The Carbon Border Adjustment Mechanism (CBAM) is the EU's tool for putting a carbon price on imported goods that compete with carbon-priced EU production. Ireland implements CBAM through Revenue Commissioners. The transitional reporting phase ran from 2023 to end of 2025. From 1 January 2026, the financial phase begins — and Irish importers of in-scope goods need to be ready.
What's covered (and what isn't)
CBAM applies to imports of:
- Cement — clinker, Portland cement, certain non-hydraulic cements.
- Iron and steel — most products in CN chapters 72 and 73.
- Aluminium — primary aluminium and many semi-finished products.
- Fertilisers — nitrogen fertilisers in particular.
- Electricity — imports across grid interconnectors.
- Hydrogen — pure hydrogen imports.
Downstream products (e.g. finished machinery, vehicles) are not in scope of CBAM yet, but the EU has signalled expansion is likely.
Authorised CBAM Declarant — the key registration
From 2026, only an Authorised CBAM Declarant can import CBAM goods into Ireland. The requirements:
- Established in Ireland (or have a CBAM-Authorised representative).
- Hold a valid IE EORI.
- Have arrangements for the financial security CBAM certificates require.
- Submit an application to Revenue's CBAM unit.
Applications take 4–8 weeks to approve. If you import CBAM goods and aren't registered by 1 January 2026, your imports cannot clear customs.
Quarterly CBAM declarations
Authorised Declarants submit quarterly returns covering:
- Quantities imported (tonnes).
- Country of origin.
- Producer / installation that made the goods.
- Embedded direct and indirect emissions (tCO₂e).
- Carbon price already paid in the producing country (if any).
The emissions data must come from the producer. If you can't get verified emissions data, CBAM uses default values that are typically much higher than reality — meaning more CBAM certificates and higher cost.
CBAM certificates — the cost element
From 2026, Authorised Declarants must buy and surrender CBAM certificates each year equivalent to the embedded carbon imported. Certificate prices follow the weekly average EU ETS allowance price — currently around €70–90 per tonne CO₂.
A back-of-envelope calculation: a tonne of imported steel with 2 tCO₂e embedded emissions could cost €140–180 per tonne in CBAM certificates. Significant for any volume importer.
What Turkish exporters should do
If you export CBAM-covered goods from Turkey to Ireland:
- Verify your emissions data — work with your producer to get accurate, verified emissions figures. Default values will hurt your customer's competitiveness.
- Consider Turkey's own carbon pricing — Turkey is developing its emissions trading system. Any carbon price paid in Turkey is deductible from the Irish CBAM cost.
- Talk to your Irish importer — they may need help registering as an Authorised Declarant.
Practical steps for Irish importers right now
- Audit your imports — confirm which products are in CBAM scope (by CN code).
- Apply for Authorised Declarant status — don't wait for January.
- Set up a producer data pipeline — get verified emissions data from each producer you import from.
- Model the cost impact — CBAM may shift your sourcing economics.
This is the most consequential customs regulation since Brexit for any Irish importer in steel, cement or aluminium supply chains. If you'd like help with Authorised Declarant registration or CBAM compliance design, contact us.