CBAM Romania —
Guide for Importers
Since 1 January 2026, every EU company importing steel, aluminium, cement, fertilisers, electricity or hydrogen from outside the EU must be authorised as a CBAM declarant and report the embedded emissions of imported products. This guide explains step by step how to register, which thresholds apply, and what documentation an EU-based importer must prepare.
Who is an "importer" under CBAM?
CBAM draws an important legal distinction between a plain "importer" and the "authorised CBAM declarant" — the party legally responsible for reporting and surrendering certificates. The distinction depends on where the importing company is established:
| Situation | What it means for the CBAM obligation |
|---|---|
| EU-established importer | Can register directly as an authorised CBAM declarant and take on reporting and certificate purchase alone. |
| Non-EU-established importer | Cannot register directly — must appoint an indirect customs representative established in the EU, who becomes the legally responsible CBAM declarant. |
| Direct customs representative | Acts on the importer's behalf at customs, but does not become the CBAM declarant — the obligation stays with the importer. |
| Multi-EORI groups | Each legal entity with its own EORI code must register and report separately, even within the same corporate group. |
The de minimis threshold — who is exempt from CBAM
The Omnibus package (Reg. (EU) 2025/2083) raised the de minimis threshold to 50 tonnes per year, cumulative across all CBAM products imported by the same company within a calendar year. Below this threshold, importers are exempt from registering as an authorised CBAM declarant and from purchasing certificates.
Watch out for "occasional" importers: The threshold is cumulative per calendar year, not per shipment. If a company exceeds 50 tonnes during the year, the registration obligation becomes retroactive for the entire volume imported that year, not just the excess.
How to register as an authorised CBAM declarant
Registration takes place through the EU CBAM registry, in coordination with the competent national customs authority — in Romania, the Romanian Customs Authority, working with ANAF.
- 01
Check whether your products fall under CBAM
Identify the CN codes of your imported products and check them against the 6 covered sectors (steel/iron, aluminium, cement, fertilisers, electricity, hydrogen).
- 02
Submit the application via the EU CBAM registry
The application for authorised CBAM declarant status is submitted electronically through the EU registry and routed to the competent customs authority in the member state of establishment.
- 03
Provide EORI, fiscal and customs data
You will need your EORI code, fiscal identification data, import activity history and, in some cases, financial guarantees.
- 04
Wait for approval from the competent authority
The customs authority reviews the application and grants authorised CBAM declarant status. Only authorised declarants may legally import CBAM products after the transition period ends.
- 05
Manage your status throughout the year
From 2027, the declarant must comply with the quarterly minimum certificate holding rule (50%, reduced from 80% via Omnibus), checked on 31 Mar, 30 Jun, 30 Sep and 31 Dec.
Annual obligations of an authorised CBAM declarant
Collecting supplier data
Request verified embedded emissions data from non-EU suppliers, per the Reg. (EU) 2023/1773 methodology.
Calculating embedded emissions
Combine direct and indirect emissions (where applicable) using actual data, country default values, or EU default values +120%.
Record-keeping
Keep supporting documentation per product line for a minimum of 4 years, separated by CN code.
Annual declaration by 30 September
File the annual CBAM declaration with imported volumes and embedded emissions for the previous year.
Purchasing and surrendering certificates
Purchase CBAM certificates matching declared emissions and surrender them through the centralised platform.
Third-party verification
Above certain volume thresholds, emissions data must be verified by a body accredited under EN ISO 14065:2020.
Purchasing CBAM certificates — what you need to know
The centralised CBAM platform opens on 1 February 2027. Until then, no declarant can actually purchase certificates — including for emissions generated in 2026. The certificate price tracks the weekly average EU ETS allowance price (currently €60–90/tonne CO₂), reduced by any carbon price the producer already paid in the country of origin.
Quarterly holding rule (from 2027): On 31 March, 30 June, 30 September and 31 December, the declarant must hold at least 50% of the certificates corresponding to emissions imported since the start of the year (threshold reduced from 80% via the Omnibus package).
To quickly estimate how many certificates you will need and the approximate cost, use our CBAM calculator — enter the imported quantity and the carbon price already paid, and get an instant estimate.
Indirect customs representative — when you need one
If your importing company is not established in the EU, CBAM rules do not allow you to register directly as a declarant. You must appoint an indirect customs representative, established in an EU member state, who takes on the legal responsibility for the declaration and certificate payment on your behalf.
- Non-EU companies selling directly to EU end customers, without their own European subsidiary or branch.
- Distributors importing on behalf of multiple non-EU suppliers, consolidating volumes from several sources.
- Cross-border e-commerce "merchant of record" structures, where the seller is outside the EU but final delivery goes to European consumers.
Special cases for importers
Mixed supply chains
The CBAM obligation applies only to the CN codes covered by the Regulation — keep separate records per product line, not per supplier.
Multi-entity groups
Each entity with its own EORI code must register and report separately, even within the same corporate group.
Occasional imports
If you exceed the 50-tonne threshold during the year, the reporting obligation becomes retroactive for the entire imported volume, not just the excess.
Penalties for non-compliance
€100 per unsurrendered certificate (amount indexed annually to inflation), uncapped. Importers who are not authorised as CBAM declarants risk having their goods held at customs and losing the right to import CBAM-covered products into the EU.
Frequently asked questions about CBAM for importers
Who must register as an authorised CBAM declarant?
Any EU company importing CBAM-covered products (steel, aluminium, cement, fertilisers, electricity, hydrogen) above the de minimis threshold must be authorised as a CBAM declarant. Non-EU importers must appoint an indirect customs representative established in the EU, who becomes the legally responsible declarant.
What happens if I import under 50 tonnes per year?
Below the de minimis threshold of 50 tonnes per year (cumulative, per the October 2025 Omnibus package), you are not required to register as a CBAM declarant. Watch out: if you exceed the threshold during the year, the obligation becomes retroactive for the entire volume imported that year, not just the excess.
Can I buy CBAM certificates in 2026?
No. The centralised CBAM platform for certificate purchases opens only on 1 February 2027. Certificates for emissions generated in 2026 will be purchased retroactively starting from that date. However, the obligation to register as an authorised declarant is already active since 1 January 2026.
What is an indirect customs representative and when do I need one?
It is an entity established in the EU that takes on the legal responsibility of CBAM declarant on behalf of a non-EU importer. It is mandatory if your importing company is not established in the EU — a direct customs representative, who only acts on your behalf at customs, cannot fulfil this role.
What penalties does an unauthorised importer risk?
The penalty is €100 per unsurrendered CBAM certificate (amount indexed to inflation), uncapped. Unauthorised importers also risk having their goods held at customs and losing the right to import CBAM products into the EU.
How do I calculate how many CBAM certificates I need to buy?
The number of certificates corresponds to the tonnes of embedded CO₂ not already covered by a carbon price paid at origin. Use the CarbonDRI CBAM calculator for an instant estimate of the number of certificates and the approximate cost.
Need help registering as a CBAM declarant or calculating certificates?
CarbonDRI helps you identify your exact obligations, calculate embedded emissions, and prepare the documentation needed to register as an authorised CBAM declarant.
Request CBAM Consulting →See also: CarbonDRI CBAM Service · CBAM Exporters Guide · CBAM Calendar 2026-2027