Important Deadline for CBAM Importers

The full suite of obligations under the EU’s Carbon Border Adjustment Mechanism (CBAM) Regulation take effect in 2026. Importers need to be aware of their obligations. There are important deadlines for importers to register, the latest being 31 March 2026. Our Planning & Environment team sets out importer obligations in more detail.

What you need to know

The CBAM Regulation applies to certain goods in the iron, steel, aluminium, cement, fertiliser, hydrogen and electricity sectors.
CBAM obligations apply to importers of over 50 tonnes per year of CBAM goods. There is no threshold for electricity and hydrogen.
The full suite of CBAM obligations took effect on 1 January 2026.
All relevant businesses must apply to be an authorised declarant before the earlier of:
- Exceeding the importation threshold, or
- 31 March 2026.

What is the deadline?

All relevant businesses must submit an application to be an authorised declarant before the earlier of:

Exceeding the threshold of importing CBAM goods from outside the EU, or
31 March 2026

Businesses established outside the EU can choose to appoint an indirect customs representative instead. The same deadlines apply.

What is CBAM?

CBAM is an EU Regulation designed to address the shifting of the production of certain goods to non-EU countries where there is a lower carbon cost associated with their production. It applies to so-called “CBAM goods” imported to the EU from third countries. A list of Combined Nomenclature (CN) codes for the relevant goods is set out in Annex I of Regulation (EU) 2023/956. The goods all come within the following sectors:

Iron and steel
Aluminium
Cement
Fertiliser
Electricity, no threshold applies
Hydrogen, no threshold applies

The objective of CBAM is for the prices of CBAM goods to more accurately reflect their carbon content.

When does CBAM apply from?

CBAM commenced in its transitional phase on 1 October 2023. Only reduced reporting obligations had to be complied with during the transitional period from 1 October 2023 to 31 December 2025. The full suite of CBAM obligations commenced on 1 January 2026. Authorised CBAM declarants will be required to purchase and surrender CBAM certificates in 2027 relating to the embedded emissions associated with the production of the goods imported in 2026.

Who does CBAM apply to?

CBAM obligations apply to importers of CBAM goods into the EU from third countries. If your company expects to import more than 50 tonnes of CBAM goods this year, you must apply for the status of “Authorised CBAM Declarant” before you exceed the threshold, and by 31 March 2026 at the latest. There is no threshold for CBAM goods under the hydrogen and electricity categories. Therefore, you need to be an authorised declarant before importing these relevant goods into the EU.

If your company exceeds the threshold, it is critical that it applies to obtain the status of “Authorised CBAM Declarant” in order to continue importing CBAM goods.

Next steps

If your company meets or exceeds the threshold, it must do the following:

Importers established in the EU must submit CBAM authorisation applications before 31 March 2026. They will be allowed to continue importing CBAM goods pending the authorisation decision. If established outside the EU, importers must appoint an indirect customs representative. The application must be submitted before the cumulative threshold is exceeded. Applications must be made via the Authorisation Management Module (AMM). This can be accessed via online. There are helpful demo videos on the European Commission’s website to assist you with the application.
In addition to applying via the AMM, you must also register as a reporting declarant or appoint an indirect customs representative. Reporting declarants must file quarterly reports via the Transitional Registry, including any overdue reports. More information on how to register can be found online.

The Environmental Protection Agency (EPA) is the competent authority for CBAM in Ireland. More information, including a checklist of information required for your application can be found on the CBAM page of the EPA’s website.

Conclusion

The full suite of CBAM obligations took effect on 1 January 2026. Importers should ensure compliance with their obligations before exceeding the relevant thresholds. If an importer fails to comply, it may be subject to substantial fines. The submitted declarations will be used to calculate the CBAM certificates that need to be purchased and surrendered in 2027.

For more information and expert advice, please contact a member of our Planning & Environment team.