Who does CBAM apply to (currently)?
Access to the Transitional Registry
Authorisation and becoming an Authorised CBAM Declarant
European Commission’s Simplification Proposal
Further information and guidance
The Carbon Border Adjustment Mechanism (CBAM) is a new 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 has 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). Further guidance on the Definitive phase will be made available in due course. Information on becoming an authorised CBAM declarant is available at the bottom of this page
Please note, CBAM obligations remain governed under the current Regulation (EU) 2023/956.
The obligations imposed by the CBAM apply to all who import CBAM goods, where the total intrinsic value of the CBAM goods within the consignment exceeds a value of €150 as outlined in Regulation (EU) 2023/956
Imports mean any imports to EU from outside the EU, including e.g., imports of goods ordered online and imports of gifts.
CBAM goods are listed in Annex 1 to the CBAM Regulation by their CN code. The following are included:
You can check if a CN Code falls under the scope of CBAM obligations by entering the CN Code 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 this regulation and have commenced outreach activities through Irish Business and Employers Confederation (IBEC) and the Customs Consultative Committee.
To facilitate reporting and communications the European Commission has 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.
Further information, including reporting templates and links to the Transitional Registry is available on the EU Commission’s web page and a very useful FAQ document can be downloaded from their site.
If you are an importer of CBAM goods you must register as a reporting declarant (or appoint an indirect customs representative) and file your quarterly reports via the Transitional Registry.
Access to the Transitional Registry for Irish economic operators is granted by Revenue Customs through the normal EU Customs Trader Portal using your Economic Operators Registration and Identification number (EORI) number. If you have queries on this process, please contact importpolicy@revenue.ie
All CBAM reporting declarants should be registered on the Transitional Registry as soon as possible. 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 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 2024 and 2025. The following table illustrates the reporting periods throughout the Transitional Period.
| REPORTING PERIOD | SUBMISSION DUE BY | MODIFICATION POSSIBLE UNTIL* |
|---|---|---|
| Q4 2023: October – December |
31 January 2024 |
31 July 2024 |
| Q1 2024: January – March |
30 April 2024 |
31 July 2024 |
| Q2 2024: April – June |
31 July 2024 |
31 August 2024 |
| Q3 2024: July – September |
31 August 2024 |
30 November 2024 |
| Q4 2024: October – December |
31 January 2025 |
28 February 2025 |
| Q1 2025: January – March |
30 April 2025 |
31 May 2025 |
| Q2 2025: April – June |
31 July 2025 |
31 August 2025 |
| Q3 2025: July – September |
31 October 2025 |
30 November 2025 |
| Q4 2025: October – December |
31 January 2026 |
28 February 2026 |
In accordance with Article 5 of Regulation (EU) 2023/956, declarants are required to apply for authorised CBAM declarant status in 2025 in order to continue importing CBAM goods into Ireland from 1st January 2026.
The EU Implementing Regulation underpinning the authorisation process (Implementing Regulation (EU) 2025/486) was adopted on 17th March 2025 and entered into force on 28th March 2025. The Authorisation Management Module (AMM) was made operational on 31st March 2025.
An importer established in a Member State must apply for the status of authorised CBAM declarant to continue importing CBAM goods into Ireland from 1st January 2026.
As per the EU’s simplification proposal, importers who, in 2023 and 2024, have imported in excess of 50 tonnes of CBAM goods OR who have imported close to 50 tonnes and expect to exceed this threshold in 2026, 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 asked to wait until later in the summer to begin submitting their applications for authorisation. Further communication will be issued later in the summer once we know more on the simplification proposal so please get in touch with us to ensure you are on our mailing list.
The simplification proposal also highlights that indirect customs representatives must apply for the status of authorised CBAM declarant, however, they may not be required to report if an importer they represent does not exceed the 50 tonne threshold.
The 50 tonne threshold liability is placed at importer level i.e. where a single importer imports CBAM goods in excess of this threshold they are liable for the reporting and financial obligations under CBAM.
If an importer exceeds this threshold in a given year, and are NOT an authorised declarant, they will be liable for penalties and will be unable to import further CBAM goods into Ireland until they become an authorised declarant.
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.
The application for an authorisation shall include the following information about the applicant:
Your application must include:
*Provide details of any post balance sheet events between the date on which the last audited accounts were authorised and date of application
As part of the first Omnibus package, the European Commission proposed a set of changes to simplify CBAM.
The main changes proposed are the introduction of a mass-based threshold (annual imports above 50 tonnes) to replace the consignment based threshold (€150), thereby excluding small importers from the scope of CBAM obligations, and simplifying the rules for companies that remain in CBAM scope. The proposed revised threshold of 50 tonnes net mass (cumulatively per calendar year) applies to the following sectors:
The new threshold would not apply to electricity (as an imported good) and hydrogen which will always be in scope.
We encourage you to familiarise yourself with the simplification proposal to understand how it may impact you are your CBAM obligations.
More information on the Commission proposal can be found here:
This proposal has been brought to the European Council and European Parliament for approval and adoption. We are unaware of a specific timeline for implementation of these changes, if they are accepted and adopted.
Importers and declarants alike must continue to submit their quarterly reports and comply with the current CBAM Regulations (Regulation (EU) 2023/956). This includes the application for authorisation, particularly if you will exceed the proposed annual threshold of 50 tonnes.
Please check the European Commission’s CBAM webpage for latest developments.
We have created a series of helpful demonstration videos to assist reporting declarants with their quarterly submissions throughout the Transitional phase:
Helpful guidance videos, webinars and documents on Authorisation are available on the European Commissions dedicated CBAM webpage.
If you have a query that is not answered by the website material, please contact:
Links to relevant legislation: