Carbon Border Adjustment Mechanism (CBAM)

Key elements

The implementation of the Carbon Border Adjustment Mechanism (CBAM) commenced on 1 October 2023. Importers of CBAM goods are obliged to register on the CBAM transitional registry.  In addition, from January 2024, they must prepare to file quarterly reports of CBAM imports. CBAM applies to iron, steel, aluminium, cement, electricity, fertilisers and hydrogen that are produced outside the European Union (EU). From 1 January 2026, these goods will be subject to a carbon charge under CBAM when imported. CBAM certificates must be purchased by the importer to cover the charge.

During this ‘learning by doing’ period, you are required to file quarterly reports to the Commission providing details of CBAM goods imported. The first CBAM report was due by 31 January 2024, covering CBAM imports from 1 October 2023 to 31 December 2023. The second report was due by 30 April 2024, covering CBAM imports from 1 January 2024 to 31 March 2024, and so on.

Further information, webinars and guidance documents are provided on the European Commission CBAM webpage. These reports must be uploaded in the transitional registry.

Any importer established in an EU Member State and importing 50 tonnes or more of CBAM goods annually, must apply for the status of authorised CBAM declarant. You need to do this to continue importing more than 50 tonnes of CBAM goods into Ireland. Separate provisions apply for imports of electricity and hydrogen. This can be done via the Authorisation Management Module (AMM).

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. The 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). You must then file your quarterly reports via the transitional registry.

If you are an indirect Customs representative (established in an EU Member State), you should now apply for authorisation. This is regardless of whether or not those you represent are importing above the threshold of 50 tonnes of CBAM goods per calendar year.

Next: Access to the CBAM transitional registry and the Authorisation Management Module (AMM)