Omnibus CBAM Reforms: Key Aspects to Consider

The EU Commission has announced an unprecedented simplification effort to reduce administrative burdens by at least 25%, and by at least 35% for SMEs, before the end of its mandate.

The Commission’s work programme, published on 11 February, introduced a first series of so-called “Omnibus” packages aimed at addressing overlapping, unnecessary, or disproportionate rules that create excessive burdens for EU businesses. This package includes amendments to several sustainability regulations, including the EU CBAM—Europe’s key environmental instrument to combat carbon leakage by placing a carbon price on imports of CBAM goods.

This article highlights and explains the most relevant CBAM reforms. The proposal introduces two types of simplifications:

On the one hand, it exempts importers of very small quantities of CBAM goods from CBAM requirements, as a small proportion of importers accounts for the vast majority of embedded emissions imported into the Union.
On the other hand, it simplifies CBAM compliance for importers who remain in scope.

Exempting Small Importers from CBAM

New de minimis Threshold

A new de minimis threshold is introduced: only importers of more than 50 tonnes of CBAM goods per year will fall under the mechanism’s scope. This mass-based threshold replaces the existing consignment-based threshold, which is currently exceeded if the total value of CBAM goods in a consignment is above €150.

In practical terms, the new threshold is expected to exempt around 90% of currently affected importers —mainly small and medium-sized enterprises (SMEs) and individuals— while still covering 99% of carbon emissions from imports of iron, steel, aluminium, cement, and fertilisers.

Importantly, to ensure that at least 99% of emissions remain in scope, the Commission is empowered to adopt delegated acts to amend the threshold based on updated average emission intensities, significant changes in trade patterns, or circumvention practices.

Importers expecting to exceed the annual threshold —or planning to import after exceeding it— must apply for CBAM authorisation.

Simplifying CBAM for In-Scope Importers

Authorisation Procedure

Competent authorities will no longer be obliged to consult other authorities or the Commission before making decisions on granting or revoking authorisations.

Calculation of Embedded Emissions

These reforms primarily affect manufacturers and their CBAM emission calculations.

First, emissions from downstream production steps, in particular finishing steel and aluminium processes performed at installations not covered by the EU ETS, are excluded from the calculation boundaries.

This means manufacturers outside the EU operating such facilities will not need to calculate emissions from those processes. However, they must still collect data on embedded emissions from their suppliers to report the carbon footprint of their exported CBAM goods.

Additionally, embedded emissions from relevant precursors —other CBAM goods used as inputs— produced in countries where the EU ETS applies or where emission trading systems are fully linked with the EU ETS (e.g. Switzerland) do not need to be included in the calculation of embedded emissions of complex goods.

Default Values

Default values will continue to be set based on the average emission intensity of each exporting country for each CBAM good (excluding electricity), increased by a proportionate mark-up. This mark-up will be specified in implementing acts and designed to ensure CBAM’s environmental integrity, based on the latest reliable information, including data from the transitional period.

With the new changes, when reliable country-level data is unavailable for a good, the default values will be based on the average emission intensity of the ten exporting countries with the highest emission intensities for which reliable data can be applied for that type of goods.

Verification of Emissions

Verification will apply only to actual emission values. Accredited verifiers will be allowed access to the CBAM registry upon request from an operator to verify embedded emissions.

CBAM Financial Liability

Two types of reforms are introduced with regard to the CBAM financial obligations:

Postponement of Certificate Purchase

CBAM declarants will not need to begin purchasing certificates in 2026. The start of certificate sales is postponed to February 2027. However, certificate obligations will be based on emissions from goods imported in 2026. The price for these certificates will be calculated as the quarterly average of the closing prices of EU ETS allowances in 2027. This differs from the standard method that will apply after 2026, in which the certificate price is determined based on the weekly average closing price of EU ETS allowance auctions.

Reduced Holding Requirement

Starting in 2027, the requirement to hold CBAM certificates at the end of each quarter will be reduced from 80% to 50% of the emissions embedded in all goods imported since the beginning of the calendar year. To calculate the exact number of certificates that must be held, free allocation adjustments will be taken into account, and importers may rely on either:

Default values without a mark-up
Information from the previous year’s CBAM declaration (for the same goods and third country).

Increased Repurchase Limit

The repurchase limit is increased to cover the full number of CBAM certificates that would have been needed to meet the CBAM obligations.

Carbon Prices Paid in Third Countries

Two key reforms apply:

Carbon Price Claims

Authorised CBAM declarants may claim carbon prices paid in a third country other than the goods’ country of origin.

Use of Default Carbon Prices

Declarants may use default carbon prices, published annually by the Commission through delegated acts, if such prices can be reliably determined for the third country. These prices (expressed in EUR/tCO₂e) will be based on the best available public data and information from third countries.

Declarants may still request a reduction in the number of certificates by accounting for carbon prices effectively paid abroad by the third-country operator (i.e., the non-EU manufacturer). However, they must retain documentation proving that the emissions were indeed subject to a carbon price and that payment was made.

CBAM Representatives

The reforms allow authorised CBAM declarants to delegate reporting obligations to third parties, though they retain full legal liability. The complete set of eligibility criteria for such representatives has not yet been published, but they must, at a minimum, hold an Economic Operators Registration and Identification (EORI) number and be established in a Member State.

New CBAM Deadlines

Start of CBAM certificate sales: February 2027
Annual CBAM declaration: By 31 August each year (first due in 2027 for 2026)
Surrender of certificates: By 31 August each year (first in 2027 for 2026)
Repurchase of CBAM certificates: By 30 November each year
Certificate cancellation: 1 October each year (exception: 1 December 2027 for 2026 emissions)

Enforcement and Monitoring

The reforms strengthen enforcement by improving monitoring by both the Commission and national authorities.

Customs authorities will periodically transmit import data to the Commission, which will forward it to the competent authorities in the relevant Member States for cross-checking against CBAM registry data.

When assessing penalties, competent authorities may consider factors such as intentional or negligent behaviour by declarants.

Next Steps

The proposed simplification reforms were approved by the European Parliament on 22 May 2025. On 27 May, the Council of the European Union (the Council) adopted its negotiating position, paving the way for trilogue discussions.

Just a few weeks later, on 18 June, the two co-legislators reached a provisional agreement. The next step is formal endorsement by both institutions. Once published in the Official Journal of the European Union, the revised CBAM regulation will enter into force three days later.

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