CBAM simplification: what the omnibus changed and the key dates
CBAM simplification came through Regulation (EU) 2025/2083, part of the EU's Omnibus I package, which entered into force on 20 October 2025. It replaced the €150-per-consignment exemption with a 50-tonne annual threshold per importer, moved the annual CBAM declaration deadline to 30 September, delayed certificate sales to 1 February 2027 and cut the quarterly certificate requirement from 80% to 50%. The definitive period still started on 1 January 2026.
How the CBAM omnibus came about
The Commission proposed the change on 26 February 2025 as part of its Omnibus I simplification package, alongside changes to sustainability reporting. Parliament and Council reached a provisional agreement on 18 June 2025, the regulation was adopted on 8 October 2025, published in the Official Journal on 17 October 2025 and entered into force on 20 October 2025. It amends the CBAM Regulation (EU) 2023/956.
The aim was to remove small and occasional importers from scope while keeping almost all embedded emissions covered. The Commission estimated at the proposal stage that the new threshold would exempt most importers by number while keeping the large majority of emissions in scope. For the wider picture of the definitive period, read our CBAM definitive period overview.
The CBAM 50 tonne threshold
- What it replaced: the old exemption for consignments with an intrinsic value of €150 or less.
- How it works: an importer is exempt if the cumulative net mass of its CBAM goods imported in a calendar year is 50 tonnes or less.
- Goods counted: iron and steel, aluminium, fertilisers and cement, added together.
- Not covered by the threshold: electricity and hydrogen remain in scope regardless of volume.
- If exceeded: all of that importer's CBAM imports for the year fall in scope, not only the tonnes above 50.
Splitting imports artificially to stay below 50 tonnes is prohibited, and authorities monitor importers approaching the threshold. Importers that expect to exceed it must apply to become authorised CBAM declarants before they do. Those who applied by 31 March 2026 could keep importing while their application was decided.
All CBAM 2026 changes at a glance
| Topic | Before Regulation 2025/2083 | After |
|---|---|---|
| De minimis exemption | €150 per consignment | 50 tonnes per importer per calendar year (not electricity or hydrogen) |
| Annual declaration and surrender | 31 May of the following year | 30 September of the following year; first one 30 September 2027 |
| Start of certificate sales | 2026 | 1 February 2027, for 2026 imports |
| Price of certificates for 2026 imports | Weekly average | Quarterly average of 2026 EU ETS auction prices; weekly from 2027 |
| Quarterly holding requirement | 80% of embedded emissions | 50%, adjusted for free allocation |
| Repurchase of excess certificates | Limited to one third of certificates bought | Aligned to the 50% requirement; requests by 31 October |
| Filing declarations | Declarant only | Can be delegated to an EU-established third party; declarant stays responsible |
| Carbon price paid abroad | Actual price paid, with evidence | Also Commission default carbon prices for third countries |
Unused certificates from the year before the previous calendar year are cancelled each 1 November; certificates bought for 2026 emissions are cancelled on 1 November 2027 if not surrendered.
Key dates: CBAM simplification timeline
What did not change
- The definitive period started on 1 January 2026 as planned. 2026 imports carry a certificate obligation; only the payment timing moved.
- The covered sectors stayed the same: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen.
- The method for calculating embedded emissions remains installation-based, with direct and indirect emissions and precursors.
- Default values remain available, now with a mark-up — see CBAM default values vs actual data.
- The free allocation adjustment still applies, phasing down as EU ETS free allocation is withdrawn.
What followed the omnibus: implementing acts and further proposals
In December 2025 the Commission adopted the implementing and delegated acts the definitive period needed: methods for calculating embedded emissions, verification principles, accreditation of verifiers, certificate pricing, the free allocation benchmarks and the default values (Implementing Regulation (EU) 2025/2621, corrected in July 2026 by Implementing Regulation (EU) 2026/1740). Sector guidance for non-EU operators followed in August 2026, and verifier registration in the CBAM Registry opened in September 2026.
Two further changes are proposals, not law:
- Downstream extension and anti-circumvention (proposed December 2025): adding further products made of steel and aluminium. The Council agreed its position in June 2026 and the European Parliament in September 2026; negotiations between them began in autumn 2026.
- EU ETS revision (proposed July 2026): would slow the phase-out of free allocation for CBAM sectors and extend it to 2038, which would also slow the CBAM phase-in.
Proposals can change substantially before adoption. Plan on the rules in force and check the European Commission's CBAM pages for the latest status.
What the changes mean in practice
For EU importers
Check annual tonnage across all four threshold sectors. Above 50 tonnes, you need authorised declarant status, a budget for certificates bought from February 2027, and supplier data ready well before 30 September 2027.
For non-EU producers
The simplification gives importers more time to pay, not you more time to prepare. Customers still need calendar-year 2026 data, verified if it is to replace defaults, in time for their first declaration. Smaller EU buyers may now fall below the threshold and stop asking for data, while larger importers still need data for every installation they buy from. Exporters in India should read our guide for Indian steel and aluminium exporters.
A checklist for the next twelve months
- Total your 2026 CBAM imports by sector and confirm whether you crossed 50 tonnes.
- Confirm your authorised declarant status, or that of the indirect customs representative acting for you.
- Collect 2026 installation data from each supplier, and note which values are actual and verified and which will be defaults.
- Estimate the certificates needed using the published 2026 quarterly prices, after the free allocation adjustment and any eligible carbon price paid.
- Plan purchases from 1 February 2027 and the declaration by 30 September 2027.
- For 2027 imports, plan to hold certificates covering at least 50% of embedded emissions at the end of each quarter.
How EKOTRACE helps
EKOTRACE tracks CBAM imports by importer, sector and tonnage against the 50-tonne threshold, and holds supplier installation data, actual and default values and evidence in one place. Producers calculate specific embedded emissions per good and share them with customers through the supplier portal. See our CBAM compliance page for details.
Frequently asked questions
What is the CBAM 50 tonne threshold?
It is an annual exemption for importers whose cumulative net mass of iron and steel, aluminium, fertiliser and cement imports is 50 tonnes or less in a calendar year. It replaced the €150-per-consignment exemption and does not apply to electricity or hydrogen.
When is the first CBAM declaration due?
The first annual CBAM declaration, covering goods imported in 2026, is due by 30 September 2027. Certificates must be surrendered by the same date.
When can CBAM certificates be bought?
Sales on the common central platform start on 1 February 2027. Certificates for 2026 imports are priced at the quarterly average EU ETS auction price for the quarter in which the goods were imported.
Was CBAM delayed by the omnibus?
No. The definitive period began on 1 January 2026 as planned. The omnibus delayed certificate sales and the first declaration deadline, but 2026 imports are still covered.