CBAM Compliance for Irish Importers
The definitive period began on 1 January 2026, and this year's imports are already building a certificate bill that falls due in 2027. We help you get authorisation, supplier data and your first declaration right.
What is CBAM?
The Carbon Border Adjustment Mechanism (CBAM) is an EU regulation designed to prevent carbon leakage — where companies move production to countries with weaker climate policies. It applies a carbon price to imports of carbon-intensive goods, ensuring they face the same carbon costs as products manufactured within the EU under the Emissions Trading System (ETS).
For Irish importers of iron and steel, aluminium, cement and fertilisers, the definitive period started on 1 January 2026. Anyone bringing in more than 50 tonnes of these goods a year needs authorised CBAM declarant status, and the emissions embedded in this year's imports are paid for through CBAM certificates, which go on sale on 1 February 2027. The quality of your supplier data decides how many certificates you buy, so the work that controls the cost happens well before the invoice arrives.
What Importers Must Do
Authorised Declarant Status
Anyone importing more than 50 tonnes of CBAM goods a year must be an authorised CBAM declarant. In Ireland the EPA assesses applications, which are made through the EU's Authorisation Management Module.
Embedded Emissions Data
Every import needs emissions data behind it, ideally verified actual data from the non-EU producer. Where that data is missing, default values apply, and they are deliberately set high.
Annual CBAM Declaration
One declaration a year replaces the quarterly reports of the transitional period. The first, covering 2026 imports, is due by 30 September 2027.
CBAM Certificates
Certificates go on sale on 1 February 2027, priced from EU ETS auction prices. From 2027, declarants must hold certificates covering at least 50% of the emissions embedded in their year-to-date imports.
Covered Sectors
CBAM applies to imports in six product categories. The 50-tonne annual exemption covers the first four combined, but not hydrogen or electricity.
Iron & Steel
Hot-rolled, cold-rolled and coated steel, tubes, pipes, fixings and iron products.
Aluminium
Unwrought aluminium, aluminium bars, rods, profiles, wire, plates, and foil.
Cement
Clinker, Portland cement, aluminous cement, and other hydraulic cements.
Fertilisers
Nitrogen-based fertilisers including urea, ammonium nitrate, and mixed fertilisers.
Hydrogen
Imported hydrogen, which is not covered by the 50-tonne exemption.
Electricity
Imported electricity, which follows its own rules and also sits outside the 50-tonne exemption.
CBAM Timeline
Transitional Period
Quarterly emissions reports, with no certificates to buy.
Definitive Period Begins
Importers above 50 tonnes a year need authorised declarant status, and every tonne imported starts building a certificate liability.
Certificate Sales Open
Certificates covering 2026 imports go on sale, priced from EU ETS auction prices.
First Annual Declaration
The declaration for 2026 imports is due by 30 September, with the matching certificates surrendered alongside it.
CBAM Questions We Hear Most
Do I need to register for CBAM in Ireland?
Yes, if you import more than 50 tonnes of iron and steel, aluminium, cement and fertilisers combined in a calendar year. You apply for authorised CBAM declarant status through the EU's Authorisation Management Module, and the EPA assesses the application. At or below 50 tonnes you are exempt, but you need records that show you stayed below it.
When do CBAM certificates have to be paid for?
Certificates go on sale on 1 February 2027 and cover the emissions embedded in goods imported during 2026. They are surrendered with the first annual declaration, due by 30 September 2027. From 2027, you must also hold certificates covering at least 50% of the emissions in your year-to-date imports.
What happens if my suppliers cannot give me emissions data?
Default values apply instead. They are set deliberately high, so a declaration built on defaults usually means buying more certificates than verified supplier data would require. Starting supplier engagement early is the most effective way to control the cost.
What are the penalties for getting CBAM wrong?
Failing to surrender the required certificates attracts a penalty of EUR 100 per tonne of embedded emissions, and paying it does not remove the obligation to surrender the certificates. Importing above the 50-tonne threshold without authorisation can cost up to five times that rate.
Your 2026 imports are already on the clock.
The declaration due by 30 September 2027 will be built on the supplier data you collect this year. Talk to us about your CBAM exposure and what needs doing before certificates go on sale.