Snippets from the “CBAM Declarant Portal”
A major shift is coming for importers, and the clock is ticking. From January 1, 2026, importing CBAM-covered goods without proper authorization will no longer be an option. Failure to comply could mean halted shipments, heavy fines, and significant business disruptions. But what does this process involve, and how can you stay ahead of the game?
The application window officially opens on March 28, 2025. According to Danish Business Authority (Erhvervsstyrelsen) and The Swedish Environmental Protection Agency (Naturvardsverket).
UPDATE: The European Commission’s Implementing Regulation (EU) 2025/486, published on March 17, 2025, sets strict new CBAM compliance rules.
Who Needs Authorization?
Importers based in Denmark who bring in CBAM-covered goods above a certain threshold must act now. The Danish Business Authority (Erhvervsstyrelsen) has set strict requirements: If you import over EUR 150 worth of these goods, authorization is mandatory. A proposed simplification suggests a 50-ton annual limit—once this threshold is met, you must comply. Indirect customs representatives are also required to obtain authorization, regardless of volume. Though delegation of tasks is possible, the responsibility remains solely on the importer’s shoulders.
For small importers uncertain about whether they will be affected, authorities recommend waiting until mid-2025 before making a move. However, applications submitted before November 2025 will still be processed before the year’s end.
The Step-by-Step Process
The application window officially opens on March 28, 2025, and time will be critical. Here’s what you need to do:
- Submit your application through the CBAM registry
- Wait for Erhvervsstyrelsen’s decision on approval
- If approved, your authorization will be logged in the registry
- If rejected, you will be notified with an option to appeal
How Long Will It Take?
- Standard review: 120 days
- Early applications (before June 15, 2025): 180 days
- Small importers (if simplification isn’t adopted by November 1, 2025): 60 days
Submitting Your Application
When the system goes live, you will find all necessary links and guidance on the Danish Business Authority’s website. Access requires an EORI number, which must be obtained through the Danish Customs Agency. Your company will also need to assign specific employee roles to complete the application process efficiently. Additionally, Danish-language instructional videos will be made available to guide you.
What You’ll Need to Provide
Your application must include:
- Company role: Acting on your own behalf or as a customs representative
- Contact information: Name, email, and phone number
- Company details: EORI number, name, address, and industry classification
- Import estimates: Expected import volume and value for 2025 and 2026
- Tax compliance confirmation: A declaration from tax authorities confirming no outstanding debts
- Compliance history: A sworn statement that the company and its leadership have not violated customs, tax, or CBAM regulations in the past five years
- Financial details: Revenue, financial standing, and liabilities
- Consent for the Business Authority to access your financial records
How the Authorities Will Evaluate Your Application
The Danish Business Authority will assess:
- Whether your company is established in Denmark and has an active business address
- How long your business has been operating (newer businesses may need financial security)
- Consistency of your application data with official business registry information
- Your company’s overall regulatory compliance
- Your company’s risk level, assessed through an internal risk model
Financial Security: A Must for New Businesses
If your company was founded less than two years ago, you will be required to provide financial security. This security, which must be backed by an EU-based bank guarantee, covers two years of CBAM certificate costs. Compliance over time will lead to the release of the security deposit. However, should your import levels increase, additional guarantees may be required.
How Long Does Authorization Last?
Unlike other regulatory permits, CBAM authorization does not expire. However, if a company fails to maintain compliance, the Danish Business Authority has the right to revoke its authorization.
The Consequences of Non-Compliance
What happens if you fail to obtain authorization by January 1, 2026? The consequences are severe:
- Shipments blocked: Danish Customs will stop unauthorized CBAM imports
- Long approval times: It could take up to 120 days to process your authorization, leaving your goods stranded
- Fines: The simplification proposal introduces hefty penalties, estimated at three to five times the fine for failing to submit the required number of CBAM certificates (approx. EUR 100 per certificate)
Stay Informed Every Step of the Way
Once your application is submitted, you’ll receive an official confirmation via e-Boks. From 2025 onward, applicants will receive status updates every three weeks. Once a decision is made, it will be recorded in the CBAM registry, and you will receive a notification.
With the deadline fast approaching, businesses must act decisively. The Danish Business Authority is gearing up for an influx of applications—make sure yours is at the top of the list. Keep your business compliant, avoid costly fines, and ensure uninterrupted imports by preparing now.
Sources:
Danish Business Authority (Erhvervsstyrelsen)
The Swedish Environmental Protection Agency (Naturvardsverket)
DI (Dansk Industri)