declarant (UZ CBAM).

This is a fundamental change compared to the transition period (2023-2025), during which importers were only required to submit reports. Starting next year, importing CBAM goods above certain thresholds without the appropriate status will be prohibited.

Who needs to apply for UZ CBAM status?

The application for the status of authorized CBAM applicant is submitted by:

Import established in an EU Member State - before the import of goods into the customs territory of the Union
Indirect customs representative – if the importer has appointed such a representative and the latter agrees to act as the CBAM UZ

Exception: 50 tonne threshold

Importers they don't have to have UZ CBAM status if the net mass of CBAM goods imported in a given calendar year does not exceed 50 tonnes in total. This applies to all imports made into the customs territory of the European Union.

Note: The 50-ton threshold does NOT apply to electricity and hydrogen imports. CBAM obligations apply to these products regardless of the import quantity.

How to apply for UZ CBAM status?

Step 1: Register on PUESC

Access to the CBAM register requires authorization on the Electronic Services Platform for Tax and Customs (PUESC). If you haven't yet registered for access to the CBAM register, register immediately.

Good news: Importers who already have access to the CBAM transitional register and have registered the CBAM Register Access permission will be granted access to the CBAM reporting portal automatically.

Step 2: Submitting an application

The application for status is submitted electronically on the EU applicant portal CBAM. Access to the portal is via PUESC.

The application process will start on December 1, 2025.

Step 3: Waiting for the decision

The body competent to consider the application and grant the status is Director of the Tax Administration Chamber in PoznańThe authority has 120 days to grant UZ CBAM status.

Import while waiting for a decision

From January 1, 2026, you can import CBAM goods above the 50-ton threshold if you have applied for UZ CBAM status. Until the process of granting this status is completed, the importer may import CBAM goods based on the submitted application.

Condition: The application must be submitted no later than 31 March 2026 and before the CBAM goods are imported into the customs territory of the Union.

CBAM Guarantee – when is it required?

The importer or his indirect customs representative must provide a guarantee if he complies with oba the following conditions:

He submitted an application for the status of UZ CBAM
Has been operating for less than two financial years preceding the year in which the application was submitted

The provision of a guarantee in such a case is mandatory in order to demonstrate the financial and operational capacity to meet the obligations arising from the CBAM Regulation.

The guarantee is submitted to the body to which the application for UZ CBAM status was submitted (the Director of the IAS in Poznań). The same body monitors and releases the guarantee.

Key dates to remember

December 1, 2025 – launching the process of submitting applications for the UZ CBAM status
January 1 2026 – entry into force of the obligation to have the UZ CBAM status for importers of CBAM goods above the threshold of 50 tonnes
31 March 2026 – the final deadline for submitting an application for importers who wish to benefit from the possibility of importing based on the submitted application

What should you do now?

Check Are your imported products subject to CBAM (cement, iron and steel, aluminum, fertilizers, hydrogen, electricity)
Estimate Annual import volume – are you over the 50 tonne threshold?
Sign up on PUESC and obtain the Access to the CBAM register permission, if you have not done so already
Prepare documentation necessary to submit an application
Consider do you need a CBAM guarantee

Summary

The introduction of the requirement to be an authorized CBAM declarant is another step in implementing EU climate policy. This means new administrative obligations for importers, but also an opportunity to streamline processes related to the import of high-emission goods.

The key to success is proper preparation – the sooner you start the procedure for obtaining UZ CBAM status, the smoother the transition period will be.

Do you need support in the process of obtaining UZ CBAM status? Contact us – we will help you through all stages of the procedure and prepare the necessary documentation.

Useful sources

Legal basis

Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 establishing a CO₂ border adjustment mechanism (OJ L 130, 16.05.2023, p. 52), as amended by Regulation (EU) 2025/2083 of 8 October 2025