CBAM Omnibus client alert

With these simplifications, the EU deems to relieve some of the administrative burden caused by CBAM. The key simplifications are:

• A new threshold of importing fifty tons (mass) of CBAM goods per year. With this new threshold, an estimated 90% of importers currently subject to CBAM obligations will be exempt. However, more than 99% of embedded emissions will still fall within the scope of CBAM.
• To prevent disruptions in trade flow, importers will be allowed under certain circumstances to continue importing CBAM goods at the beginning of 2026, while their CBAM registration is still being processed. The importer must submit a CBAM registration application by 31 March 2026
• CBAM declarants may appoint a qualified representative to manage the CBAM reporting process on their behalf. However, the declarant remains responsible for the obligations arising from the CBAM regulation.
• Declarants can choose to use default values provided by the European Commission or declare the actual embedded emissions. If default values are used, then no third party verification is required.
• Exemption of EU-produced precursors when calculating the embedded emissions of imported CBAM goods.
• For certain steel and aluminium goods, the finishing process will fall outside the scope of CBAM reporting. In the Steel and Metal Plan (SMAP) the EU Commission announced to adjust this in Q4 2025, in order to prevent circumvention of CBAM. 
• The annual CBAM reporting deadline will change from 30 April to 30 September, giving declarants more time to verify emissions.
• Declarants are required to purchase CBAM certificates corresponding to at least 50% of embedded emissions, currently the minimum is 80%.
• The first CBAM certificates will be available in February 2027 (instead of January 2026). These certificates are for goods imported in 2026.
• For larger importers, various parts of the CBAM process will be further simplified as of 1 January 2026. These simplifications concern:
  • the authorization process;
  • data collection;
  • calculation and verification of embedded emissions;
  • determination of financial liability during the year of import;
  • and the possibility to deduct paid carbon prices in third countries.
• Clear agreements have been established regarding penalties and the responsibilities of indirect customs representatives. The imposed fines are linked to the directive of 13 October 2003, establishing a scheme for greenhouse gas emission allowance trading (EU ETS).

Is your business possibly affected by the CBAM Regulations and would you like to know more? Please contact.