CBAM reporting Ireland is now operating under the definitive regime, and the obligations look very different from the transitional phase that preceded it. The last quarterly report covered Q4 2025 and was due 31 January 2026.

Quarterly transitional reports have been replaced by annual declarations. Authorised CBAM declarant status is required for imports above the applicable threshold, subject to the specific 2026 pending-application customs arrangement described below. Financial and other enforcement consequences may apply for non-compliance.

For businesses importing into the Republic of Ireland, or managing trade flows through the GB-NI-ROI corridor, the compliance picture is more layered than it first appears. At Allied Group, we work across that cross-border route every day, and we have seen a clear rise in CBAM queries from importers unsure where to start since the definitive regime came into force.

“This CBAM reporting Ireland guide covers who must register, which goods are in scope, how to navigate the registry, what emissions data you need, and what happens if you miss a step.”

 CBAM Reporting Ireland 2026 at a glance

Who must register for CBAM and does the threshold apply to you

The 50-tonne rule and what it actually means in practice

The threshold that determines whether you need to register as an authorised CBAM declarant is 50 tonnes of covered goods per calendar year, measured per importer rather than per shipment or per supplier.

This is a mass-based de minimis threshold, and the critical rule is that the obligation to apply for authorisation kicks in before you cross it, not after.

If you expect to import more than 50 tonnes of covered goods during a calendar year, apply before exceeding the threshold. An authorised declarant uses customs document code Y128.

“Understanding this threshold is one of the most important parts of CBAM reporting in Ireland for importers.”

If the annual threshold is exceeded, the CBAM obligations apply to the relevant CBAM goods imported during that calendar year, including quantities imported before the threshold was crossed. Records should therefore be retained from the first import.

Two important exceptions to the threshold

Electricity and hydrogen sit outside the 50-tonne de minimis entirely. These goods are in scope regardless of volume, so if you import either at any quantity, you are subject to CBAM obligations.

A non-EU-established importer must generally act through an EU-established indirect customs representative that agrees to assume the CBAM obligations. Indirect customs representatives should assess their own authorisation requirements separately.

It is also worth clarifying the distinction between the authorised CBAM declarant status required under the definitive regime and the reporting declarant role that applied during the transitional period.

Businesses that only dealt with quarterly transitional reports may now need to apply for a different authorisation category through a different portal. The two are not interchangeable.

What the Windsor Framework means for NI businesses

Northern Ireland’s position under the Windsor Framework creates a distinct customs situation. As things stand, EU CBAM obligations do not automatically apply to NI-based importers simply because they import goods from outside the EU.

The  would only extend to Northern Ireland if it were brought within the Windsor Framework with UK agreement; as matters stand, no such agreement has been reached.

NI businesses should track the UK’s CBAM, which has now been legislated for introduction from 1 January 2027 and is intended to apply throughout the United Kingdom, including Northern Ireland, subject to the enacted UK rules and any subsequent amendments.

For businesses moving goods between NI and the Republic, the specific compliance picture depends on the direction of trade and the nature of the goods, and specialist advice is worth seeking early.

Which goods fall under CBAM reporting Ireland: checking your CN codes

The six covered sectors and how to find your products

CBAM covers six product sectors:

iron and steel, aluminium, cement, fertilisers, electricity, and hydrogen.

Coverage is determined by the Combined Nomenclature codes and product descriptions listed in Annex I to Regulation (EU) 2023/956. CN codes are generally eight digits; TARIC may add two further digits for EU customs measures.

Some code families to know are :

• Iron and steel: most goods in Chapter 72, subject to the exclusions in Annex I, together with specified headings in Chapter 73. Chapter 73 is not covered in its entirety.
•  Cement: ex 2507 00 80 (other kaolinic clays, excluding non-calcined kaolinic clays), 2523 10 00, 2523 21 00, 2523 29 00, 2523 30 00 and 2523 90 00. The ‘ex’ designation means only the goods described in Annex I are covered, not every product under that code.
•  Electricity: 2716 00 00.
• Hydrogen: 2804 10 00. Heading 2804 as a whole is not covered.
• Fertilisers: relevant goods include 2808 00 00, heading 2814, 2834 21 00, heading 3102 and the applicable goods under heading 3105, subject to the descriptions and exclusions in Annex I. The whole of heading 2834 should not be treated as covered.

