I missed the 31 March 2026 CBAM authorisation deadline — what now?

Short version. If you missed the 31 March 2026 deadline to apply as an authorised CBAM declarant, you have three options for continuing to import CBAM goods into the EU after 1 January 2026: appoint an Indirect Customs Representative who is already authorised, submit a late application and pause CBAM imports while it processes, or stop importing those goods entirely. Continuing to import without either an authorised declarant status or an ICR means your goods are held at customs.

The deadline that just passed

Per Regulation (EU) 2023/956, every EU importer of cement, iron and steel, aluminium, fertilisers, electricity, or hydrogen above the 50-tonne annual threshold per Implementing Regulation (EU) 2025/2083 must have either:

• their own authorised CBAM declarant status, or
• an authorised Indirect Customs Representative acting on their behalf.

The original deadline to apply as an authorised declarant was 31 March 2026. The European Commission reported ~12,000+ applications were submitted by the deadline; ~4,100 were processed and approved by 1 April. A significant tail of importers either applied late, applied to the wrong NCA, or didn't apply at all.

From 1 January 2026 (the start of the definitive period) until the first surrender on 31 May 2027, importers without authorisation cannot release CBAM goods into free circulation. Customs authorities will hold the consignment at the port until an authorised party is on the entry.

Path 1 — appoint an Indirect Customs Representative (recommended)

This is the fastest path back to operating. An ICR is a customs representative authorised under Article 18(2) of the Union Customs Code who acts in their own name but on behalf of the importer. For CBAM, the ICR must themselves be an authorised CBAM declarant — many freight forwarders and customs brokers applied for this exact purpose.

What this looks like in practice:

• You sign an indirect-representation mandate with the ICR.
• The ICR submits the CBAM declaration on your behalf, becomes the legal declarant of record, and (where applicable) surrenders certificates.
• You reimburse the ICR for certificate costs, plus a service fee. Typical 2026 pricing: €500–2 500 setup, €25–150 per shipment, plus certificate cost at pass-through.
• Liability split: the ICR is jointly and severally liable with you for the declaration. If the data is wrong, both parties are on the hook to the NCA. Read the mandate carefully.

Path 2 — submit a late application

National Competent Authorities continue accepting applications past 31 March. Processing time is now 3–6 months in most member states (vs 2–4 weeks during the original cohort window). Some practical notes:

• Apply via the right NCA. Your NCA is determined by your country of establishment, not by where the goods land. A German importer applies to DEHSt, a French importer to ADEME, a Spanish importer to MITECO, etc. See the full per-country NCA index for your country's contact details, application steps, and portal URL.
• Prepare the supporting documents up front. Authorisation requires proof of EU establishment, EORI number, financial guarantees in some MS, and a 2-year compliance history. Missing documents are the #1 reason late applications get bounced.
• Don't import until the application is approved. "Pending application" is not a defence under Implementing Regulation (EU) 2025/2549. Your goods will still be held without an authorised declarant on the entry.

Realistic timeline: if you apply this week, expect approval somewhere between Q3 2026 and Q1 2027. For most importers that's incompatible with continuing to ship in the meantime, which is why Path 1 is the recommended first move.

Path 3 — stop importing CBAM goods

If your CBAM-scope volume is small and the ICR overhead doesn't pay back, you can simply stop importing those goods and source domestically (or from another EU member state) until your own authorisation comes through. Run our CBAM scope checker on your CN codes — if they're outside the 6 sectors of Annex I (cement, iron/steel, aluminium, fertilisers, electricity, hydrogen), CBAM doesn't apply at all and you keep operating normally.

What NOT to do

• Don't import without authorisation thinking you'll "catch up later". The customs hold is automatic and the shipment doesn't release until an authorised declarant ID is on the entry. Storage fees at the port accumulate fast.
• Don't reclassify your CN codes to fall outside scope. Misclassification is fraud under EU customs law and the penalties (back-duty plus 3–5× the certificate price for the surrender period per Article 28 of Reg 2023/956) compound on top of customs misclassification penalties.
• Don't use a customs broker who isn't a CBAM-authorised declarant. A regular broker can file your customs declaration but cannot file the CBAM declaration. They need their own authorised declarant status to act as ICR.

Quick decision tree

Three questions to land on the right path. Or skip these and use the CBAM authorisation decision tree on /cbam — it asks the same things and surfaces your NCA's contact link directly.

1. Are you EU-established? If no — your only path is an EU-based ICR. You can't be a self-declarant from outside the EU.
2. Did you apply by 31 March 2026? If yes and the application is pending — chase the NCA, do not import in the meantime, consider a temporary ICR for ongoing volumes.
3. Do you have an account number from your NCA? If yes — you're authorised, business as usual. If no — assume not yet authorised and treat as Path 1 or 2.

What we offer for forwarders + brokers reading this from the other side

If you're a customs broker or freight forwarder who already applied for CBAM authorisation, you're in the right place at the right time. Tens of thousands of importers are looking for an ICR right now and they don't know where to find one. The market clearing rate for ICR services has roughly tripled since 1 April.

We built tooling specifically for this workflow:

• ICR client roster — track your importer-clients, EORIs, default countries, and per-client preferences.
• Bulk CSV processor — upload a month's shipments for any client, get the CBAM calculation per row plus the spreadsheet for your records.
• Per-shipment cost report PDFs — tamper-evident, cited, branded with your firm's name (white-label option). Hand to the importer-client as the basis for invoicing certificate costs.

Read our companion post: How to become a CBAM Indirect Customs Representative for your import clients.

Sources

• Regulation (EU) 2023/956 — establishing the CBAM, Articles 4, 5, and 28 (the authorised-declarant requirement and the penalty regime). Source URL: eur-lex.europa.eu/eli/reg/2023/956/oj/eng.
• Implementing Regulation (EU) 2025/2083 — the 50-tonne threshold for CBAM scope. Source URL: eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202502083.
• Implementing Regulation (EU) 2025/2549 — declarant status, account number, application process. Source URL: eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202502549.
• EU Commission CBAM main page (with the Implementing Acts package announcements): taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en.
• Updated National Competent Authorities list (5 January 2026 PDF): EU Commission NCA list.

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