The European Commission simplifies the procedures for obtaining the status of an authorised CBAM notifier

On December 10, 2025, the European Commission published a new implementing regulation amending the rules for applying for CBAM Authorized Declarant status. The most important change? You can import CBAM goods even while waiting for a decision on your application.

Temporary import for applicants

This is a key change for all companies applying for UZ CBAM status. Under the new Article 4(6), if your application is "registered" in the CBAM Register by March 31, 2026, you may temporarily continue importing CBAM goods until a decision is issued.

In practice, this means you don't have to suspend your import activities while waiting for your application to be processed. However, remember – the application must be registered, not just submitted. Make sure all required documents are complete.

Less paperwork – digital data collection

The new Article 4(7) introduces the possibility for the competent authority to digitally retrieve data directly from other national authorities. The condition? Your consent or national law that allows this.

What does this mean for importers? Potentially fewer documents need to be submitted. The authority examining the application can collect the necessary information itself instead of requiring it from you.

Optional consultations instead of mandatory ones

Previously, the consultation procedure with other authorities (e.g., customs, tax) was mandatory. Now it is becoming optional. The competent authority "may" initiate it, but is not required to do so.

Additionally, the method of calculating deadlines has been changed – from business days to calendar days. The maximum consultation time is 15 calendar days, with the possibility of extending it by another 15 days in justified cases.

Special rules for status revocations in 2026

Because the purchase of CBAM certificates will not begin until 2027, the regulation introduces transitional provisions. If the UZ CBAM status is revoked in 2026, the obligation to surrender CBAM certificates must be fulfilled by February 15, 2027.

What does this mean in practice?

The European Commission is clearly responding to importers' concerns about deadlines and procedures. The new regulations:

• They eliminate the risk of import suspension while waiting for a decision
• They reduce the administrative burden on applicants
• They speed up the application processing process

If you are planning to apply for UZ CBAM status, please do so as soon as possible – but please ensure your application is complete and becomes “registered” before March 31, 2026.

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Need help preparing your CBAM Authorized Reporter application? Contact Green Reporting: office@greenreporting.eu