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 CBAM complements the EU Emissions Trading System (EU ETS) and seeks to address the risk of carbon leakage by ensuring that products, irrespective of whether they are imported or produced in the Union, are subject to an equivalent carbon price. The CBAM also aims to encourage third countries, foreign producers and EU importers to reduce their emissions.
The mechanism is applied to 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).
The Definitive phase of CBAM commenced on 1st January 2026. Importers whose cumulative annual imports of CBAM goods exceed the single mass-based threshold of imports of 50 tonnes per calendar year of CBAM goods (excluding hydrogen and electricity) must obtain the status of authorised CBAM declarant before importing CBAM goods for release for free circulation from 2026. 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 . This includes annual reporting and financial obligations. Further information on calculating your estimated CBAM liability can be found here.
Imports mean any imports of CBAM goods to the 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 (any quantity, the 50 tonne threshold does not apply to this sector)
- Electricity (any quantity, the 50 tonne threshold does not apply to this sector
You can check if a CN Code falls under the scope of CBAM obligations by entering the CN Code and country of origin (as entered on the customs declaration) in the TARIC database.
The EPA is the National Competent Authority (NCA) responsible for implementation of CBAM in Ireland, responsible for granting and revoking the status of authorised CBAM Declarant, the sale of CBAM certificates, compliance and enforcement including penalties and overall support to CBAM declarants to ensure compliance with CBAM obligations. Revenue (Customs Division) is the Customs Authority for this Regulation. Please get in touch if you are unsure about your obligations under CBAM.
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. Separate provisions apply for imports of electricity and hydrogen.
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.
What will happen in 2026 and 2027?
The Definitive period of CBAM commenced on 1st January 2026.
Once you have been granted authorisation, you can continue importing CBAM goods and will be required to meet annual CBAM reporting and financial obligations. See our section on TARIC document codes for further guidance on how to complete customs import declarations for CBAM goods.
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 CBAM 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.
Authorisation - applying for and managing your authorisation
Customs Information and TARIC Document Codes
Accreditation and Verification
Further Information and Contact Details