Relevant Matter
Public policy or programme
Public Policy Area
EU Affairs
Period
1 Sep, 2025 to 31 Dec, 2025
Specific Details
Carbon Border Adjustment Mechanism(CBAM)
Intended results
To highlight that, while CBAM was included in the first omnibus simplification package this year, this simplification failed to have any tangible impact for Ireland's agricultural sector who, as it stands, face potential shortages in fertiliser availability and significant increases in fertiliser prices from January 2026.
To demonstrate that Ireland's fertiliser market is particularly exposed to the impact of CBAM due to our reliance on imported nitrogen and phosphorus from outside of the EEA.
Of the imported nutrient nitrogen, 80% of Ireland's urea fertiliser imports (required to produce protected urea and satisfy Government climate policy targets) originated outside the EEA.
That the mechanics & implementation to date of the CBAM legislation make it impossible for CBAM declarants to cost CBAM charges going forward. This will force fertiliser importers to avoid non-EEA fertilisers putting nutrient supply for grass and crop production in significant jeopardy for 2026 and beyond.
To emphasise that the proposed CBAM framework has both legislative and implementation flaws which are outlined as follows
Legislative flaws
1. Timely actual emissions values unavailable turning CBAM into an import tariff
When actual embedded emissions data is unavailable, CBAM requires the use of default values, which are currently c. 90% higher than some exporters actual emissions. As actual emissions for a given production year (e.g. 2026) will not be verified until the following year (2027), importers will be forced to rely on inflated defaults (see article 22). This effectively turns CBAM from a carbon-based pricing mechanism into an import tariff on non-EEA fertiliser.
2. Unworkable certificate pricing system preventing timely cost calculation
The CBAM certificate portal will not be operational until February 2027, with certificate prices set retrospectively on a quarterly basis. For example, prices for imports from January–March 2026 will only be known in April 2026 (see article 21.1a). This makes it impossible for importers and retailers operating on a just-in-time model to accurately set fertilizer prices.
3. Risk of CBAM circumvention via importation of fertiliser from Northern Ireland
As CBAM will not take effect within the United Kingdom until 2027, fertiliser imports into Northern Ireland will remain CBAM-free in 2026. This has the potential to cause significant difficulties to the fertiliser market south of the border which will be distinctly uncompetitive in comparison to the fertiliser for sale north of the border.
Implementation Issues
4. Delayed publication of CBAM benchmarks until 2026
The European Commission was due to release CBAM benchmarks in Q3 2025, but this has been postponed to Q1 2026. These benchmarks determine the level of “free allowances” assigned to fertiliser products. Without them, CBAM charges cannot be calculated for the start of 2026.
5. Unpublished default emissions for the definitive period
As mentioned above, actual embedded emissions for imported fertilisers will not be available for use, and default emissions values for the definitive CBAM period have not yet been published, with no confirmed timeline for release. This leaves importers without the essential data needed to comply with CBAM requirements.
That The EU currently imports around 30% of its nitrogen needs, including 6 million tonnes of urea annually. As all European countries will face similar administrative challenges under CBAM, importers across the bloc are likely to reach the same conclusion—leading to a sharp increase in demand for EU-produced fertiliser.
Given that Europe is not self-sufficient in fertiliser production, there is a real risk that Ireland—without any domestic manufacturing capacity—will not be able to secure sufficient nutrient supplies to meet national crop and livestock demands.
To emphasise that the existence of just one of the issues completely undermines the ability of Irish fertiliser industry to source fertilisers from outside the EEA. The presence of all five proves that CBAM in its current form has the capacity to seriously disrupt fertiliser availability for spring deliveries to farm in 2026 and beyond.
That, in recognition of the broader European fertiliser market, to urge the Minister for Agriculture, Food, & the Marine to raise this as an AOB item at the next Agri-Fish Council and to discuss the issues surrounding CBAM implementation with fellow Agriculture Ministers.
