EU Carbon Border Adjustment Mechanism

The EU Carbon Border Adjustment Mechanism (CBAM)

The Carbon Border Adjustment Mechanism (CBAM) is an EU instrument for preventing carbon leakage, that is, shifting of the production of goods to non-EU countries where there is a lower or no carbon cost associated with their production. The mechanism is applied to so-called CBAM goods imported to the EU from outside the EU and specified in an EU Regulation (Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 establishing a carbon border adjustment mechanism). It is part of the EU "Fit for 55" Package.

The objective of the mechanism is for the prices of certain goods imported to the EU to reflect more accurately their carbon content. The CBAM also aims to encourage third countries, foreign producers and EU importers to reduce their emissions.

The CBAM commenced in its transitional phase as of 1 October 2023. Only reporting obligations arise during the Transitional Period (1 October 2023 to 31 December 2025).

The Definitive phase of CBAM commences on 1st January 2026. Under the amended CBAM Regulation, a single mass-based threshold of 50 tonnes per calendar year has been introduced (Article 2(3a), Regulation (EU) 2025/2083). The new De-minimis rule applies to imports of all CBAM goods except hydrogen and electricity.

Importers whose cumulative annual imports of CBAM goods exceed this threshold must obtain the status of authorised CBAM declarant before importing CBAM goods for release for free circulation from 2026. Importers must submit CBAM authorisation applications before 31 March 2026 and will be allowed to continue importing CBAM goods pending the authorisation decision. An application for authorisation to become a CBAM importer must be submitted before the cumulative threshold of 50 tonnes is exceeded.

Who does CBAM apply to?

The obligations imposed by the CBAM apply to all who import more than 50 tonnes of CBAM goods (excluding hydrogen and electricity) per calendar year as outlined in Regulation (EU) 2023/956 (as amended)

Imports mean any imports to EU from outside the EU (i.e. third countries)

CBAM goods are listed in Annex 1 to the CBAM Regulation by their CN code. The following sectors are included:

Iron and Steel
Fertilisers
Aluminium
Cement
Hydrogen
Electricity

You can check if a CN Code falls under the scope of CBAM obligations by entering the CN Code and country of origin in the TARIC database.

In Ireland, the EPA is the National Competent Authority and Revenue (Customs Division) is the Customs Authority for this Regulation. Both authorities have contacted importers who may have obligations under CBAM however please get in touch if you are unsure about your obligations. To facilitate reporting and communications the European Commission developed an IT system for the Transitional Period, called the CBAM Transitional Registry. This system is accessible to reporting declarants and all competent authorities in the EU.

For the Definitive period, a CBAM Registry will be available to authorised CBAM declarants to submit their annual declaration and will facilitate the purchase and surrender of CBAM certificates.

What should I do now?

If you are an importer established in an EU Member State, importing 50 tonnes or more of CBAM goods per calendar year, you must apply for the status of Authorised CBAM Declarant now to continue importing more than 50t of CBAM goods into Ireland in 2026. Separate provisions apply for imports of electricity and hydrogen.

In order to avoid supply disruptions early in the year, importers who have submitted an application for authorisation before the 31^st March 2026 will be allowed to continue importing while awaiting the decision of the National Competent Authority.

However, the application for the status of Authorised CBAM declarant must be submitted before the date of the import where the 50 tonne threshold is exceeded. If you are in any doubt about this threshold, please contact the CBAM Team and apply for authorisation. You can withdraw your application at any time before the assessment is complete and financial and reporting obligations only apply to those who import 50 tonnes or more of CBAM goods throughout the course of the year.

In addition to applying for the status of Authorised CBAM Declarant, you must also register as a reporting declarant (or appoint an indirect customs representative) and file your quarterly reports via the Transitional Registry.

Becoming an Authorised CBAM Declarant

In accordance with Article 2(a) of Regulation (EU) 2025/2083, importers are required to apply for authorised CBAM declarant status in order to continue importing more than 50 tonnes of CBAM goods into Ireland in 2026.

Implementing Regulation (EU) 2025/486 is the EU Implementing Regulation underpinning the authorisation process

The 50 tonne threshold is placed at importer level i.e. where a single importer imports CBAM goods in excess of this threshold throughout the year they are liable for the reporting and financial obligations under CBAM.

Who has to apply for the status of Authorised CBAM Declarant?

Importers:

An importer established in a Member State must apply for the status of authorised CBAM declarant to continue importing 50 tonnes or more of CBAM goods into Ireland from 1^st January 2026.

Under the amended CBAM legislation, importers who expect to exceed the newly adopted threshold of 50 tonnes of CBAM goods (cumulatively) per calendar year should now apply for authorisation via the Authorisation Management Module (AMM).

