Omnibus Package I – Simplification of the Carbon Border Adjustment Mechanism

We note that the concept of importer has been amended to cover all relevant customs procedures, including the simplified customs procedure.

Article 2(a) is introduced, providing for a “de minimis”exemption. This exemption from the obligations arising under CBAM applies to importers where the net mass of the goods imported in a given calendar year does not cumulatively exceed the “single mass-based threshold”, i.e. 50 tonnes. This threshold applies to the total aggregate of goods per importer per calendar year, and the importer must note the exemption on the relevant customs declaration, even if they have authorised declarant status under the CBAM.
If the importer exceeds the single mass-based threshold in the relevant calendar year, they will become subject to all the obligations foreseen in the Regulation, covering all emissions embodied in all goods imported in that calendar year.

Imports of electricity or hydrogen covered by the Regulation are not included in the aforementioned exemption.

The Regulation will no longer apply to hydrogen and electricity produced entirely on the continental shelf or within the Exclusive Economic Zone of an EU Member State or a non-covered third country or territory.

The deadlines have been adjusted, with the first CBAM declaration only having to be submitted by 30 September 2027, with reference to 2026.

On this same date, the CBAM declarant must surrender the number of certificates corresponding to the embedded, declared, and verified emissions.

It is also only from 2027 onwards that, at the end of each quarter, the authorised declarant must have in their registration account the number of certificates corresponding to at least 50% of the embedded emissions in all goods imported since the beginning of the calendar year (instead of the 80% established in the original version of the Regulation).

Indirect representatives acting on behalf of a third country importer are now covered and must obtain authorised CBAM declarant status before acting.

Emissions embodied in goods may be determined on the basis of actual emissions, in accordance with established methods, or by reference to default values.

The means of determining the default values are simplified when reliable data for the exporting country is not available for a given type of goods. In order to avoid carbon leakage, the default value will in that case be set at the level of the average emissions intensity of the 10 exporting countries with the highest emissions for the type of goods concerned.

Furthermore, only the imported materials explicitly listed in Annex I to the CBAM Regulation and originating from a third country (and territories not exempted from the CBAM under point 1 of Annex III) should be considered in the calculation of embedded emissions. This clarification aims to make the calculations more transparent and user-friendly.

Electricity is added to Annex II for the purposes of calculating embedded emissions, which includes the list of goods for which only direct emissions should be taken into account.

Regulation (EU) 2025/2083 entered into force on the third day following its publication in the Official Journal of the European Union (which took place on 17 October 2025).