Why importers need to know this now?

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An Indian steel exporter recently received an email from its German buyer asking whether the shipment was covered under "Registry status." The exporter had not heard the term before and had no clear answer to give.
That kind of question is becoming more common. From September 1, 2026, the EU opened CBAM Registry access to accredited verifiers, a step that has pushed this system into sharper focus for exporters outside the EU who supply CBAM-covered goods.
This article explains what the CBAM Registry actually is, who uses it, and why understanding it is the first step to answering questions like the one above.
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The Carbon Border Adjustment Mechanism, or CBAM, is the European Union's system for pricing the carbon embedded in certain imported goods, including iron, steel, aluminium, cement, and fertiliser. The CBAM Registry is the digital infrastructure that sits underneath this system. It is a centralised IT platform, operated by the European Commission under Regulation (EU) 2023/956, where the EU records who is authorised to import CBAM goods and tracks the data those imports generate.
Three terms matter here. A declarant is the party, usually the EU-based importer of record, who takes on the legal obligation to report and eventually pay for embedded emissions. Embedded emissions are the greenhouse gases released in producing the imported good, measured per tonne of product. A CBAM certificate is the financial instrument declarants will purchase from 2027 onward to cover those emissions. The Registry exists to give the European Commission and national customs authorities a single, verifiable record of all three: who is authorised, what they are importing, and what emissions are attached to it.
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Authorisation happens at the level of the individual importer, not the shipment. An EU-based company applies to its national customs authority for the status of authorised CBAM declarant. Once approved, that status and the company's details are entered into the Registry under Regulation (EU) 2023/956. From this point, the Registry becomes the record system the declarant uses for every later CBAM obligation, including emissions reporting and, from 2027, the purchase of CBAM certificates.
Registration is limited to authorised CBAM declarants, almost always the EU importer, not the non-EU exporter producing the goods. An Indian steel manufacturer, for example, does not open a Registry account; its EU customer does. This is a narrow but important point: the Registry's declarant-registration function is separate from verifier accreditation, which is a different process, and separate from any general market access requirement.
Authorised declarants use the Registry to submit CBAM declarations reporting the embedded emissions in their imports, based on supplier emissions data and the methodology set out in Regulation (EU) 2023/956. From 2027, the Registry also becomes the point where declarants purchase and surrender CBAM certificates to cover those emissions. Accredited verifiers, authorised under Regulation (EU) 2025/2083, confirm the accuracy of emissions data before it is submitted, which is why verifier accreditation and Registry access are connected but distinct processes.
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A company or its customs broker having a login to the Registry does not by itself confirm CBAM authorisation. Authorisation is a status granted by a national customs authority and then reflected in the Registry, not the other way around. Exporters should verify this status directly with their EU buyer rather than assuming Registry visibility settles the question.
Since exporters themselves do not hold Registry accounts, the practical step is confirming that the EU importer receiving their goods has completed authorisation and is prepared to report the required emissions data. Delays on the importer's side can affect shipment terms even when the exporter's own production data is ready.
Registry registration is the foundation record on which later obligations, including verifier-checked emissions reports and certificate purchases, are built.
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The CBAM Registry is best understood as the record-keeping backbone of the carbon border adjustment mechanism, not a compliance milestone in itself. It confirms who is authorised to import CBAM goods and holds the emissions data tied to those imports.
For exporters outside the EU, the practical takeaway is straightforward: know your buyer's authorisation status, since the Registry entry belongs to them, and treat it as the first checkpoint in a longer compliance chain that runs through certificate purchases from 2027.
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It is the European Commission's central IT system for recording authorised CBAM declarants and CBAM-related transactions.
Authorised CBAM declarants, generally EU importers, along with accredited verifiers and national customs authorities in their respective roles.
Yes, any EU company acting as an authorised CBAM declarant must be registered before it can report emissions or, from 2027, purchase CBAM certificates.
No, Registry access reflects an authorisation status already granted by a national customs authority; it does not grant that status itself.
Registered declarants move on to emissions reporting and, from 2027, certificate purchases, with verifier accreditation playing a role along the way.
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