30.09.2026

CBAM in Ireland: How to Become an Authorised CBAM Declarant

Name: Carbonova Build
Brand: Carbonova

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Irish importers of more than 50 tonnes of CBAM goods a year must be authorised CBAM declarants. This guide covers applying to the EPA, the 30 September 2027 declaration, certificates, default values versus verified supplier data, and Omnibus I.

Since 1 January 2026, a business in Ireland that imports more than 50 tonnes a year of CBAM goods (iron and steel, aluminium, cement and fertilisers) must be an authorised CBAM declarant, and the EPA says you must apply before your cumulative imports pass that threshold. Hydrogen and electricity have no threshold. The first annual CBAM declaration, covering 2026 imports, is due by 30 September 2027, and certificates go on sale in February 2027. What you pay depends largely on whether your suppliers give you verified emissions data or you fall back on default values, which carry a rising mark-up.

What has applied since 1 January 2026

Definitive period. The 2023 to 2025 reporting-only transitional period has ended. Importers now pay for embedded emissions by surrendering CBAM certificates.
50-tonne exemption. Regulation (EU) 2025/2083 exempts importers whose CBAM goods do not exceed 50 tonnes net mass, cumulatively, in a calendar year. The exemption does not apply to hydrogen or electricity.
Irish authorities. Under S.I. No. 539/2024, the EPA is the national competent authority: it grants and revokes authorisations, handles certificate sales and enforces compliance. Revenue (Customs Division) is the customs authority.
Declaration. The annual declaration and certificate surrender are due by 30 September each year, for the first time on 30 September 2027 for 2026 imports.
Certificates. Sales on the common central platform start on 1 February 2027. For 2026 imports, the price is the average EU ETS auction clearing price for the quarter of import: €75.36 for Q1 and €75.28 for Q2 2026, with the Q3 price due on 5 October 2026. From 2027, prices are published weekly.
Quarterly holding. From 2027, declarants must hold certificates covering at least 50% of the embedded emissions in goods imported since the start of the year at the end of each quarter.

Who needs authorisation

Any importer established in Ireland that brings in more than 50 tonnes of CBAM goods in a calendar year, or any quantity of hydrogen or electricity, needs authorisation. An indirect customs representative can apply instead of the importer. To qualify you must be established in Ireland, hold an EORI number, show the financial and operational capacity to meet your obligations, and have no serious or repeated infringements of customs, tax or CBAM rules.

Steps to take now

Check your volumes. Add up the net mass of CBAM goods imported so far in 2026 and forecast the rest of the year by CN code and country of origin.
Prepare your credentials. You need a valid ROS certificate, customs and excise registration and an EORI number to sign in to the Commission's Authorisation Management Module, selecting Customs, Ireland and Economic Operator.
Gather the documents. The EPA's list includes your CRO number, main economic activity, CN codes with quantities by country of origin, an Irish tax clearance certificate (e-cert), unabridged financial statements for the last two financial years, a declaration on infringements and AEO details if you hold that status.
Apply early. The EPA has 120 days to decide, or 180 days if it asks for more information. Only importers that applied by 31 March 2026 could keep importing while their application was pending.
Request supplier data. Ask each producing installation for verified embedded emissions per good for your 2026 imports.
Budget for certificates. Estimate 2026 embedded emissions with both actual and default values, apply the quarterly prices and plan the cash for purchases from February 2027.
Plan the declaration. Decide who prepares it. You may delegate submission to a person acting on your behalf and in your name.

Default values or verified supplier data?

If a producer outside the EU cannot provide a verified emissions report, you must use the default values published by the European Commission. Under Implementing Regulation (EU) 2025/2621, those values carry a mark-up of 10% for 2026, 20% for 2027 and 30% from 2028, so the cost of relying on defaults rises each year to 2028. Fertilisers carry a lower 1% mark-up. Actual emissions must be verified by an accredited verifier; verifiers based in the EU or EEA obtain CBAM accreditation from their national accreditation body. A carbon price effectively paid in the country of origin can reduce the certificates you surrender, provided you hold the evidence.

What Omnibus I means for CSRD in Ireland

Omnibus I (Directive (EU) 2026/470, published on 26 February 2026) narrowed the CSRD to EU companies with more than 1,000 employees and more than €450 million net turnover, reporting from financial year 2027. Non-EU groups with more than €450 million EU turnover and an EU subsidiary or branch above €200 million report from financial year 2028, which matters for the many multinational groups with Irish subsidiaries. Listed SMEs are out of scope. Ireland must transpose the changes by 19 March 2027 and may exempt first-wave reporters that fall below the new thresholds for financial years 2025 and 2026. Where you remain in scope, supplier emissions data gathered for CBAM also feeds your Scope 3 figures for purchased goods.

Common mistakes

Counting tonnes per shipment or per CN code instead of cumulatively across all CBAM goods in the calendar year.
Assuming hydrogen and electricity benefit from the 50-tonne exemption. They do not.
Accepting supplier figures that an accredited verifier has not verified. Unverified data cannot replace default values.
Collecting data from the trader rather than the producing installation.
Assuming the CSRD changes remove the need for emissions data. CBAM obligations are separate from CSRD scope.

How Carbonova helps

Brazil-based Carbonova builds Carbonova CarbonOS, an AI-agent platform for greenhouse gas inventories, CBAM embedded-emissions data and regulatory reporting. For Irish declarants, CarbonOS collects data from suppliers, organises embedded emissions by installation and product and keeps the evidence and data lineage behind each figure, including whether it rests on verified actual data or a default value. The same supplier data can support Scope 3 reporting if you stay within CSRD scope. See our regulatory compliance solutions.

Carbonova is a software provider. It does not apply to the EPA for you, buy certificates or verify emissions; verification opinions come from accredited verifiers.

Do I need to be an authorised CBAM declarant if I import less than 50 tonnes?

No, as long as your cumulative imports of CBAM goods stay at or below 50 tonnes net mass in the calendar year and none of them are hydrogen or electricity. If you expect to go above 50 tonnes, apply to the EPA before you cross the threshold, bearing in mind that it has up to 120 days to decide, or 180 if it needs more information.

When is the first CBAM declaration due in Ireland?

By 30 September 2027, covering goods imported in 2026. Authorised declarants submit it through the CBAM Registry and surrender the matching certificates by the same date, buying them from February 2027 at the price for the quarter of import.

What happens if my supplier cannot provide verified emissions data?

You must use the European Commission's default values. For goods imported in 2026 they include a 10% mark-up, rising to 20% for 2027 and 30% from 2028, with a 1% mark-up for fertilisers. Verified actual data from the producing installation lets you pay on your supplier's real emissions instead of a marked-up default.

If you import CBAM goods into Ireland and want your supplier data and evidence in order before the first declaration, book a demo.