Important Note The information in this report is provided as general guidance only.How CBAM applies in practice depends on the specific details of your procurement contracts, supply chain arrangements, and incoterms.Responsibility for reporting and paying CBAM charges lies with the importer of record, and that role is determined by how each transaction is structured. For […]
The information in this report is provided as general guidance only.
How CBAM applies in practice depends on the specific details of your procurement contracts, supply chain arrangements, and incoterms.
Responsibility for reporting and paying CBAM charges lies with the importer of record, and that role is determined by how each transaction is structured.
For example, under Ex-Works terms, the buyer may become responsible for CBAM, while under Delivered Duty Paid terms, the supplier may hold that responsibility.
Additional factors — such as the origin of the steel, route of transport (including transit through the UK), and availability of emissions data — can all alter how CBAM obligations apply.
This overview should not be considered legal, financial, or customs advice.
Each organisation should review its contracts carefully, confirm incoterms with suppliers and logistics partners, and obtain specialist advice where required.
If you would like specific support in understanding how CBAM impacts your steel procurement and supply chain, please contact Irish Steel.
We can provide tailored advice to help your business meet its obligations while managing costs and risks effectively.
1. If we don’t import directly but buy steel from Irish or UK stockholders, does CBAM apply?
• From Irish stockholders: No – they are the importer and responsible.
• From UK stockholders: Yes, if you are the importer into Ireland/EU (depending on incoterms).
2. If supplier terms are Ex-Works, does CBAM apply to us?
• Yes. You take responsibility for importation and CBAM obligations.
3. If I buy from a UK stockholder but the steel is of EU origin, do I need to report?
• No, provided you have documentation proving EU origin.
3a. What about sourcing steel in Northern Ireland?
• Goods placed on the NI market may be treated as within the EU single market (under the Windsor Framework).
• However, if the steel is of UK or non-EU origin and merely transiting through NI, CBAM obligations still apply when imported into Ireland.
4. UK suppliers are not providing emissions data — what then?
• During the transitional phase, you may use default values, but must show efforts to obtain real data.
5. Does CBAM apply across all EU countries? Is there a similar charge in the UK?
• Yes, CBAM applies across the EU.
• The UK does not yet have CBAM but has consulted on introducing one.
6. Do we need to buy a full year’s certificates in January?
• No. Certificates can be bought throughout the year and surrendered annually.
• (Change expected: certificates not available until February 2027.)
7. Are there thresholds or bands by company size/output?
• No. CBAM applies per tonne of imported steel.
• Only very small import volumes (under €150 per year, possibly 50 t per annum under review) are exempt.
8. Does CBAM apply to steel coils, fixings, or fabricated steel?
• Yes, for steel coils and rolled products.
• No, for most fixings or fabricated steel, unless listed in Annex I.
9. When will proposed CBAM changes be confirmed?
• Updates are ongoing – watch for European Commission announcements (expected by end 2025).
10. Will stockholders bear the cost and pass it on? What about landbridge/Northern Ireland?
• Yes, stockholders will pass on CBAM costs.
• Goods transiting through the UK (landbridge) are subject to CBAM if of non-EU origin.
• NI goods may benefit from EU alignment, but origin must be verified.
11. Is CBAM applied automatically, or must we calculate it?
• Importers must declare emissions and purchase certificates. It is not automatic.
12. What’s the difference between registering on the CBAM portal and being an Authorised CBAM Declarant?
• Registration gives portal access.
• Authorised Declarant status is required to import CBAM goods.
13. If I buy from a UK stockholder, am I the importer?
• Yes, if you are responsible for customs entry into Ireland/EU.
14. If the UK introduces its own CBAM, how will that work with the EU CBAM?
• They will be separate systems.
• For EU imports, EU CBAM still applies. Double reporting may occur unless a bilateral agreement is reached.
15. Does CBAM include fabricated steel imported from the UK?
• Not usually, unless the product is listed in Annex I.
16. If my supplier outside the EU handles delivery and import paperwork, am I responsible?
• No, if the supplier is importer of record.
• Yes, if you are importer of record.
17. What is the “Authorised CBAM Declarant” application?
• The formal EU approval to import CBAM goods and discharge obligations.
18. We are reporting quarterly — will this move to annual?
• Yes. Quarterly applies 2023–2025; annual from 2026 (subject to change).
19. Clarify if major suppliers (e.g. TATA) act as stockholder or importer.
• If they act as importer, they’re responsible; if not, you may be responsible.
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