The published EU amendments for CBAM simplification won’t surprise most observers. The core elements have been on the table since February. A closer read of the published texts does reveal several additions that sharpen the rules and help with their interpretation. Most provisions apply from 2026.
(Last update on 17/10/2025)
Adoption of CBAM amendments
Now they are finally published: the amendments 2025/2083 of the core regulation 2023/956 for establishing the EU Carbon Border Adjustment Mechanism (CBAM). Even though many implementation details will still be set by the European Commission, the operating framework is now clear.
On September 29, the EU Council signed off the amendments to the EU. On September 10, already the European Parliament (EP) had voted for the simplifications.
The amendments enter into force 3 days after publication in the Official Journal. Most provisions – including the de-minimis exemption of small importers – apply from 1 January 2026, when the definitve CBAM period starts and with it the CBAM costs impact on imports.
The CBAM amendments aim to ease the burden on EU companies, and to enable authorities to improve monitoring and supervision. Another objective is to better detect circumvention risks. Further amendments to reduce carbon leakage risks are expected to later this year.
The starting point was the EU Commission’s (EC) legislative proposal for the CBAM amendments within the so called “Omnibus” package. There were no major policy shifts versus the Commission’s proposal; rather, the final law adds practical clarifications that improve how the rules will be applied
Amendments for CBAM simplification
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:
- Exemption of companies with annual import volumes of less than 50 tons;
- Simplification of the rules for companies that remain above this limit.
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-related threshold of EUR 150, a new mass-based threshold is to be set as:
- A single mass-based threshold keeps ≥99% of embedded emissions in scope;
- Initially, 50 t total net mass per importer and year of iron & steel, aluminum, fertilizer or cements (electricity and hydrogen are excluded).
Below 50 t, no CBAM obligations apply for that year. The Commission estimates that with these changes, about 90% of importers would be exempt. If the threshold is exceeded, the importer falls under full-year CBAM obligations for that year and an authorization is needed.
What’s new: The annual review of the de-minimis threshold is now fixed for 30 April each year. If the exemption would cover more than 1% of embedded emissions, the Commission will adjust the threshold, but only when the newly calculated value deviates by more than 15 tonnes from the current level.
Clarified timing: Any change to the CBAM scope from this review applies from 1 January 2026. Companies below 50 t therefore remain subject to transitional reporting until the end of 2025.
Authorization of CBAM declarants
From 2026, only an authorised CBAM declarant may import CBAM goods. You obtain this status by applying for authorisation; without it, customs can stop further imports until you are authorised, and penalties may apply.
The definition of the CBAM declarant, on the other hand, has been expanded to cover all relevant customs procedures, incl. inward processing. Indirect customs representatives must always be authorized; when they act as authorised CBAM declarant, they assume the importer’s CBAM obligations and penalties.
What’s new: If you file your application by 31 March 2026, you may provisionally continue importing in 2026 (even after crossing the mass-based threshold) until the authority decides. If the application is refused, penalties under Article 26(2a) apply for all goods imported in 2026 without authorisation.
Determiniation of CBAM emissions
For emissions, the application of default values (with an added mark-up) is simplified by removing the required justification. For actual emissions, the following adjustments are adopted:
- Aligning system boundaries with the EU ETS: the emissions generated during final finishing/processing steps for some steel and aluminium products (not covered by the ETS) are excluded;
- Focusing on relevant precursors: only emissions from input materials (precursors) that are not already covered by the ETS are considered;
Actual emissions must be verified by accredited verifiers; reporting and verification follow EU ETS verifier rules. Third-country producers can submit data via the CBAM registry, and accredited verifiers must be registered there.
What’s new: Timing is clarified. Verifier registration in the CBAM registry starts on 1 September 2026; a verifier must file the registration request within two months of accreditation with the competent authority.
Deduction of carbon prices
The deduction of carbon prices already paid is adjusted by:
- Yearly default carbon prices (per third country) set by EC. If default emissions are reported, only use these default carbon prices can be used;
- For deductions based on actual data, independently certified evidence is needed, incl. for any rebates/compensation that affected the price paid.
What’s new: No material changes have been made. The final text clarifies that the deduction of carbon prices based on actual data is tied to actual emissions. It is also stated more clearly that a carbon price paid in a third country other than the country of origin can also be deducted too.
CBAM certificate management
Flexibility in the CBAM certificate management is enhanced by:
- One-off postponement of the certificate purchase to February 2027 also retroactively for 2026 at the average price of EU-ETS emission allowances in the quarter of the import;
- Lowering the end-of-quarter minimum holding obligation for embedded emissions to 50% from 2027 (based on defaults without mark-up or the certificates surrendered in the previous year);
- Shifting the deadlines for the repurchase requests to October 31 and for the cancellation of unused certificates from the pre-previous year to November.
What’s new: A fee paid by authorised CBAM declarants will fund the central platform (cost-recovery basis). Daily sales/repurchase data are fed into the CBAM Registry. Repurchase and cancellation cut-off dates have also been adjusted and clarified; for 2026 certificates, corresponding special deadlines apply in 2027.
CBAM declarations
Also, the rules for the annual CBAM declaration are amended by:
- Deadline moves to September 30 of the following year (first due in 2027 for 2026);
- An authorised CBAM declarant may appoint a CBAM representative to submit the annual declaration on the declarant’s behalf (liability remains with the declarant). The representative must be established in the EU.
What’s new: The uniform 30 September deadline is now fixed (rather than the previously discussed 31 August). Surrender of certificates is tied to the same date (30 September). Missing or late submission can be sanctioned with ETS-style penalties.
Clarity on overall rules in 2026
Overall, the amendments simplify compliance, above all through the new de-minimis exemption that lifts many small importers out of scope. That said, any future expansion to additional sectors or downstream products will bring new companies into CBAM.
Other changes create practical simplifications, especially for emissions calculation and the crediting of carbon prices paid abroad; the clarified verification requirements for actual values make the rules easier to interpret and apply.
In some areas, the amendments, however, make implementation more complex. The deferral of certificate purchasing to 2027 improves liquidity, but the retroactive payment for 2026 imports makes forecasting and hedging CBAM costs more difficult in practice.
Despite some details still to come in implementing acts, the final text now gives importers a clear operating framework to prepare purchasing, contracts and budgets for 2026:
- Monitor the 50t rule by tracking imported masses across all covered CN codes;
- Set-up organizational roles (incl. delegations) to implement CBAM obligations, incl. authorization, certificates, and declarations;
- Prepare authorization if you expect to exceed the 50t threshold to apply no later than Mar 31, 2026;
- Lock supplier data based embedded emissions (actual or defaults) and ensure CBAM conformity of these data for verification;
- Price CBAM into purchasing orders and product calculations to budget and recover CBAM costs from Janaray 2026, incl. uncertain carbon prices.
For companies above the exemption thresholds, the proposals also make it clear that CBAM – although with amended rules – will become material in a few months.
Sources and further information:
- European Commission: Proposal for amending CBAM Regulation 2023/956 (COM 2025/87)
- European Commission: Staff working document on amendments to the CBAM Regulation (SWD 2025/87)
- EU: Regulation for simplifying and strengthening CBAM (2025/2083)
- EU: Regulation establishing CBAM (2023/956)
