A revolution in CBAM simplification

The European Commission has definitively approved and implemented significant changes in the Carbon Border Offset Mechanism (CBAM), whose main objective is to reduce administrative and regulatory burdens, especially for small and medium-sized enterprises (SMEs)This proposal, presented On 26 February 2025, as part of the "Omnibus I" simplification package, it responds to calls from European leaders for a "simplification revolution". The aim is to ensure the effective application of the mechanism without weakening its environmental ambitions.

The new CBAM simplification regulation (Regulation (EU) 2025/2083) was published on October 17, 2025 and entered into force on October 20, 2025.

Key change: New de minimis weight threshold

The most significant change is the introduction of new exception de minimis based on a uniform weight thresholdThis new threshold replaces the original exemption which applied to goods of negligible value (below EUR 150 per consignment).

The new uniform weight threshold is set at 50 tonsThis limit applies cumulatively per importer per calendar year for all CBAM goods in the iron and steel, aluminium, fertilisers and cement sectors. This approach eliminates the risk of circumvention of the rules by artificially splitting shipments. The threshold does not apply to imports of electricity and hydrogen.

It is expected that this measure will exempt approximately 90 % importers – in particular small and medium-sized enterprises and micro-companies – from CBAM obligations, such as reporting and declaration requirements. At the same time, will retain more than 99 % of total embedded CO2 emissions within the scope of the mechanism, thus preserving its environmental character.

If an importer exceeds this weight limit, all emissions contained in goods imported during that calendar year, including quantities below the limit, are subject to the CBAM obligations. The European Commission is empowered to review and adjust the threshold annually by delegated act to ensure that 99 % emissions remain within the scope of the CBAM.

Simplification for authorized declarants

For importers to whom CBAM continues to apply (CBAM authorised declarants), the proposal brings several operational simplifications.

  1. Deadlines and Delegation: The deadline for submitting the annual CBAM declaration and submitting certificates has been extended to August 31 the following year (for the first time for 2026, to be submitted in 2027). This shift provides additional time for declarants to comply with their obligations. Eligible CBAM declarants may also delegate the submission of declarations to a third party, although they remain legally responsible for the performance of their obligations.
  2. Financial Adjustments: The minimum quarterly requirement for purchasing CBAM certificates is reduced from 80 % to 50 % of emissions put in. The limit for the redemption of surplus certificates is also aligned with this new 50 % obligation. The sale of CBAM certificates for emissions in 2026 will start from February 1, 2027.
  3. Carbon price: Declarants can claim a reduction in the number of certificates for the carbon price actually paid in a third country. What is new is that the deduction is possible even if the carbon price was paid in a third country other than the country of origin of the imported goodsIf the actual carbon price cannot be determined, declarants may use standard carbon prices set by the European Commission (from 2027), which will be determined on the basis of the best available, reliable and public data.

Technical and Control Strengthening

The new regulation also includes measures to strengthen monitoring and streamline technical processes.

  • Emissions verification: The obligation to verify the submitted emissions by an accredited verifier now only applies to cases where the declarant uses real values (not default).
  • Scope: The scope of CBAM includes: excluded uncalcined kaolin claysAt the same time, it was Electricity added to the list of goods for which only direct emissions are taken into account when calculating embedded emissions.
  • Combating Circumvention: Anti-circumvention provisions have been strengthened. False practices or arrangements aimed at artificially dividing imports in order to avoid the threshold are explicitly prohibited and subject to sanctions. Unauthorised importers who violate the rules face fines of three to five times the standard fine.

According to Antonio Decaro, rapporteur for this amendment, the aim was to facilitate competitiveness and business growth by exempting 90 % importers, while fully preserving the EU's environmental ambitions. JRi

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