Introduction: A Bottleneck on the Buyer’s Side
From 2026, only an Authorised CBAM Declarant may import covered goods into the EU. That concentrates the obligation on your EU customer — and makes your data-readiness a condition of staying their supplier.
Much of the CBAM conversation focuses on the producer’s emissions. But the import itself is now gated. Since the definitive period began, only an Authorised CBAM Declarant may import the covered goods (iron & steel, aluminium, cement, fertilisers, hydrogen, electricity). Importers above the 50-tonne threshold had to apply for that status (applications by 31 March 2026, with a grace period to keep importing pending the decision). This is a different bottleneck from the shortage of verifiers — and it sits on the buyer’s side.
Why It Becomes Your Problem
The authorised declarant — your EU customer — carries the declaration, the certificate cost and the paperwork. Their cost depends directly on the data you supply: verified actual values keep it down, missing data forces them onto punitive defaults. So from the buyer’s chair, a supplier divides into two kinds:
- One who is registered as a third-country operator, hands over verified emissions data, and makes the CBAM declaration easy and cheap.
- One whose data is missing or messy, who pushes the importer onto high default values and extra work.
In a tight market, the second supplier is the one that gets dropped. Not because of the product — because of the friction they add to the buyer’s compliance.
What to Do as a Non-EU Supplier
- Register in the CBAM Registry’s third-country operator module so your data can reach any EU customer.
- Prepare verified emissions data under the CBAM methodology, so your importer can use actual values (see what CBAM actually costs).
- Make yourself the easy choice: a supplier who simplifies the buyer’s declaration is a supplier they keep.
How EPD Polska / Multicert Can Help
We help non-EU producers register, prepare verification-ready data, and become the low-friction supplier their EU customers want to keep. Contact us before your buyers start choosing on CBAM-readiness.
FAQ
Can any importer still bring in covered goods?
No. In the definitive period only an Authorised CBAM Declarant may import the covered goods above the 50-tonne threshold; importers had to apply for authorisation.
I am the producer, not the importer — why does this affect me?
Because the importer’s cost and effort depend on your data. If you make their declaration hard, you become the easy supplier to replace.
Is this the same as the verifier shortage?
No. The verifier shortage is about who can verify your data; this is about who is allowed to import and how your data quality affects them. Both point to the same fix: get verification-ready early.