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Authorisation of CBAM declarants

Climate action

This initiative will set out the procedures and conditions for the authorisation of CBAM declarants and will specify the communication and procedures between the applicant, competent authority and the Commission, including format, deadlines and rules for identification of CBAM declarants for the importation of electricity.

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Public consultation

ID: 14116

Lobbying Activity

24 responses

German industry urges simplified CBAM authorization process

Bundesverband der Deutschen Industrie e.V., 27 Nov 2024

BDI requests that companies with trade security status be recognized as CBAM declarants. They also propose a hardship clause to avoid value chain interruptions after 2025.
This would lower administrative costs and prevent a stop of critical industrial imports.

EUROFER urges stricter screening for carbon border tax importers

The European Steel Association, 27 Nov 2024

EUROFER requests that importers demonstrate best efforts to source goods from manufacturers in the CBAM Registry. They also suggest registry use should count as an indication of good faith.
This would prevent importers from claiming low carbon emissions without having verified manufacturer data.
Unregistered foreign manufacturers may lose market access as importers face pressure to avoid them.

German Chamber of Commerce urges simplified CBAM registration

Deutsche Industrie- und Handelskammer, 27 Nov 2024

The DIHK calls for a radically simplified process to prevent small companies from failing. They suggest paying the border adjustment at customs clearance upon import instead of registering. Additionally, provisional authorisation should be possible for Authorised Economic Operators to ensure continuity.
This would lower compliance costs and ensure small firms remain in the import market.
Climate regulators lose precise emissions data if importers use generic standard calculation values.

Austrian Industry Group Calls for Simpler CBAM Registration Rules

Wirtschaftskammer Österreich, 25 Nov 2024

The group urges the reuse of existing data to simplify registration and requests faster approval times. They also propose a mandatory testing phase for the new IT registry to ensure system stability.
Austrian companies would reduce their administrative workload and costs associated with financial guarantees.
National regulators would face significant pressure to process applications under much tighter deadlines.

Eurometaux demands clearer rules for authorized CBAM declarant status

EUROMETAUX, 26 Nov 2024

Eurometaux calls for precise definitions of expert entities and clearer rules on application deadlines. They recommend establishing a mandatory minimum response time for companies facing authorization rejections.
Metal importers would gain greater legal certainty and avoid arbitrary response windows during applications.
National authorities would lose the discretion to impose extremely short response periods on applicants.

European Aluminium seeks CBAM declarant rules streamlined for AEO holders

European Aluminium AISBL, 27 Nov 2024

The organization requests clearer definitions of expert conclusions, transparent application deadlines, minimum response periods of 15 days for negative decisions, and exemptions for AEO-certified importers from duplicative financial capacity requirements and guarantee provisions.
This would reduce administrative burdens for their member companies holding AEO certification.

Cement industry urges stricter data requirements for CBAM importers

CEMBUREAU - The European Cement Association, 27 Nov 2024

The association wants importers to use data from third-country installations registered in the CBAM registry. They propose adding a criterion requiring applicants to import only from operators registered in the CBAM Registry.
This would ensure competing imports face the same carbon pricing as European cement producers.

Tata Steel Nederland calls for stricter screening of carbon importers

Tata Steel Nederland, 27 Nov 2024

TSN proposes requiring declarants to prioritize sourcing from registered manufacturers. They seek stricter controls to prevent the use of unverified emissions data.
This would prevent competitors from gaining an unfair advantage through inaccurate reporting.
Unskilled importers would find it harder to justify declaring lower carbon emissions.

Elia Group urges CBAM exemptions for electricity grid operators

Elia Transmission Belgium, 27 Nov 2024

Grid operators should not be treated as energy traders under the new rules. They request simplified financial capacity checks to avoid duplicating existing regulations.
This would reduce regulatory costs and avoid unnecessary administrative tasks for grid operators.

European Express Association seeks shorter CBAM approval timelines

European Express Association, 27 Nov 2024

The EEA requests shorter assessment periods for applications and a higher threshold for small shipments. They also advocate for more flexibility regarding detailed import value forecasting for logistics providers.
Streamlined processes would help businesses avoid trade disruptions and reduce high administrative compliance costs.
Regulatory authorities lose transparency when reporting requirements for indirect customs representatives are significantly eased.

IKEA Urges Centralised Reporting to Cut Carbon Border Costs

Inter Ikea Systems BV, 27 Nov 2024

IKEA proposes a single tool for filing reports across multiple European markets. They suggest simplified processes for trusted traders. They also want certain non-EU residents to act as declarants.
This would significantly reduce the administrative and financial burdens of managing multiple national accounts.
Third-party service providers lose business if importers no longer need external legal risk management.

