On 28 August 2025, the European Commission launched a call for contributions in view to inform the adoption of three key implementing regulations under the Carbon Border Adjustment Mechanism (CBAM), which will apply from 1 January 2026. The consultation seeks stakeholder input on:
- The methodology for calculating emissions in CBAM goods
- Free allowances within the EU Emissions Trading System (ETS)
- Carbon price paid in a third country
Methodology for Calculating Embedded Emissions: The implementing act aims to clarify how to calculate direct, indirect, and default emissions for CBAM goods, ensuring consistency and reducing administrative burdens.
Free allowances within the EU ETS: The implementing act will set rules for adjusting CBAM obligations in line with the gradual phase-out of free allowances under the EU ETS between 2026 and 2034, and aims to establish general rules for importers and producers on how free allocation adjustments affect their CBAM obligations.
Carbon price paid in a third country: The implementing act will establish procedures and evidentiary requirements for EU importers to claim deductions for carbon prices paid abroad.
This call for contributions is a pivotal step in defining the legal and operational framework of CBAM, securing clarity, reducing compliance friction and balancing environmental policy with legal fairness. Submissions are due from 28 August until 25 September 2025. The Commission’s adoption is planned for the fourth quarter of 2025.”
