BlogCarbon Border Adjustment Mechanism (CBAM)

Proposals for CBAM amendments

Written by

Ulf Narloch

Published on

26. February 2025

The EU Commission proposes an amendment of the CBAM regulation – in an effort to cut administrative burdens on EU companies. The amendments would exempt all companies with annual imports smaller than 50 tons. Companies that would still fall under CBAM are to benefit from simplifications too.

(this blog is regularly updated – last update on 28/02/2025)

Simplification of CBAM obligations

On February 26, the EU Commission presented its first legislative proposals for the Clean Industrial Deal, Affordable Energy Act and the “Omnibus” package. The latter is supposed to reduce the regulatory burden of companies to achieve sustainability and climate targets more cost-effectively.

In addition to bundling sustainability reporting obligations, the “Omnibus” package also includes revisions of the carbon border adjustment mechanism (CBAM), which will introduce a CO2 price on imports from 2026.

These proposals are the first concrete measures of the new EU Commission. This follows the announcements in the EU Competitiveness Compass, which serves as the strategic roadmap for the legislative period up to 2029.

The EU Commission has now submitted a proposal for amendment (COM 2025/87) to the CBAM Regulation 2023/956, which sets out the overarching rules for CBAM. The amendments aim to simplify and strengthen CBAM.

In addition to easing the burden on EU companies, authorities are also enabled to improve monitoring and supervision. Another objective is to better detect circumvention risks.

These proposed amendments result from early implementation experience since the start of the CBAM transitional period on October 1, 2023:

The amendments still have to be adopted by the EU Council and Parliament before they enter into force upon publication. Further revisions are possible.

Proposed amendments to the  Regulation

In addition to changes in the rules for national authorities, customs authorities, CBAM verifiers and non-EU producers, the proposals primarily focus on 2 simplification levers for importing companies:

  1. Exemption of companies with annual import volumes of less than 50 tons;
  2. Simplification of the rules for companies that remain above this limit.

The Commission estimates that the proposed simplifications would exempt 90% of the companies previously affected but will continue to cover 99.27% of emissions.

Exemption of companies

Importers of small quantities of CBAM goods that only account for very low emissions would be exempt. These companies, often SMEs, face disproportionate burdens in administering CBAM.

In contrast to the existing consignment-based threshold of EUR 150, a new mass-based threshold is to be set as:

  1. >99% of embedded emissions in imports of CBAM goods to remain covered; accordingly, a weight-based value is derived and updated regularly;
  2. 50 t of total mass of imported CBAM goods over a year as initial value set per declarant (not applicable for hydrogen and electricity).

Companies below these limits would not be subject to CBAM obligations. They would not need an authorization as CBAM declarants to import CBAM goods into the EU from 2026.

However, as soon as thresholds are exceeded, an authorization is required. Penalties are due for all imports if the limits are exceeded before such an authorization is granted.

The definition of the CBAM declarant, on the other hand, has been expanded to cover all relevant customs procedures. In addition to customs declarations for free circulation of CBAM goods, now also bills of discharge related to inward processing are covered.

Simplification of the rules

Implementation would also be made easier for importers above the newly set thresholds. In particular, the requirements for emissions data and for calculating the required CBAM certificates have been adjusted. These resulted in major implementation challenges in corporate practice.

The determination of emissions is to be simplified by:

  1. Removal of a necessary justification for the application of (national) default values (with a mark-up) in the emissions calculation from 2026 onwards;
  2. Adjustment of the system boundaries to exclude emissions from the (final) processing stages of some steel and aluminum products in line with the boundaries in the EU emissions trading system (ETS);
  3. No accounting for precursors that are produced in countries with an emissions trading system integrated in or linked to the EU ETS.

The deduction of carbon prices already paid is to be adjusted by:

  1. Setting of annual default carbon prices in third countries by the Commission to be used for calculation of deductions;
  2. Consideration of carbon prices in third countries outside the country of origin of CBAM goods (e.g., for precursors).

Flexibility in the CBAM certificate management is to be improved by:

  1. One-off postponement of the purchase of the necessary certificates for 2026 to 2027 – but at 2026 prices;
  2. Reduction of the minimum quantities for which certificates must be held at the end of the quarter from 80% to 50% (starting 2027) and adjustment of the calculation base;
  3. Replacement of the 1/3 limit for the repurchase of any unused certificates by a limit based on the minimum quantities (as per ii).

Also, the rules for the annual CBAM declaration are to be amended by:

  1. Postponement of the submission deadline from May 31 to August 31 of the following year;
  2. Possibility of appointing a CBAM representative who takes over the annual CBAM declaration for the CBAM declarant (but not the liability).

Clarity on the future direction of CBAM

Overall, these proposed amendments would be a major simplification – mainly due to the exemption of over 182,000 importers. According to the estimates by the Commission 18,000 companies would remain within the scope of CBAM.

At the same time, an extension of the CBAM scope to other sectors and downstream goods was also announced. A legislative proposal for this is to follow at the beginning of 2026.

The proposed postponement of the certificate purchase to 2027 would give companies now more time to prepare. Also, the EU Commission would gain time. With 10 announced regulations there is a tight schedule to develop the implementation requirements.

For EU companies, this now means:

  • Reassessment of the CBAM applicability in light of the proposed thresholds and possible extensions; if necessary, adjustment of import volumes and development of warning systems for exceeding critical import limits.
  • Accounting for CBAM costs in purchasing and financial planning from 2026. Today’s purchasing decisions for imports in 2026 already result in financial CBAM costs – although these have been passed on to 2027.

For companies above the exemption thresholds, the proposals also make it clear that CBAM – although with adjusted rules – will become a financial liability from next year onwards.

Sources and further information:

Photo by Guillaume Périgois on Unsplash

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