CBAM Compliance
The EU Carbon Border Adjustment Mechanism is transforming how importers account for embedded emissions. We handle the full complexity — from calculation to compliance.
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 and EU importers of steel, aluminium, cement, and fertiliser, CBAM means mandatory reporting of embedded emissions and, from 2026, the purchase of CBAM certificates priced at the EU ETS carbon price. Getting this wrong means financial penalties, supply chain disruption, and regulatory risk.
What Importers Must Do
Embedded Emissions Reporting
Importers must calculate and report the greenhouse gas emissions embedded in CBAM-covered goods — including direct emissions from production and, in some cases, indirect emissions from electricity used in manufacturing.
Quarterly CBAM Reports
During the transitional period, importers must submit quarterly reports to the CBAM registry detailing the volume of goods imported, the country of origin, and the embedded emissions per installation.
CBAM Certificate Procurement
From 2026, importers will need to purchase CBAM certificates corresponding to the embedded emissions in their imports, priced at the EU ETS carbon price.
Supply Chain Data Collection
Importers must obtain emissions data from non-EU producers. Where actual data is unavailable, default values apply — which are typically higher, increasing cost.
Covered Sectors
CBAM currently applies to imports in the following product categories.
Steel & Iron
Hot-rolled, cold-rolled, coated steel, tubes, pipes, 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
Hydrogen produced via electrolysis or steam methane reforming.
Chemicals
Select organic and inorganic chemicals covered under the regulation.
CBAM Timeline
Transitional Period Begins
Quarterly reporting obligations start. No financial obligations yet, but data collection is mandatory.
Transitional Period Continues
Reporting requirements tighten. Importers must demonstrate efforts to obtain actual emissions data from producers.
Definitive Period Begins
CBAM certificates must be purchased. Financial obligations commence based on embedded emissions and EU ETS carbon price.
Don't wait for the definitive period.
The transitional period is your opportunity to get systems in place. Talk to us about your CBAM exposure and what you need to do now.