The Omnibus Package: CBAM simplifications and business implications

In early 2025, the European Commission published the Omnibus Package — a sweeping set of legislative proposals designed to simplify and streamline several flagship EU regulations, including the Carbon Border Adjustment Mechanism (CBAM). The package responds to widespread feedback from businesses and member states that the compliance burden of CBAM, in its original form, risked being disproportionate for many importers, particularly small and medium-sized enterprises.

Among the most significant proposed simplifications is the introduction of a de minimis threshold, which would exempt importers below a certain value or volume of CBAM-covered goods from full reporting and certificate surrender obligations. The Commission has also proposed simplifying the emissions calculation methodology, reducing the granularity of data that importers must collect from their non-EU suppliers. These changes, if adopted, would meaningfully reduce the administrative effort required to comply with CBAM during its early years.

However, businesses should not interpret the Omnibus Package as a signal that CBAM is being weakened or delayed. The core mechanism — requiring importers to pay a carbon price equivalent to that faced by EU producers — remains intact. The definitive period timeline is unchanged, and the certificate purchasing obligation still applies. What the Omnibus Package does is adjust how compliance is delivered, not whether it is required. Importers who have not yet begun preparing for CBAM should not use the simplifications as a reason to postpone action.

For organisations already working on CBAM readiness, the Omnibus Package is largely positive news. Simplified reporting requirements mean lower ongoing compliance costs, and the de minimis threshold may remove obligations entirely for smaller importers. CBAMBOO is tracking the legislative process closely and will update the platform as the final text is agreed. Businesses should continue to collect supplier emissions data and classify their imports, so that they are ready to comply regardless of the final form the simplifications take.