Carbon Border Adjustment Mechanism (CBAM)

Key elements

The implementation of the Carbon Border Adjustment Mechanism (CBAM) commenced on 1 October 2023. 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.

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 Environmental Protection Agency (EPA) 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).

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 Authorisation Management Module (AMM)