Ireland's CBAM Regulations 2026 (S.I. No. 332)
Key Takeaways
- This guide covers compliance reporting requirements based on IR (EU) 2025/2621 and EU Regulation 2023/956
- All emission factors and CN codes referenced are verified against the latest EU implementing regulations
- Practical steps and common mistakes are drawn from hands-on implementation experience with the CbamTrack platform
From the team behind CbamTrack
We built this guide based on hands-on experience implementing CBAM compliance for SME importers. The calculations and workflows described here power our own platform — this is not theory, it's what we ship.
Meta Description: Ireland transposes CBAM via S.I. No. 332 of 2026: EPA as competent authority, authorisation rules, de minimis, declarations and penalties. What it means in practice.
Target Keywords: Ireland CBAM, S.I. 332 2026 CBAM, Ireland CBAM authorisation, EPA CBAM competent authority, Irish CBAM regulations
Ireland Implements CBAM
Ireland has transposed Regulation (EU) 2023/956 into national law via the European Communities (Carbon Border Adjustment Mechanism) (Amendment) Regulations 2026, S.I. No. 332 of 2026, in force from 3 July 2026.
"The Agency is designated as the competent authority in the State for the purposes of these Regulations, the CBAM Regulation and any Commission implementing acts thereunder." S.I. No. 332 of 2026, Regulation 11
The Environmental Protection Agency (EPA) is Ireland's competent authority for CBAM.
The De Minimis Exception (Regulation 5A)
Ireland mirrors the EU's single mass-based threshold:
| Rule | Detail |
|---|---|
| Threshold | 50 net tonnes/year (all CN codes aggregated per importer) |
| Effect | Exempt from all CBAM obligations below the threshold — but must declare the exemption in the customs declaration |
| If exceeded | All obligations apply to all emissions embedded in all goods imported that year |
| Exclusions | De minimis does not apply to electricity or hydrogen |
Authorisation: Key Practical Rules (Regulations 6-7)
- No importation without authorisation: importing CBAM goods unauthorised is an offence
- Application through the CBAM registry; the EPA processes applications lodged in Ireland
- Indirect customs representatives must obtain authorisation when acting for importers (including non-established importers)
- Authorisation criteria include: no serious/repeated infringements in the past 5 years, financial & operational capacity, establishment in Ireland, EORI number
- Guarantee required if the applicant wasn't established for the two preceding financial years (bank guarantee payable at first demand)
- Provisional authorisation: applicants who submitted by 31 March 2026 may provisionally continue importing until the EPA decides (Regulation 14(10))
Declarations, Certificates and Surrender
| Obligation | Deadline | Detail |
|---|---|---|
| CBAM declaration | 30 September each year (first: 2027 for 2026) | Total quantities, embedded emissions, certificates to surrender, verification reports |
| Certificate sales | From 1 February 2027 | Sold on the common central platform at the Article 21 price |
| Surrender | 30 September (first 2027 for 2026) | Certificates matching declared emissions |
| Quarterly holding | From 2027 | ≥50% of embedded emissions of goods imported since 1 January |
| Repurchase | Requests by 31 October each year | Excess certificates bought back at purchase price |
Inward processing note: where goods are imported after inward processing (Article 256 UCC), the declaration must include emissions embedded in the goods placed under the procedure, even if the processed products aren't themselves in CBAM's Annex I.
Enforcement and Penalties
- Authorised Officers appointed by the EPA may enter premises, inspect records and take samples
- Review window: the EPA may review declarations up to the fourth year after submission
- Offences include: importing without authorisation, false/misleading information, obstructing authorised officers
- Penalties and appeals follow the CBAM Regulation's framework, with a right of appeal against EPA decisions and penalties
Why This Matters Beyond Ireland
Ireland's SI is one of the first national transposition instruments for the CBAM's definitive phase. It's a useful template for how Member States are operationalising:
- The 50-tonne de minimis in practice (with the exemption-declaration requirement)
- Provisional authorisation for the 2026 transition (application by 31 March 2026)
- Guarantee requirements for newly established declarants
- The EPA-style competent authority structure that importers deal with on the ground
If you import through Ireland, your operational counterparties are the EPA (authorisation, declarations) and Revenue Commissioners (customs controls). Knowing which body does what saves real time during the first declaration cycle.
Key Takeaways
- S.I. No. 332 of 2026 transposes CBAM in Ireland, in force 3 July 2026
- The EPA is Ireland's competent authority; Revenue handles customs enforcement
- 50-tonne de minimis with a mandatory exemption declaration; no de minimis for electricity/hydrogen
- Provisional importation allowed for applications lodged by 31 March 2026
- First CBAM declaration due 30 September 2027 for 2026 imports
Related: CBAM Reporting Deadlines | How to Submit Your CBAM Report | What Is a CBAM Declarant?
Frequently Asked Questions
Who is Ireland's CBAM competent authority?
The Environmental Protection Agency (EPA), designated under Regulation 11 of S.I. No. 332 of 2026.
What if I'm below 50 tonnes?
You're exempt from CBAM obligations, but you must declare the exemption in the customs declaration. If you exceed 50 tonnes in a year, obligations apply to all goods imported that year.
When is the first CBAM declaration due in Ireland?
By 30 September 2027, covering imports made in 2026, with surrendered certificates required for the embedded emissions declared.
Regulation Status
| Field | Value |
|---|---|
| Last reviewed | 2026-08-01 |
| Based on | S.I. No. 332 of 2026, Regulation (EU) 2023/956, Regulation (EU) 2025/2083 |
| Applies to | CBAM permanent phase (2026+) in Ireland |
References
- S.I. No. 332 of 2026 — European Communities (CBAM) (Amendment) Regulations 2026
- EU Regulation 2023/956
- European Commission — CBAM
- Irish EPA — CBAM
Last updated: August 2026 | Sources: S.I. No. 332 of 2026, Regulation (EU) 2023/956, Regulation (EU) 2025/2083
Important Financial Disclaimer
The financial figures, cost estimates, and compliance scenarios discussed in this article are for informational purposes only. Actual CBAM liability depends on your specific import profile, verified emission data, and regulatory interpretations. Consult a qualified CBAM advisor or customs professional before making compliance decisions.
This article was researched and written with AI assistance. All factual claims, emission factors, and regulatory references have been verified against official EU sources (EUR-Lex, European Commission CBAM page). Last verified: July 2026.
R. Emrah Gökkaya
I built CbamTrack because I saw SME exporters struggling with spreadsheets and confusing regulations. Every article here reflects what I've learned implementing IR 2025/2621-compliant calculations, integrating live EU ETS pricing, and building the emission factor database that powers our platform.
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