Since the end of March, companies in Germany that import emission-intensive goods from a third country into the EU can apply for the status of an approved CBAM declarant. The "Carbon Border Adjustment Mechanism" affects iron, steel, cement, aluminium, electricity, fertilizers, hydrogen as well as upstream and downstream products. "The application should be submitted by the beginning of September at the latest,” advises Jan-Eike Boonstoppel, Business Consultant at a. hartrodt Germany. The registration requirement applies from January 1, 2026. "By then, an importer without approval as a CBAM declarant will no longer be able to import the goods, and storage fees may be imposed," he warns.
Identify supplier values for electricity consumption and more
The CBAM is part of an EU regulation from May 10, 2023, which is intended to create a Carbon Border Adjustment Mechanism. Since the end of 2023, affected companies have been subject to the CBAM reporting obligation, which requires "a lot of detailed work" according to Jan-Eike Boonstoppel: "You have to rely on information from third countries, which is often difficult." If supplier figures on electricity consumption, for example, cannot be verified, standard values apply. However, the reporting obligation has not yet had any impact on customs clearance.
Electronic application at the German Emissions Trading Authority
In Germany, importers must apply electronically to the German Emissions Trading Authority (DEHSt) for the status of an approved CBAM declarant. "The prerequisite for accessing the portal is an ELSTER certificate for the electronic tax declaration," says Jan-Eike Boonstoppel, naming one hurdle. While the ELSTER certificate is available "very quickly" according to him, it takes up to 180 days for the approved CBAM declarant, and up to 120 days from June 15. "From January 1, 2026, affected customers must also communicate their registration number to us when placing an order for customs clearance," he says. For further information, he recommends contacting the local chambers of industry and commerce.
The 27 EU countries each have national offices for the application to become an approved CBAM declarant. Jan-Eike Boonstoppel hopes "that all customers will respond in time". Sustainability is also an integral part of a. hartrodt's corporate strategy.