Does the European Union (EU) Carbon Border Adjustment Mechanism (CBAM) apply to goods produced in or released from Northern Ireland?
No for goods produced or released for free circulation in Northern Ireland: CBAM is not listed in Annex 2 of the Windsor Framework, and Northern Ireland is not part of the EU customs territory. Goods from other parts of the United Kingdom or from third countries are subject once released for free circulation in the EU.
Two separate questions
This page is about the European Union's mechanism only. The Commission's Questions and Answers (Q&A) 7.12 and 7.13 answer two things. First, CBAM is not listed in Annex 2 of the Windsor Framework in the Withdrawal Agreement between the EU and the United Kingdom, so CBAM does not apply to and in the United Kingdom in respect of Northern Ireland. Second, Northern Ireland is not part of the EU customs territory, although the Union Customs Code applies there under Articles 5(3), 5(4), 13(1) and Annex 2 of the Windsor Framework.
What Q&A 7.14 says about goods
- Goods originating from parts of the United Kingdom other than Northern Ireland, or from third countries, going to the EU are subject to CBAM provided that they are released for free circulation in the EU.
- Goods produced and, or, released for free circulation in Northern Ireland are not subject to CBAM.
- The Q&A question is about goods transiting via Northern Ireland to the EU. It does not describe goods released in Northern Ireland and later moved into an EU Member State.
Where the decision sits
Q&A 7.14 applies the release-for-free-circulation test: goods from third countries or from other parts of the United Kingdom are subject to CBAM provided that they are released for free circulation in the EU, and goods released for free circulation in Northern Ireland are not.
Our reading: a Belfast port call changes nothing if the goods are then released in an EU Member State. For Indian steel there are two separate cases.
- After a stop in Northern Ireland, released in the EU: the steel is a third-country good imported into the EU, so CBAM applies when it is released for free circulation there.
- After release in Northern Ireland: Q&A 7.14 says goods released for free circulation in Northern Ireland are not subject to CBAM. The later move into the EU is not covered by the Q&A, so ask the customs authority of that Member State.
What Senseible does here
Senseible does not file customs or CBAM declarations and does not decide origin, release or who the declarant is. It reads an Indian plant's fuel invoices and electricity bills into dated, fingerprinted installation records, the plant-side data an EU buyer asks for whichever port the steel passes.
- Does CBAM apply to inward processing?
- Country of origin against country of production
- Check your EU buyer is an authorised declarant
- Senseible for CBAM
Last reviewed 2026-11-05. Check the Windsor Framework and Q&A 7.12 to 7.14 again if the EU-UK arrangements change. The reading in the last section is our own.