Simplifications of the CBAM Regulation

On October 17, 2025, Regulation No. 2083/2025 amending Regulation No. 956/2023 concerning the simplification and consolidation of the Carbon Border Adjustment Mechanism (CBAM) was published in the Official Journal.                         

Among the most important changes, we mention:

• The minimis threshold is modified from a value per import of EUR 150 to an annual cumulative threshold based on weight, set at 50 tons, which will apply to all importers, including those who have obtained the status of authorized declarant;
• The single mass-based threshold does not apply to the imports of electricity and hydrogen;
• If it falls within this annual threshold, the importer declares the respective exemption in the relevant customs declaration;
• An importer who has submitted an application for authorization to obtain the status of authorized declarant by March 31, 2026, may continue to import goods until the competent authority makes a decision. In the event that the competent authority refuses to grant the authorization, it establishes, within one month from the date of the decision, the emissions incorporated in the imported goods between January 1, 2026, and the date of the decision that will be used for calculating the penalties;
• Emissions embodied in goods, other than electricity, can also be determined through default values, which will be updated by the European Commission;
• On November 1, of each year, the Commission will cancel all CBAM certificates that were purchased during the year before the previous calendar year and that remain in the account of an authorized declarant in the CBAM registry;
• The accredited verifier will submit the registration application within two months from the date of accreditation, but not before September 1, 2026;
• Starting from February 1, 2027, the sale of CBAM certificates by a member state will be conducted on a common central platform for CBAM authorized declarants established in that member state.

Obligations of the authorized declarant:

• Submits the CBAM declaration and surrender through the CBAM registry a number of certificates corresponding to the declared and verified embedded emissions by September 30 of each year, for the first time in 2027 for the year 2026;
• Ensures that the number of certificates in their account in the CBAM registry at the end of each quarter corresponds to at least 50% of the embedded emissions in all goods imported since the beginning of the calendar year;
• Submits the repurchase request for the surplus CBAM certificates by October 31 of each year in which CBAM certificates have been redeemed.

The amendments will enter into force three days after publication in the Official Journal of the EU.

The EY team is available for further details regarding the above.