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CBAM and CSRD: what Northern Ireland manufacturers actually need to know

16 October 2026 · CBAM · CSRD · Northern Ireland

If you make things in Northern Ireland and sell them into Great Britain, the Republic or further into Europe, you’ve probably had an email in the last year asking about your carbon. Sometimes it’s a customer’s procurement team. Sometimes it’s a questionnaire that seems to have been written for a multinational. Either way, the acronyms doing the asking are usually CBAM and CSRD.

Here’s my plain-English take on both, and why they matter more here than almost anywhere else in the UK.

CBAM in one paragraph

A Carbon Border Adjustment Mechanism puts a carbon price on certain imported goods, so that products made where carbon is cheap don’t undercut products made where it isn’t. The EU’s version moved into its definitive phase on 1 January 2026. It covers iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. Importers bringing in more than 50 tonnes a year of the covered goods need to be authorised CBAM declarants, buy certificates from February 2027, and file their first annual declaration by 30 September 2027 for goods imported during 2026.

The UK is following with its own CBAM from 1 January 2027. It covers aluminium, cement, fertilisers, hydrogen, and iron and steel, and it bites on importers once the value of covered goods reaches £50,000. The first UK return and payment, for the whole of 2027, is due by 31 May 2028.

Why Northern Ireland is a special case

Northern Ireland sits between the UK and EU systems in a way nowhere else does. The UK Government’s position is that the EU CBAM does not currently apply in Northern Ireland. Bringing it in would need a joint decision under the Windsor Framework, and that hasn’t happened. Meanwhile the UK and EU are negotiating a link between their emissions trading schemes, which is widely expected to lead to mutual exemptions from each other’s CBAM. That deal isn’t done yet.

So the honest answer to “does CBAM apply to me?” is often “not directly, but your customers are going to ask anyway”. If you supply steel components, aluminium extrusions, cement products or fertiliser into the EU, your EU customer is the importer, and it is their declaration that needs your embedded emissions data. If you import covered goods into GB, the UK scheme may hit you from 2027.

CSRD has shrunk, but it hasn’t gone away

The Corporate Sustainability Reporting Directive was originally going to pull in tens of thousands of EU companies. The 2025–26 “Omnibus” simplification cut that back hard. Mandatory reporting now applies only to companies with more than 1,000 employees and more than €450 million turnover, plus large non-EU groups with significant EU sales.

That sounds like it lets small and mid-sized NI firms off the hook. Directly, it does. But your large EU customers are still in scope, and they still need value-chain data. The good news is that the Omnibus added a cap: suppliers with up to 1,000 employees can’t be pushed beyond a defined, voluntary-standard level of information. You have the right to say no to requests beyond that.

What I’d do now

• Map your exposure. List the products you sell into the EU and the goods you import. Check which fall into CBAM categories, on either side.
• Talk to your top five customers. Ask what data they’ll need and when. It’s far better to find out now than in a tender.
• Start a carbon inventory. Embedded emissions data comes from the same place as a carbon footprint: your energy, your materials, your processes.
• Keep it proportionate. You don’t need a 200-page sustainability report. You need credible numbers and a clear story behind them.

None of this has to be a box-ticking exercise. Done properly, the work of answering these questions tells you a lot about your costs, your suppliers and where your business is exposed. That’s the bit I find most useful, and it’s what the rest of this series is about.

This post reflects my understanding of the rules as of October 2026. The UK–EU linking talks in particular could change the picture quickly, so check the current position before making decisions.