These chapter references are a starting point only; the final check must always be against the specific code.

How to confirm whether your specific goods are in CBAM scope

Take the commodity code from the customs declaration and compare it with the current Annex I at the level shown there. A four- or six-digit heading can cover several subordinate codes, while an ‘ex’ entry covers only the product description stated in Annex I. Where classification is uncertain, consider applying to Revenue for Binding Tariff Information. Broad chapter coverage does not mean every product in that chapter is caught.

Annex I is specific, and some neighbouring codes within a covered chapter are excluded.

TARIC is a reliable lookup tool for Irish importers doing this check.

“Accurate classification is essential for compliant CBAM reporting in Ireland.”

If your goods appear to fall within a covered chapter but you are not certain about the exact code, confirming the classification before you import is far simpler than correcting an error after the fact.

How to register for CBAM reporting Ireland: what importers need to do

 The two portals and which one you need

There are two distinct CBAM portals, and confusing them is a common mistake. The Transitional Registry was used for quarterly reports during the transitional phase.

Following the end of transitional reporting on 31 December 2025, it is no longer the route for new submissions; from 1 January 2026 it is accessible for amendment purposes only, in line with Commission guidance.

The Authorisation Management Module (AMM) is the portal for applying for authorised CBAM declarant status under the definitive regime. For any Irish importer seeking to import CBAM goods above the threshold from 2026 onwards, the AMM is the relevant system. If you have only ever used the Transitional Registry, you will need to engage with the AMM separately.

Setting up EU Login and the documents required

For an Irish economic operator, EU Login alone is not sufficient. The operator should have a valid ROS digital certificate, Customs and Excise registration and a valid EORI number. Access the EU Customs Trader Portal on a computer holding the ROS certificate, select the Customs domain, Ireland and Economic Operator, and authenticate through the Revenue/ROS route.

Complete the AMM application and upload each supporting item in the requested format; the EPA CN-code template is an Excel spreadsheet, not part of a single combined PDF.

The EPA’s current application information includes applicant and contact details; EORI and CRO number; main economic activity; CBAM goods and expected countries of origin; estimated quantities and values; a completed EPA CN-code spreadsheet; Member States of import; Irish electronic tax clearance; declarations requested in the application; AEO evidence where applicable; financial information for the preceding three years; and financial statements or management accounts as required.

Representation information is also required where an indirect customs representative is involved.

In Ireland, the application for authorised declarant status is assessed by the Environmental Protection Agency (EPA) as the National Competent Authority.

“Completing this process is a key step in meeting your CBAM reporting Ireland obligations.”

A note on timing: apply before you need to import

 Irish importers should apply before exceeding the 50-tonne threshold.

The EPA indicates that the assessment period is normally up to 120 calendar days. This may take longer if additional information is required, so applicants should apply as early as possible.

Reporting deadlines and what the 2026 shift means for your business

The end of quarterly transitional reporting

The last quarterly CBAM report covered Q4 2025 and was due 31 January 2026.

The ordinary correction period for a Q4 2025 transitional report ended at the end of February 2026. In justified cases, a reporting declarant may request permission from the competent authority to correct a report within one year after the end of the relevant reporting quarter. This is not an unrestricted extension for new or late ordinary submissions.

If you missed that window and your transitional reports contain errors, the position is more complicated and worth discussing with a compliance specialist.

Annual CBAM declarations under the definitive regime

Under the definitive CBAM reporting Ireland regime, authorised CBAM declarants must submit one annual declaration by 30 September each year , covering all CBAM goods imported in the previous calendar year.

The first annual declaration, covering 2026 imports, is due by 30 September 2027.

CBAM certificates for 2026 imports are purchased and surrendered in 2027 under the applicable timetable; businesses should not describe certificates as being purchased throughout 2026.

The annual declaration is linked to the surrender of CBAM certificates calculated by reference to embedded emissions, with the adjustments required by the Regulation, including the applicable adjustment reflecting EU ETS free allocation and any eligible carbon price effectively paid in the country of origin. For 2026, certificate prices use a quarterly average EU ETS auction price; from 2027, prices are generally calculated weekly.

This is a materially different obligation from the transitional quarterly process, and businesses should not assume that what they did before translates directly.