Please note, importers who do not expect to exceed the proposed threshold of 50 tonnes of CBAM goods in 2026 are not required to apply for the status of authorised CBAM declarant. However, they will be expected to monitor their import quantities and ensure they apply for authorisation in good time if they think the threshold may be reached or exceeded. If they do not have authorisation and exceed the threshold, CBAM import restrictions laid down in Article 4 and related provisions of the CBAM Regulationand penalties will apply. The legislation allows 120 days for the NCA to assess the application and make a decision, so this should be factored into an importers timeline should they envisage importing more than 50 tones after 31^st March 2026.

If you are an importer not established in an EU Member State, you must appoint an Indirect Customs Representative (ICR) (established in an EU Member State) to obtain the status of authorised CBAM Declarant on your behalf. The Indirect Customs Representative will assume the reporting and financial liabilities and ultimately act as the "importer" for those they represent

Indirect customs representatives:

If you are an Indirect Customs Representative (established in an EU Member State), you should apply for authorisation now, regardless of whether those you represent are importing above the threshold of 50 tonnes of CBAM goods per calendar year.

It is important to note, that if you (as an importer or indirect customs representative) apply for authorisation, but do not import above the 50 tonne threshold throughout the calendar year, there will be no financial or reporting obligations. The obligations to report and surrender the associated CBAM certificates will only come into force once the threshold has been reached – in which case, all CBAM goods imported become reportable.

How can I apply?

The application for an authorisation shall be submitted via the Authorisation Management Module (AMM).

Authorisation Management Module (AMM)

Helpful guidance videos on how to use the new AMM are available on the European Commission website and other guidance will be made available in due course.

Logging into the portal and information required for authorisation application

Logging into the portal(s)

There are two portals to be aware of, the Authorisation Management Module (AMM) where you submit your application for the status of authorised CBAM Declarant (for the Definitive Period commencing 1 January 2026) and the Transitional Registry portal where you submit your quarterly reports in the Transitional Period (October 2023 – December 2025)

AMM link: https://cbam.ec.europa.eu/authorised-declarant
Transitional Registry link: https://cbam.ec.europa.eu/declarant

NOTE: The access to the portals should be used on the PC/Laptop that has the ROS cert saved to it. Please select Customs as the domain of the application you request access to.

Before starting, ensure you have not attempted to log in previously and close your browser.
Click on this link to access the AMM - https://cbam.ec.europa.eu/authorised-declarant
The first page you see will be a TAXUD Authentication Portal page.

Make the selections as follows:
1. Domain - “Customs” - not Carbon Border Adjustment Mechanism
2. Country - “Ireland”
3. Actor - “Economic Operator”
When you click submit, you will be brought to a ROS page. Here, load your ROS cert (associated with the EORI number) by clicking the “Manage my certificates” link and enter the associated password.
Then click “Return to login” – you will see your cert has been loaded in the box above. Re-enter the ROS password and you will be brought into the AMM portal.

These steps can be repeated to access the Transitional Registry portal also – the same log-in credentials will apply.

What information is required for the application for authorisation?

Download our checklist here to make sure you have included all the required information in your application:

Authorisation Application Checklist

The application for an authorisation shall include the following information about the applicant:

Stakeholder information

Applicant information
Contact details of the person applying
If you have indicated you are acting as an indirect customs representative, enter the importer details of those you represent and validity period in the relevant section.

Activity details

Main economic activity e.g. “Manufacture of basic metals”
Type of goods imported – select the sector.

In "Description of Goods" please provide a list of the CN Codes attributable to your application, broken down by the tonnes by CN Code you expect to import in 2025 and 2026. You can also upload a spreadsheet or document listing your CN Codes and quantities if easier. Click “Add” to add more than one sector attributable to your application.
Note: Do not make any selection (Yes or No) for the question "Electricity Import Status" unless you are an importer of Electricity This question only becomes mandatory once Electricity is selected as the sector in the field "Type of goods imported"

Estimations of the quantity and value of goods for the current year and for next calendar year.
Select the EU member states in which you have been or expect to be involved as importer or declarant in customs declarations for CBAM goods (this includes Ireland). This is not where you outline the countries you import from, but rather where you indicate if you are using your IE EORI number as the importer of record in another EU Member State.
Irish tax clearance certificate – e-cert to be uploaded to application, please do not print the results screen. Details on how to obtain a tax clearance certificate can be found on Revenue’s website here - The electronic Tax Clearance (eTC) System
Declaration of honour – tick box to state you have not been involved in serious or repeated infringements. Please read this question carefully.

Financial & operational details

Data access declaration – by selecting this box, you are allowing the EPA, as NCA, to access relevant information from relevant government bodies in relation to your application
AEO status (if applicable). Proof of status will be required.
Business Registration Number – this is your Companies Registration Office (CRO) number https://cro.ie/
Financial figures for the preceding three years (profit/loss/turnover/current assets/current liabilities) i.e. 2024 (Year 3) 2023 (Year 2) 2022 (Year 1)

Your application must include (these can be uploaded to the "Add Documents" section of the application form):

Financial Statements for the last two financial years. (including Income Statement/Profit & Loss, Statement of Financial Position/Balance Sheet and Statement of Cash Flows). Please note these financial statements must be audited (unless an audit exception has been granted) or
Management accounts relating to periods subsequent to the most recent Audited Financial Statements.

