By Pauline Miquel
On 30 September 2025, EU institutions passed a reform to the CBAM, effectively simplifying its design.
Key changes include exempting small importers by raising the de minimis threshold, streamlining reporting for larger importers, and delaying CBAM certificate sales.
Despite these simplifications, the EU CBAM’s timeline remains unchanged. Large importers of carbon-intensive goods covered by CBAM will have to consider the financial impact of the tax as soon as 1 January 2026. Accurate carbon data collection and early preparation will be critical to managing costs in the evolving cross-border trade landscape.
We broke down all the changes and highlighted business implications below.
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Core changes
1. Threshold adjustment: who is covered?
Under the new rules, companies importing less than 50 tonnes of CBAM goods annually (or roughly 100t CO2e) will be exempt from CBAM reporting and fees. This change lifts the burden from 182,000 small and occasional importers, replacing the previously impractical €150 monetary value threshold.
The new threshold still captures 99% of imported embedded emissions, according to the Commissions’ trade and carbon data analysis. Authorities will review the weight-based threshold annually to maintain this coverage.
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Note: Customs authorities will monitor trade data and flag importers at risk of exceeding the new de minimis threshold, ensuring all relevant companies report to the CBAM registry. Occasional importers near the threshold must still obtain CBAM importer authorisation.
2. 2027 CBAM certificate sale delay
CBAM certificates will go on sale in February 2027, a year later than previously announced. While importers will have to surrender their first batch of certificates in 2027, they should cover 2026 imports. Surrendered certificates will reflect the 2026 quarterly average of EU ETS prices.
Note: businesses will therefore gain an extra year to prepare, but they must still track and report emissions quarterly throughout 2026. Early preparation remains key in avoiding financial surprises in 2027.
The revised rules also lower the certificate holding requirement from 80% to 50% of embedded emissions per quarter, easing financial strain on importers.
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3. Extended reporting deadlines
To give importers more time and flexibility in reporting, several elements of the timeline have been updated.
CBAM annual declarations will be due 30 September instead of 31 May previously
The deadline for certificate resale will move from 30 June to 30 September
4. Simplified emission accounting
Default emissions values will now be based on the ten highest-emitting countries with available data, as published by the Commission by the end of 2025. Importers using these values will no longer need third-party verification. However, the markup remains steep, reinforcing the incentive to collect actual supply chain data.
Several exemptions were introduced:
indirect emissions from electricity classified as a CBAM good (not to be mistaken with electricity as a source of energy)
Non-calcined clay (CN code: 2507 00 80)
EU-produced precursors covered by the ETS, which will be assigned zero emissions
Downstream emissions from steel and aluminium finishing processes
Note: exact processes to be exempted under this new provision are yet to be confirmed. We recommend referring to the list of EU ETS-covered processes. Since CBAM mirrors the EU ETS, it is expected to introduce carbon pricing for equivalent processes outside the EU and exclude others.
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5. Carbon price paid in third countries
The European Commission will set default carbon price values for third countries, enabling importers to claim CBAM discounts where a carbon price has been paid. Unlike the previous stricter “country of origin” rule, businesses can account for carbon costs paid at any stage along the supply chain.
6. Authorisation
According the the secondary legislation published on 17 March 2025, companies importing CBAM goods will require an "authorised" status by the end of the year. In order to obtain this status, they will need to submit an application to their respective National Competent Authority.
Importers will have until 31 March 2026 to continue bringing goods into the EU without having officially been recognised as CBAM authorised declarants. If importing in 2026, they will have to prove their application has been submitted in 2025 and still pending approval or risk fines.
Additionally, the Omnibus reform creates a new “CBAM representative, status which allows third-party companies to manage and report CBAM data on behalf of importers. However, the importing entity (CBAM declarant) remains legally responsible for non-compliance.
7. Verification
To facilitate the data verification process, accredited verifiers will gain direct access to the CBAM registry and operator portal.
The list of accredited verifies and detailed verification rules will be published in the form of a delegated act by the end of 2025.
8. Reinforced penalties
Fines, previously minimally enforced, will increase by 3 to 5 times to strengthen enforcement and deter circumvention. In order to implement a rigorous anti-circumvention monitoring, customs authorities will be able to share real-time trade data with the CBAM registry.
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Key business implications
The recent CBAM updates will affect businesses differently based on their size and exposure to CBAM requirements. Smaller importers benefit from the new exemption threshold and reduced compliance obligations, while larger businesses with greater exposure continue to face cost uncertainty.
Financial liability will officially begin in 2027, but companies must still collect quarterly data to anticipate future CBAM costs. By tracking EU ETS prices and investing in robust carbon accounting systems, businesses can better forecast the financial impact of CBAM. Accurate carbon data remains crucial, especially considering the complexity of certificate purchases and verification rules. Companies should prioritise actual emissions data, as using default values will incur a mark-up, increasing costs.
A methodological shift specifically affects downstream steel and aluminium manufacturers. Instead of calculating emissions from downstream processes like rolling, cutting, or forging, businesses will now focus on emissions from precursor materials used in production, disrupting prior emission accounting practices and effectively exempting EU-originated processors from emission calculation.
What’s next ?
As the end of the transitional period nears, the European Commission has leveraged insights gained during this phase to introduce key simplifications to CBAM. Simplifications introduced are now effective.
By the end of 2025, secondary legislation including overdue Implementation Acts and Delegated Acts will outline verification rules, default values, as well as benchmark and emission accounting methodology.
In 2026, the European Commission will propose an mechanism to compensate exporters, expansion of CBAM to finished steel and aluminium goods as well as an anti-circumvention plan through a new legislative proposal. Any further change to the core design if the policy such as the latter will require a full legislative process and could take up to a year before enforcement.