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Requirement · DECL-04Identify in the authorisation application, by EORI or national identification number, every person on whose behalf the applicant acts.
Applicants for authorised CBAM declarant status acting on behalf of others must comply, and it sits in an act that is partly law and partly a proposal.
Why it matters
The act this comes from is partly law in force and partly a proposal that can still change.
- It is Art. 1(4), replacing point (h) of Art. 5(5) of Regulation (EU) 2023/956, in the CBAM extension — downstream goods and anti-circumvention. as of 2026-08-14
- The act gives its timing as: from entry into force (third day after publication), Art. 2. as of 2026-08-14
- It names no industry: it applies across the economy rather than to one of them. as of 2026-08-14
- Compliance is checked by competent authority, one-off. as of 2026-08-14
The rule
New — no predecessor
Trigger
application for authorisation as a CBAM declarant on behalf of other persons
Obligation
Identify in the authorisation application, by EORI or national identification number, every person on whose behalf the applicant acts.
Who is affected
Addressee
Applicants for authorised CBAM declarant status acting on behalf of others
Class
Businesses
Sectors
No sector named — applies by size or activity
Applies
from entry into force (third day after publication), Art. 2
Burden drivers
D1 · D3 — 2 of 7 marks fire on this provision.
Source text
Verbatim
‘(h) EORI number or other national identification number, names and contact information of the persons on behalf of whom the applicant is acting, if applicable.
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