Major changes in CBAM

• A new threshold of fifty tons 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 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 March 31, 2026.

Key CBAM Changes for Importers

The higher threshold will reduce the burden for SMEs, as most will be exempt from CBAM reporting. For large importers, the EC has also proposed several changes to simplify the CBAM process:

• CBAM declarants may appoint a qualified representative to handle the CBAM reporting process. However, the declarant remains responsible for the obligations arising from CBAM.
   
• Declarants can choose to use standard values provided by the European Commission or declare the actual embedded emissions.
• Exemption of EU-produced precursors when calculating the embedded emissions of imported CBAM goods.
   
• For certain steel and aluminum goods, the finishing process will fall outside the scope of CBAM reporting.
   
• The annual CBAM reporting deadline will change from April 30 to September 30, 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.

Further Changes Announced as of June 16, 2025

• For larger importers, various parts of the CBAM process will be further simplified as of January 1, 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 October 13, 2003, establishing a scheme for greenhouse gas emission allowance trading (EU ETS).

International Developments

• The United Kingdom and the European Union have announced the start of negotiations to link the UK ETS system with the EU's Carbon Border Adjustment Mechanism (CBAM).
   
• Turkey has announced plans to implement its own Emissions Trading System (ETS).