To stress that it is clear that CBAM's implementation on January 1st 2026 has the capacity to massively impact Irish agriculture both in terms of viability and environmental metrics.
To urgently request a meeting with the Minister and other farming organisations to discuss this very important issue.
To emphasise that the introduction of a CBAM tariff on nitrogen fertiliser will severely negatively impact the capacity to achieve this adoption rate a it will make protected urea significantly less price competitive compared with CAN fertiliser.
That IFA has been in contact with the Agricultural Industries Confederation of the United Kingdom who have received confirmation from the UK treasury office that Northern Ireland will not implement CBAM until 2027 at the earliest. Given that Ireland plans to implement the EU CBAM in January 2026, how do Irish authorities think this affect the trade of fertiliser between North and South?
Does this have any impacts on the Windsor Framework Agreement? (It is worth bearing in mind that general preparations for CBAM in the UK are at a very primitive level and 2027 would be seen as a very ambitious timeline).
To seek further clarity on the expected price impact per tonne of fertiliser, the information we have seen from the EPA is that this will be in excess of €40 per tonne and will rise significantly over the coming years depending on whether free allowances are removed? This price increase comes at a time when the Irish tillage sector is struggling significantly and often operating at a loss.
Equally, prices in the dairy sector are also falling and could hit close to costs of production given global oversupply in dairy production – how can farmers be expected to bear this price increase which will further erode farm viability? Rabobank has also estimated that for 2026 the expected price increase will range between 10-20% depending on the product and the intensity of emissions associated with the production of the product.
To emphasise that the solutions the Commission has offered to date in regard to increasing European production of fertiliser and paying attention to market conditions for farmers are not coherent – fertiliser is a commodity that is bought significantly in advance of sale to farmers and so merchants need clarity on what they are buying in order to price.
While natural gas prices are relatively cheap at the moment – the other components used in fertiliser production are expensive and therefore we are highly unlikely to see any increase in EU production to offset the deficit in supply. China who is a significant exporter of fertiliser has also only shipped 10% of its usual exports this year.
Given the lack of concrete solutions being offered to resolve the price impact of CBAM, what pragmatic solutions can be put forward by the relevant departments in relation to its potential implementation?
To highlight that Ireland has voiced its concerns twice now in the Agri-Fish Council in relation to CBAMs impact – what further work has been done to communicate the impact of its implementation? Have these concerns been shared with DG TAXUD who has competency over the issue? Is the department co-operating with other Member States like France and Sweden who have also shared the concerns associated with potential implementation?
To question what the future plan of the relevant departments is, in terms of voicing these issues further in relation to potential implementation of CBAM – Is a delay currently seen as a credible option?
Name of person primarily responsible for lobbying on this activity
Francie Gorman IFA President, Tadhg Buckley IFA Director of Policy & Chief Economist, John Murphy IFA Environment Chair, Noel Banville IFA European Policy Executive
Did any Designated Public Official(DPO) or former Designated Public Official(DPO) carry out lobbying activities on your behalf in relation to this return? You must include yourself, and answer Yes, if you are a current DPO or a DPO at any time in the past. (What is a Designated Public Official?)
No
Did you manage or direct a grassroots campaign?
No
Was this lobbying done on behalf of a client?
No
Lobbying activity
The following activities occurred for this specific Subject Matter Area.
Informal communication (2-5)
Designated public officials lobbied
The following DPOs were lobbied during this return period on this specific Subject Matter Area. These DPOs were involved in at least one of the Lobbying Activities listed above, but not necessarily all of them.
As returns are specific to a Subject Matter Area the above Lobbying Activities may be associated with multiple returns.
Louise Byrne
Deputy Chief Inspector (Department of Agriculture, Food and the Marine)
Martin Heydon
Minister (Department of Agriculture, Food and the Marine)
Barry Cowen
MEP (European Parliament)
Barry Cassidy
Special Adviser (Department of Agriculture, Food and the Marine)
Brian Purcell
Special Adviser (Department of Agriculture and the Marine)