CBAM Compliance Application Required to Avoid Trade Disruption

The EU Carbon Border Adjustment Mechanism (CBAM) applies to importers of carbon-intensive goods such as iron, steel, aluminium, cement, fertilizers, electricity, and hydrogen. Obligations under CBAM apply to importers of over 50 tonnes per year of such goods into the EU.

If your company expects to import more than 50 tonnes of these goods in a year, you must apply for the status of Authorised CBAM Declarant to mitigate any interruption to trade flows. Applications must be submitted by 31 December 2025. The EPA will allow continued trade of CBAM covered goods until 31 March 2026, but only if your application is submitted before the end of 2025.

The application process for Authorised CBAM Declarants requires prompt preparation, with the EPA encouraging declarants to apply as soon as possible to avoid complications when the definitive regime begins in January 2026. Applications will be assessed by the EPA based on criteria such as the importer's demonstrable capacity to fulfil CBAM obligations (both financially and operationally) and evidence of no serious or repeated infringements of customs legislation and taxation rules. From an operational standpoint, it is crucial to demonstrate sound organisational administration, including internal controls to manage CBAM compliance, certificate obligations, and sufficient oversight to prevent non-compliance. 

EY has expertise in helping companies navigate both CBAM reporting compliance and the authorisation process. Our customs and sustainability specialists provide:

• CBAM impact assessments to businesses unsure of their CBAM impact
• Accurate, complete and timely Authorised CBAM Declarant applications
• End-to-end CBAM compliance support

Contacts

If you require further information, please call your regular contact in EY or contact any of the following:

• Deirdre Hogan
• Colin Doolin
• Lewis Murphy
• Síofra Ní Mhidigh