Calculating Embedded Carbon for CBAM Reporting in Ireland : the data you need from suppliers

 Simple goods versus complex goods: the calculation difference

 Acceptable emissions data and what suppliers must provide :

• Use actual emissions where the definitive-regime methodology requires and permits them, supported by the required records and verification. Do not describe actual data merely as a preference.
• Use default values only in the circumstances expressly permitted by the definitive-regime implementing rules. Defaults are not a general substitute whenever supplier data is difficult to obtain.
• Apply the prescribed calculation methodology and the legally permitted default values, rather than a general ‘minimise defaults’ rule.
• Treat the applicable calculation, monitoring and verification rules as legal requirements. The permitted treatment of precursor emissions and default values depends on the relevant product and methodology.
• Request the supplier’s production route and system boundaries.
• Collect fuel and electricity consumption records.
• Obtain production volumes and relevant precursor data.
• If verified data is unavailable, first determine whether the definitive-regime rules permit a default value for the relevant element. Do not automatically substitute a default without checking the legal methodology.
• Select defaults carefully – they are product- and country-specific.
• Remember that the importer carries the compliance risk for incorrect data or defaults.
• Check the relevant Commission FAQs for precise guidance.

Grid emission factors and fuel-specific defaults

Calculate direct and indirect emissions using the methods and emission factors prescribed or permitted by the CBAM legislation and Commission guidance. National-grid, IEA or IPCC factors should not be presented as automatically acceptable alternatives; their use depends on whether the applicable CBAM methodology expressly permits them for that calculation.

Whatever factors you use, document your reasoning: which factor was used, why it was selected, and where the source data came from.

Maintain the audit trail for the annual declaration. The European Commission carries out preliminary review functions, the EPA is Ireland’s CBAM competent authority and may assess compliance, and Revenue administers customs declarations, EORI and the Irish customs-access route.

Penalties for non-compliance and where to get specialist support

 What enforcement looks like for Irish importers from 2026

Failure to surrender the required number of certificates attracts the penalty amount applied under the CBAM Regulation by reference to the EU ETS excess-emissions penalty. The amount is indexed and should not be stated as a permanently fixed EUR100 per tonne of CO2e.

Where a person introduces CBAM goods without complying with the authorised-declarant obligations, the Regulation provides for a penalty of three to five times the applicable penalty calculated under Article 26(1), with the competent authority considering the prescribed factors and circumstances.

Beyond administrative penalties, the Irish regulations create criminal liability for offences: on indictment, the maximum is a fine of up to €500,000 or up to three years’ imprisonment, or both.

Unlike the transitional period, which carried lighter-touch obligations, the definitive regime treats CBAM compliance as equivalent to other customs obligations, and enforcement scales accordingly.

How Allied Group supports Irish and NI businesses with CBAM obligations

Allied Group is an Armagh-based specialist with direct operational knowledge of the GB-NI-ROI trade corridor.

We help Irish and Northern Irish businesses manage CBAM reporting Ireland requirements across the GB-NI-ROI trade corridor : confirming whether your goods trigger the 50-tonne threshold, supporting the AMM registration process, helping you collect and structure embedded carbon data from your suppliers, and preparing your annual declaration.

Our CBAM compliance service sits alongside our customs clearance and freight forwarding work, which means we understand how CBAM obligations intersect with the practical realities of import declarations.

For importers managing cross-border trade who need a single point of contact for both customs and compliance, that combination of expertise is well suited to the specific demands of the GB-NI-ROI corridor.

Don’t Wait Until the CBAM Deadline Is Closing In

Confirm whether the 50-tonne threshold applies to your business, check your goods against the Annex I CN code list and, where required, complete your AMM registration before importing CBAM goods.

With annual declarations due by 30 September, now is the time to organise your supplier emissions data – not August.

Ireland’s CBAM requirements have moved beyond transitional quarterly reporting.

The definitive regime is live, obligations are enforceable and non-compliance can carry real consequences. Businesses that act early can secure authorisation, structure supplier data and establish a reliable reporting process well ahead of the deadline.

Get Your CBAM Position Clear Today

Unsure about your obligations, need a second opinion or want support with AMM registration?

Speak to the Allied Group team today. We’ll help you identify potential compliance gaps and understand exactly what your business needs to do next.

“Contact Allied Group today for practical support with CBAM reporting in Ireland and get ahead of your obligations.”