Consultation response

Baker Hughes Holdings, 27 Nov 2024

Baker Hughes is a leading energy technology company that provides solutions for energy and industrial customers worldwide. We design, manufacture, and service transformative technologies to help take energy forward making it safer, cleaner, and more efficient for the people and the planet. While we…

CLECAT urges automatic carbon tax status for trusted traders

CLECAT - European association for forwarding, transport, logistic and Customs services, 27 Nov 2024

CLECAT recommends shortening application timelines and automatically approving companies with trusted certifications. They also seek exemptions for small-volume importers.
This would reduce administrative burdens and provide smaller companies with predictable costs.

National Grid urges simpler CBAM rules for electricity interconnectors

National Grid Commercial Holdings Limited, 27 Nov 2024

National Grid seeks simplified authorization for transmission operators and automatic recognition of their status. They recommend netting electricity flows to ensure importers pay only for physical volumes.
This would reduce administrative overhead and prevent costly financial guarantees for energy transmission firms.
Small competitors and new market entries face high costs and barriers to entry.

Carl Zeiss AG Urges Streamlined Carbon Border Tax Authorizations

Carl Zeiss AG, 25 Nov 2024

The company requests automatic authorization if deadlines lapse and a weight-based exemption. They argue mandatory reviews for every change create enormous effort for companies.
Reduced effort and discretionary enforcement would lower compliance costs and administrative burdens.
Climate transparency decreases if small imports are excluded from the carbon reporting system.

Japan Business Council seeks clarity on CBAM declarant procedures

Japan Business Council in Europe, 26 Nov 2024

The group seeks clarity on the content of applicant observations. They also request technical details for reactivating closed accounts.
Clearer rules would prevent redundant administrative steps and ensure stable global supply chains.
Ambiguous procedures risk trade disruptions that harm the resilience of global supply chains.

Italian SME group urges CBAM expansion to finished products

Confederazione Nazionale dell'Artigianato e della Piccola e Media Impresa, 25 Nov 2024

CNA requests expanding the regulation to include finished products to stop unfair competition. They also seek simplified reporting and support from trade associations.
This would protect European manufacturers from cheaper imports and reduce compliance costs.
Foreign exporters of finished goods would lose their current exemption from the carbon tax.

Dutch Logistics Group Urges Simplified CBAM Rules for Trusted Traders

Transport en Logistiek Nederland, 27 Nov 2024

Fenex requests automatic or simplified approval for trusted traders and clarity for indirect customs representatives. They argue current proposals create uncertainty for agents managing multiple importers across several Member States.
This would reduce regulatory duplication and lower compliance costs for established logistics firms.
Small businesses may lose access to affordable customs representation if requirements remain complex.

Consultation response

POSCO Co., Ltd, 22 Nov 2024

POSCO appreciates the opportunity to express its views on the draft Implementing Regulation on authorisation. Please find the attached for details.

Consultation response

Signify N.V., 27 Nov 2024

Thank you for the opportunity to comment on the implementing act on the authorized CBAM declarant status. We would like to ask you to consider the points listed in the attached document.

Consultation response

Union TLF Overseas, 27 Nov 2024

TLF Overseas est la fédération représentative des représentants en douane enregistrés français. A ce titre nos adhérents, seront potentiellement amenés à déposer en 2025 leur demande de candidatures pour devenir "déclarant MACF autorisé". Au regard de l'échéance du 1er janvier 2026, date à partir…

Fecc urges streamlined CBAM rules to protect small chemical firms

European Association of Chemical Distributors, 25 Nov 2024

Fecc calls for a streamlined authorization process and detailed guidelines to help companies comply. They suggest the Commission provide simplified procedures and financial support to assist smaller businesses.
This would help chemical distributors avoid high administrative costs and maintain competitiveness.
Small importers face financial losses and competitive disadvantages due to heavy compliance burdens.

Consultation response

Adolf Würth GmbH Co. KG, 27 Nov 2024

Wir bedanken uns für die Möglichkeit einer Stellungnahme zum CO2-Grenzausgleichssystem (CBAM) Zulassung von CBAM-Anmeldern (europa.eu). Unser Beitrag zur Konsultation zur Festlegung der Verfahren und Bedingungen für die Zulassung von CBAM-Anmeldern: Wir begrüßen die Initiative zur Festlegung der…

Consultation response

, 26 Nov 2024

With more than 3,600 members, the VDMA is the largest network organization and an important voice for the machinery and equipment manufacturing industry in Germany and Europe. The association represents the common economic, technical and scientific interests of this unique and diverse industry.…