The transitional period for compliance with CBAM (Carbon Border Adjustment Mechanism) obligations will end in late 2025. Based on the experience gained so far, the European Commission deemed it necessary to clarify and simplify the regulation, and the European Parliament has now approved these amendments. The most significant change is the introduction of a new 50-ton annual import threshold, which provides substantial relief for companies with smaller import volumes, while larger corporations must prepare for stricter obligations.
Why were CBAM amendments necessary?
During the transitional period, it became clear both to companies and national climate protection authorities that the regulation required clarification in several areas. Businesses sought more predictable and proportionate obligations for preparation, while authorities needed clearer rules to implement detailed procedures.
Data showed that the current framework imposed disproportionate burdens on companies importing minimal volumes. In response, regulators decided to set a new threshold.
CBAM obligations: the new import threshold
The most anticipated change is the introduction of a new threshold for CBAM obligations.
So far, virtually all companies importing CBAM-covered goods were subject to obligations during the transitional period. Only importers of low-value consignments (under EUR 150) were exempt – a rule that did not provide meaningful relief for businesses engaged in regular trade.
Following an analysis of the transitional period data, legislators concluded that a new threshold was required to genuinely exempt companies importing only small volumes, for whom compliance requirements posed disproportionate disadvantages.
Under the newly adopted amendment, companies importing less than 50 tons per year of CBAM-covered goods will be exempt from obligations.
Importantly, however, if a company exceeds the 50-ton threshold at any point during the year, the obligations will apply retroactively to all CBAM goods imported in that year.
According to the EU, this represents a significant simplification: 90% of affected companies – mostly SMEs – fall under the new exemption.
Still, it raises the question: to what extent will CBAM fulfil its intended role in reducing carbon emissions if over 90% of affected businesses are removed from the system? Many of these questions will only be answered once detailed implementing rules are published.
The role of customs authorities in the CBAM system
Until now, customs officers have played only a limited role in verifying and managing CBAM obligations. This will certainly change.
From 2026 onwards, imports above the threshold will only be permitted by companies registered in the CBAM registry and holding valid CBAM certificates.
The key question is how customs procedures will integrate checks to ensure importers possess the required authorisations – and how to detect those exceeding the threshold without authorisation.
Given the well-functioning IT systems of the EU Customs Union, it is expected that CBAM “free-riders” will become much rarer. Customs IT databases can instantly show what volumes a company has imported into the EU and when, and this data will form the starting point for inspections.
Deadlines and obligations for companies
The amendment introduces several important deadlines:
- From 1 September 2025, companies exceeding the threshold can begin submitting registration and CBAM applications to their national climate protection authorities.
- The first purchase of CBAM certificates has been postponed from January 2026 to February 2027, meaning actual payment obligations will only arise in 2027.
- However, authorities may still impose fees at the time of registration or licence application.
- Reporting obligations will also change: instead of quarterly, companies will be required to submit annual CBAM reports. The deadline for the first annual report will be October 2026.
New rule on CBAM guarantees
The amendments also affect the calculation of emission values, the monitoring of imports of covered products, and the liability of CBAM operators. As part of the package, the obligation to provide a CBAM guarantee will be introduced, primarily targeting companies without at least two years of establishment in the EU.
Product scope remains unchanged
The regulation continues to apply to the same product categories: iron and steel, aluminium, cement, fertilisers, and electricity. While the product scope has not been expanded, companies should prepare in good time for stricter obligations and enhanced inspection mechanisms.
Next steps for companies
The text of the amendment still requires approval by the Council of the European Union, but it is expected to enter into force without changes to the version already passed by Parliament. Formal Council approval and publication in the Official Journal of the European Union are still pending.
The CBAM amendments will exempt a significant portion of companies from obligations. At the same time, those exceeding the threshold will face considerable administrative and financial requirements.
Importers of CBAM-covered goods must monitor on an ongoing basis whether they remain below the threshold or risk exceeding it mid-year, in which case obligations will apply to all imports for that year.
Companies importing more than 50 tons annually should begin preparations now for the full implementation phase in 2026–2027.