*Provide details of any post balance sheet events between the date on which the last audited accounts were authorised and date of application

What will happen in 2026 and 2027?

The Definitive period of CBAM commences on 1^st January 2026. Importers of more than 50 tonnes of CBAM goods must apply for the status of authorised CBAM declarant to continue doing so.

Once you have applied for authorisation before 31^st March 2026 and before you exceed the 50 tonne threshold, you can continue importing these goods. See our section on TARIC document codes for further guidance. In the Definitive period of CBAM, financial and reporting obligations will apply.

You will be required to purchase and surrender CBAM certificates in 2027 relating to the embedded emissions associated with the production of the goods you imported in 2026. Authorised CBAM declarants should submit their annual CBAM declaration and surrender the corresponding number of certificates by 30 September of the year following the year of importation of the goods. This will include the calculation of embedded emissions on the basis of either default values or actual values verified by accredited verifiers.

The number of CBAM certificates that each authorised CBAM declarant will surrender will be determined by the amount of imported CBAM goods and the actual specific embedded emissions, reduced by the specific emissions covered by EU ETS free allocation, and, where relevant, reduced by the specific emissions already covered by a carbon price effectively paid in the country of origin.

While we await the publication of secondary legislation to provide specific guidance on the calculation of the liabilities, please refer to questions 128-134 of the European Commission FAQ Document available here.

TARIC document codes for use from 1^st January 2026

From 1^st January 2026, the Definitive Phase of CBAM begins. The following table outlines the different TARIC document codes that may be used in the customs import declaration from 1 January 2026 and the scenarios in which each code should be declared:

Note; any queries in relation to customs procedures should be referred to importpolicy@revenue.ie

TARIC Document Code	Description	Details declared in the ‘Document produced, certificates and additional references’ field on customs import declaration.
Y128	This code is to be used when an importer has been granted a CBAM authorisation and a CBAM account number has been assigned	TARIC document type code Y128 CBAM Account number
Y238	This code is to be used when an importer has applied for a CBAM authorisation but has not yet been assigned a CBAM authorisation.	TARIC document type code Y238 CBAM Application Reference Number
Y137	De minimis exemption code. Refers to occasional small imports of up to 50 tonnes net mass per importer and year (cumulative threshold). (Does not apply to hydrogen and electricity)	TARIC document type code Y137
Y135	Exemption Code. Applies to goods to be moved or used in military activities (art. 2(3) of CBAM reg)	TARIC document type code Y135
Y134	Exemption Code. Goods originating in Büsingen, Heligoland, or Livigno (Article 2(4) of Regulation (EU) 2023/956	TARIC document type code Y134
Y136	Exemption Code. Electricity generated or hydrogen originating in the exclusive economic zone or on the continental shelf of a Member State	TARIC document type code Y136
Y237	Goods of EU origin	TARIC document type code Y237

Further guidance on the Definitive Period will be made available in due course.

Submitting your Quarterly reports on the Transitional Registry (Q4 2023 – Q4 2025)

See log-in guide above to assist in logging into the Transitional Registry portal.

All CBAM reporting declarants should register on the Transitional Registry (separate to the Authorisation Management Module where you apply for Authorisation). This is where reporting declarants will upload their quarterly reports throughout the Transitional period.

CBAM Transitional Registry Portal

The “reporting declarant” is the entity which is responsible for the reporting of embedded emissions of imported goods. In principle, the reporting declarant is the “Importer”. However, in practice there are different options depending on the person lodging the customs declaration.

In line with the options provided under the Union Customs Code (UCC), the reporting declarant can be either:

The importer who lodges a customs declaration for release for free circulation of goods in its own name and on its own behalf;
The person, holding an authorisation to lodge a customs declaration referred to in Article 182(1) of the UCC, who declares the importation of goods; or
The indirect customs representative, where the customs declaration is lodged by the indirect customs representative appointed in accordance with Article 18 of the UCC, when the importer is established outside the Union or where the indirect customs representative has agreed to the reporting obligations in accordance with Article 32 of the CBAM Regulation.

The CBAM Transitional Period commenced on 1 October 2023 and consequently, importers of CBAM goods are obliged to register on the CBAM Transitional Registry and file quarterly reports for Q1 -4 2024 and Q1 – Q4 2025.

Further information and guidance

Authorisation:

Helpful guidance videos, webinars and documents on Authorisation are available on the European Commissions dedicated CBAM webpage.

A helpful checklist can be downloaded using the button below: