In September 2025, the European Parliament approved a package of changes known as CBAM Omnibus I, aimed at simplifying and strengthening the EU's Carbon Border Adjustment Mechanism (CBAM). These changes significantly reduce the administrative burden for small and occasional importers, without lowering the EU's climate ambitionsThe key modification is the introduction of a new exemption threshold – 50 tons per year – which will exclude approximately 90% of importers (mainly SMEs and individuals) from the system, while leaving CBAM within its reach 99% of CO₂ emissions are import-related goods covered by the mechanism. The Omnibus Package thus responds to business calls for simplification of procedures, while maintaining the fundamental objective of the CBAM, which is to protect the EU's energy-intensive sectors from carbon leakage in full compliance with the 2050 climate neutrality objective.
The amendment was adopted by a large majority (617 votes in favour) and will enter into force after formal approval by the Council. on the third day after publication in the Official Journal of the EU. Below we present in detail all the adopted changes – in accordance with the final text of the European Parliament document A10-0085 / 2025 together with annexes – and their practical consequences for importers preparing for the new CBAM obligations.
Repealed provisions and new solutions in the CBAM regulation
The Omnibus Package amends over 20 articles of Regulation (EU) 2023/956 establishing the CBAM. Below we detail the most important ones. repeal of existing provisions and newly added regulations:
- Abolition of the current "negligible value" threshold – the exemption for shipments with a total value of up to EUR 150 (previously de minimis) was deleted. Instead, a uniform mass threshold of 50 tonnes per year per importer (described later).
- Exclusion of uncalcined kaolin clays – these products have been removed from the list of goods covered by the CBAM, considering that their production is not carbon-intensive (only calcined clays remain covered under the cement category). Imports of these uncalcined raw materials will no longer be subject to CBAM obligations.
- Modification of the importer and operator definitions – the definition has been expanded "importer" including an entity using the inward processing procedure (a reference to Article 175(5) of Regulation 2015/2446 has been added). The definition has also been clarified "operator" installations outside the EU – this now also includes parent companies that control such installations directly or through a subsidiary. These changes are intended to prevent exploitation of definitional loopholes and ensure that the relevant entity is responsible for CBAM obligations.
- New mass threshold of 50 tonnes – annual deminimis – provisions have been added establishing an exemption from CBAM for importers who import a total of less than 50 tons of CBAM goods (net) from four main sectors: steel and iron, aluminum, cement, fertilizersThe details of this mechanism are described in the next section.
- New simplifications for calculating emissions – the possibility of free choice between actual emissions and default values when calculating emissions of imported goods (with the reservations described below). Definitions and rules have also been added for complex goods (produced using other CBAM goods as intermediates) to avoid double counting of emissions (e.g. when the component was already covered by the ETS or a fee in the country of origin) – more on this later in the text.
- Delegation of declaration obligations – a new provision has been added (Article 5, paragraph 7a of Regulation 2023/956) allowing the authorized CBAM declarant may delegate the submission of the CBAM declaration to a third party acting on his behalf. However, the importer remains fully responsible for fulfilling his obligations, even if he outsources the preparation of the declaration to a third party.
- Change of settlement schedule – the deadlines for submitting annual declarations and redeeming CBAM certificates have been extended. The previous deadline of May 31 has been moved to 31 October the year following the reporting year. The mechanism for selling and redeeming certificates has also been modified – this is discussed in detail in the section on certificate management.
- New monitoring and sanctions rules – provisions have been added imposing an obligation on the European Commission and national authorities monitoring of exempt importers (below the threshold) and detection of threshold exceedances. The catalogue of mitigating circumstances when imposing penalties has been specified and a different sanction procedure has been introduced for unauthorized entities that have violated the regulations (discussed in the section on sanctions). Furthermore, a centralized CBAM register and an IT platform that will ensure data exchange between authorities and greater transparency and control over import and emission data.
These changes mean that the existing CBAM regulations have been significantly updated. Below, we detail what these changes mean for importers in practice, broken down into key areas.
Requirements and obligations of importers after changes (50 tonnes threshold, authorization, delegation)
New 50 tonne threshold – According to the amendment, if total weight of goods covered by CBAM (steel, iron, aluminum, cement, fertilizers) imported by a given entity does not exceed 50 tonnes per calendar year, such importer is deemed to be "occasional CBAM importer" and benefits from exemption from major obligations. This exemption does not include imports of electricity or hydrogen, because for these sectors the bulk threshold was not considered appropriate (different nature of units and emissions). In practice, the 50 tonne threshold will be applied collectively to all imports in the four sectors mentioned – not separately for each sector – which prevents circumvention of the regulations by fragmenting imports across different categories of goods. According to Commission analyses, the 50-ton limit exempts ~90% of importers from CBAM obligations, leaving a maximum of ~1% of import emissions outside the system (the rest of the emissions are still subject to CBAM).
Exemption from obligations for small importers: Importer who is expected to not exceed 50 tons per year, does not need to apply for the status of an authorized CBAM declarant or submit standard emission declarations. No authorization required constitutes a significant relief – it means there is no need to register in the CBAM register, conduct detailed quarterly reporting, etc. However, freedom from procedures goes hand in hand with the importer's responsibility for monitoring your own import volumeSuch an entity must itself control the weight of the imported CBAM goods in order to not to exceed the threshold of 50 tonnes per year. If he is approaching the limit, he should take steps to achieve full compliance in good time (e.g. obtain authorization).
Crossing the threshold: In the event that an occasional importer will exceed a total of 50 tons during the year, he loses his exemption. Exceeding the threshold gives rise to the obligation to register as an authorized CBAM declarant and fulfilling all standard obligations for the given year. Importantly, Customs authorities and the Commission will jointly monitor Import data to detect entities that exceed the threshold and fail to register. The new regulations require the Commission to verify annually (by April 30) whether the threshold still ensures coverage of 99% of emissions – and authorize it to adjust the threshold via a delegated act if changes in trade patterns justify it. However, any potential adjustment to the threshold will be rare – the final text only provides for a change if the calculated threshold differs from the applicable one. more than 15 tons.
Obligations of importers above the threshold: Importers who exceed 50 tons per year (i.e., approximately 10% of the largest importers, accounting for ~99% of import emissions), remain fully covered by the CBAM mechanism. Their main responsibilities are:
- Authorization (registration) as a CBAM declarant – The entity importing CBAM goods (except for exempt small occasional goods) must have the status of authorized CBAM declarant granted by the competent national authority (in Poland – by the National Revenue Administration). The amendment simplified the procedure for obtaining authorization – the previously mandatory consultation procedure between Member States was removed (national authority maybe(but is not required to consult with others before giving consent). This will speed up and facilitate the process of registering the company in the CBAM system. Warning: Importers who reported emissions during the transition phase in 2025 and expect to exceed 50 tonnes in 2026 should ensure they obtain authorisation before the end of the transition period.
- Submitting CBAM declarations – The authorized declarant is obliged to submitting the annual CBAM declaration containing, among others, the total quantity of imported CBAM goods (in tonnes or MWh for energy) and the calculated embedded emissions, i.e. emissions generated during the production of these goods. Novelty: even an importer benefiting from the 50 tonne exemption must report to the authorities once a year total weight of imported CBAM goods (even if there is no obligation to account for emissions). This is to enable monitoring of threshold exceedances and possible abuses.
- Obligation to settle emissions and acquire certificates – An importer above the threshold calculates the total emissions related to imports on an annual basis and must purchase and surrender the corresponding number of CBAM certificates (each certificate corresponds to 1 tonne of CO₂). Detailed rules regarding certificates (purchase deadlines, redemptions, prices, possible discounts) are described below. It is important that the first obligation to redeem certificates will occur in 2026 – with settlement made in 2027 (see schedule section).
- Record keeping and reporting – CBAM declarants must maintain accurate records of imported goods and their emissions (including documents confirming the products' carbon footprint). If they use actual emissions values, they are required to have verified reports from producers. This data will be verified by accredited verifiers (who will now also register with the CBAM system).
- Delegating activities – According to the new regulations, an authorized importer may commission a third party to submit the CBAM declaration on his behalfThis could be, for example, a specialized representative, advisor, or customs representative. It is important, however, that formally this is the importer remains responsible for the accuracy and timeliness of submitting the declaration. Delegation is optional – it is intended to facilitate companies in fulfilling their obligations by utilizing the services of experts, but does not relieve them of responsibility for any errors.
- Indirect representative (non-EU) – If the importer is not based in the European Union, he cannot obtain the status of a CBAM declarant himself. In such a case, he must designate indirect representative based in the EU, which on his behalf will obtain authorization and perform the duties of the CBAM. The amendment clarified the duties of such a representative – he must register himself as an authorized CBAM declarant (Article 5 of Regulation 2023/956 has been supplemented in this respect). The indirect representative is jointly and severally liable for the obligations of CBAM. Importantly, in the case of representatives serving many small customers, the 50 tonnes threshold applies total import volume assigned to a given declarant (i.e. representative), so the representative of the group of small non-EU companies will probably exceed the threshold and will have to fulfil full obligations (hence the 50 tonne exemption does not apply to indirect representatives declaring goods of different importers).
In summary, it is crucial for importers to determine their status: whether their imports will exceed 50 tons per year or notSmall, occasional importers may simply need to monitor their import volume and submit an annual summary report, while larger importers must prepare for the full process of authorization, emissions reporting, and certificate purchase.
Emissions calculation methods – simplifications, simple vs. complex goods, default values
One of the most practical improvements to the Omnibus package is the introduction of greater flexibility in emission calculation methods attributed to imported goods. The original regulation required importers to obtain detailed data on the actual emissions during the production of each product. This proved particularly burdensome for SMEs that source goods from multiple suppliers. The new regulations give importers a choice and distinguish between "simple" and "complex" goods.
Choosing between actual and default emissions
Optional use of default values: The importer can free to decidewhether it will be used in settlements for a given product actual emission volume (calculated based on data from the manufacturer's installation) or will it use established default value (simplified emission factor). This applies to goods other than electricity - for electricity, special rules based on the actual emissions of the energy mix still apply. Default values are to be determined by the Commission based on "best available data" and reflect the emission intensity of production in exporting countries. According to the announcement, the default emission factors will be conservative – for example, based on the average of the 10 most emitting producers of a given commodity for which reliable data is available. This is to ensure that the choice of the simplified option will not underestimate reported emissions (it will rather overestimate them), encouraging importers with lower emissions to report actual data.
Emissions verification: If the importer decides to actual emissions, the requirement remains that these data are verified by an accredited environmental verifierThe newly added Article 10a imposes an obligation on all verifiers registration in the CBAM system in the country where they were accredited. However, when default values are used, there is no need for additional verification – they are treated as pre-approved indicators. This also simplifies the duties of importers, especially those unable to obtain reliable data from foreign suppliers.
Choosing the “carbon price paid” settlement method: Similar flexibility was introduced in the countdown emission costs incurred abroadLet us remind you that the CBAM mechanism allows you to reduce the number of certificates due by any carbon price paid in the country of origin (e.g. carbon tax, ETS allowance cost, etc.) to avoid double charging. Following the changes, the importer can choose whether to document the price actually paid for the emissions in the country of production, whether it will benefit from default carbon price established by the Commission for a given country. Warning: The principle of consistency has been introduced – if the importer uses the default emission value, To must also use the default carbon price value for a country. Therefore, it is impossible to selectively mix approaches (e.g., low default emissions with a high actual carbon fee). This is to prevent potential abuses and ensure that simplifications do not lead to underpayments. The Commission has announced the publication of default carbon pricing tables for individual third countries starting in 2027.
These options allow importers to tailor their emissions reporting to their operational capabilities. For small foreign suppliers unable to provide detailed environmental data, using default values will be a simpler alternative (avoiding the need for complicated calculations and audits), although generally less financially advantageous, as these values will be established with a ceiling. On the other hand, companies importing from modern, low-emission installations will still be able to demonstrate lower actual emissions – which will reduce their CBAM costs – provided they submit verified reports.
Simple vs. Complex Goods – A New Approach to Emissions in the Value Chain
The amendment introduces a distinction between simple goodswhose emissions result from one basic production process, and complex goods, the production of which involves many stages and components (including precursors, i.e. semi-finished products covered by CBAM or EU ETS used to produce the final product). This is important when calculating the "embedded emissions" attributed to the imported goods, so as to avoid double counting emissions already settled or trace.
Assumptions of the new rules for complex goods:
- Exclusion of emissions previously settled in the ETS: If the imported product is made using materials that are already were subject to an emission fee – e.g. steel produced in the EU (where the manufacturer purchased ETS allowances) or in a country that has a system fully linked to the ETS was used – then the emissions related to the production of this precursor may be excluded from the emission calculation of an imported good. In other words, a zero carbon footprint is considered such a component upon import, as the emission cost has already been incurred in the EU. The importer will need to provide proof of the mass of such precursors and their origin, but will not re-charge CBAM certificates for them. For example, if we import a device in which 30% of the mass consists of steel parts manufactured in the EU (and exported to the country of assembly), the emissions associated with the production of this steel do not increase our CBAM obligation when importing the device back into the EU.
- Omission of emissions from finishing processes: For calculating emissions emissions from final production stages that are not covered by the EU ETS will not be included and generate negligible emissions. This refers to the final product finishing processes (e.g., packaging, surface treatment, component assembly), which are not energy-intensive in themselves. Under the new regulations, importers no longer have to collect and report data on emissions from such final operations – they focus on emissions from production of basic components (precursors). This simplification means that the CBAM declaration is intended to cover primarily emissions from the production of main raw materials and semi-finished products (e.g. burning of cement clinker, smelting of aluminium, synthesis of ammonia, etc.), without detailed accounting of each minor technical activity that took place afterwards and generates negligible emissions.
The new approach rewards transparency and shortens the emission chain to the most important linksIn practice, the importer will focus on obtaining data on emissions related to production key materials components of its goods. For example, if a metal product made of steel and aluminum is imported, the importer will calculate the emissions resulting from the production of steel and aluminum (or use their default or actual values), while emissions from the process of combining these materials into the finished product (unless this process is high-emission and covered by the ETS) will not be included.
This distinction between goods is also important for future expansion of the CBAM scopeThe Commission will assess the possibility of extending the CBAM to additional sectors as early as 2026. The definitions of complex goods and the mechanisms for exempting precursor emissions are intended to prepare the ground for the possible inclusion of more complex products in the CBAM in the future, without excessively complex calculations.
Submitting declarations and managing certificates – new deadlines and settlement rules
The amendment significantly changes schedule and procedures for submitting annual CBAM declarations and handling certificatesThe goal is to give companies more time to fulfill their obligations and to reduce one-time financial burdens by spreading them over time. Below, we explain what the CBAM settlement cycle will look like after 2026.
Extended deadline for the annual CBAM declaration
Annual declaration by October 31: The previous regulations required that an authorized importer until May 31 each year, submitted a declaration for the previous year (including the import volume and calculated emissions) to the CBAM authorities and simultaneously cancelled the corresponding certificates. Omnibus Package extends this deadline by 5 months – until October 31 next year. This means that importers will have almost 10 months (instead of 5) to collect data, verify emissions and prepare an annual declaration.
Example: Next year 2026 the CBAM declaration together with the emission settlement will have to be submitted until October 31, 2027 (instead of by May, as originally scheduled). Similarly, for 2027 – by October 31, 2028, etc. This is a nod to companies that reported difficulties in preparing a complete set of data so quickly after the end of the year.
Synchronization with ETS: The new October deadline better aligns with the EU ETS calendar. National ETS registries often finalize emissions and allocation data by the end of March, while previously CBAM importers had only about two months to comply and purchase certificates. This window is now longer, reducing the risk of haste or errors in declarations.
First settlement year – 2026 settled in 2027
Extended transition period: Although formally The CBAM transition period ends on December 31, 2025., the Omnibus package in practice extends the lack of financial obligations by an additional year. For 2026, importers will not have to purchase certificates quarterly or in 2026. – the sale of certificates will only be launched February 1, 2027. In other words, Emissions imported in 2026 will be settled in one lump sum in 2027.The reason is "many unknowns related to 2026" – the Commission concluded that additional time is needed for the certificate system to function efficiently from a technical and market perspective. For importers, this means that the entire year 2026 will be free from certificate expenses (although data on emissions must be collected and a declaration must be submitted by the end of October 2027 and the amount due must be paid then).
No quarterly payments in 2026: The original regulations stipulated that, starting January 1, 2026, importers would be required to gradually purchase certificates throughout the year – at the end of each quarter, they would have to have at least 80% of them, in an amount corresponding to their emissions since the beginning of the year. removes this obligation for 2026 – the first partial settlements will begin in the first quarter of 2027 (details below). This means that companies will not have to lock up their capital in certificates in 2026 before the end of the year.
Rules for acquiring and redeeming CBAM certificates from 2027
Certificate sales start – February 2027: National authorities will not start selling CBAM units until February 01.02.2027, 2026. From that date, importers will be able to purchase certificates needed to settle emissions for 2027 and gradually for 8. In practice, this gives 2027 additional months (February-September 2026) to collect certificates required for redemption for XNUMX, which significantly alleviates the one-off financial burden.
Obligation to hold 50% of certificates quarterly: Starting from 2027, a relaxed mechanism for protecting against year-end purchase peaks will be introduced. At the end of each quarter the authorized importer will have to have in his account at least 50% the number of certificates corresponding to imported emissions from the beginning of the year to the end of a given quarter. This is reduction of the requirement from the current 80% to 50%The goal: to reduce financial pressure – the importer will purchase only half of the expected certificates during the year, with the remaining amount to be purchased later. For example, after the first quarter of 2027, they must have certificates covering at least 50% of their Q1 emissions, and after the second quarter, 50% of their half-year emissions (if they imported more in Q2, they will purchase additional certificates to cover half of the Q1+Q2 total), etc. The remaining amount will be settled in their annual declaration.
Annual redemption of certificates: After the end of the year, the importer makes the final settlement. In accordance with the new calendar, until September 30/October 31 the following year, an annual declaration must be submitted and redeem the corresponding number of certificatesIn practice, this may occur simultaneously with the submission of the declaration (e.g., by September 30th – according to the Commission's proposal – or by October 31st – according to the final version adopted by the European Parliament). To be on the safe side, it is worth setting a September 30th deadline for the cancellation of certificates for the previous year to meet the cut-off date for unit cancellations (see below).
Cancellation of unused certificates: If an importer purchased more certificates than their final requirements (which can happen, for example, if they prudently purchased certificates during the year), they will be able to recover the excess by selling the certificates to the authority. The new regulations provide favorable changes to the rules: the one-third limit was abolished – until now, the state could only buy back up to 1/3 of the certificates purchased the previous year. Now all surplus certificates can be submitted for redemption, provided they were purchased to meet the quarterly 50% emission requirement. The importer submits a repurchase application to 31 October (if redemption is on September 30) of the year and the unused certificates will then be canceled November 1st without compensation. In other words, after November 1st, any certificates purchased in the previous year will no longer be valid – they must be used (cancelled) or returned for purchase within the stipulated time, otherwise they will be forfeited.
Price of certificates: According to the CBAM mechanism, the price of CBAM units will be linked to the price of EU ETS allowances – is to correspond to the average auction price of EUAs in the week preceding the purchase. Certificates will be available for purchase from national authorities (e.g., via a common central platform operated by the Commission). The fee system and any administrative charges will be specified in implementing acts – the final text stipulates that the Commission may impose a fee for using the certificate sales platform to cover its operating costs. However, there is a caveat that these fees must be limited to covering costs (without generating profit or being unduly burdensome).
Thanks to the above changes, the certificate management process will become more efficient. friendly to the financial liquidity of companies: a smaller portion of certificates purchased "upfront" during the year (50% instead of 80%), full possibility of reselling surpluses, more time to collect funds before final redemption.
Other new rules: country-of-origin carbon fees, indirect representatives, sanctions, registries and transparency
In addition to the key areas discussed above, the Omnibus package introduces a number of additional changes supplementing the CBAM system. They concern, among other things, the method of taking into account emission costs incurred abroad (carbon price paid), clarifying the role of indirect representatives, tightening or easing sanctions for non-compliance, and improving the operation of the register and the flow of information. These issues are as follows:
- “Carbon price paid” – national emission fee: As mentioned, the importer has the right to reduce his CBAM liability by emission cost actually paid in the exporting countryThe amendment makes this mechanism more practical. If a foreign producer has paid a carbon tax or participates in an emissions trading scheme, for example, the importer can provide evidence and deduct the corresponding amount (in the form of a smaller number of redeemed certificates). What's new is the ability to use the default value: The Commission will establish for each third country default CO₂ price index (e.g., the average price of allowances or carbon taxes in that country). The importer can choose this simplified path instead of collecting documents to support each transaction. Condition: if it uses the default emissions, it must also use the default price. Otherwise (if it shows actual lower emissions), it should document the actual carbon costs incurred abroad to be able to deduct them. This mechanism is especially important for imports from countries that introduce their own carbon pricing systems – CBAM will then only impose the difference between the EU ETS price and the price paid locally, which prevents international trade from being penalized twice for the same emissions.
- Indirect representatives and companies outside the EU: The changes confirm and specify that A non-EU company wishing to export goods covered by CBAM to the EU must appoint a representative in the EU to complete the formalities. Such a representative – often a customs agency or branch in the EU – becomes a formal importer (declarant) within the meaning of CBAM, is subject to authorization and is responsible for settling the issue. The regulations specify that if an indirect representative serves multiple foreign clients, he must maintain a separate CBAM account for each of them or settle the total as one entity (which usually means exceeding the 50 tonnes threshold). This is important from the point of view of, for example, Swiss or British companies – to export to the EU, they must either have their own entity in the EU or a contract with an entity acting as their representative.
- Sanctions and penalties for violations: From the outset, CBAM envisaged severe financial penalties for non-compliance (PLN 500 for each tonne of emissions not reported in accordance with the ETS rule, which in 2023 corresponded to ~EUR 100/tonne). introduces the possibility of mitigating penalties in justified casesThe competent authority will be able to reduce the amount of the penalty taking into account circumstances such as the scope of undeclared emissions, the degree of cooperation of the importer, previous reliability, whether the violation was unintentional, etc. This is intended to encourage companies to cooperate well in possible corrections instead of automatically imposing maximum fines. At the same time, a distinction has been made between situations where the violation is committed an entity that is not an authorized declarant (i.e. someone who imported goods bypassing the system). In such a case, it is provided a much higher penalty – 3 to 5 times higher than for a registered importer for similar violations. Payment of this penalty by an "illegal" importer has definitive effect – exempts him from the need to submit overdue declarations and redeem certificates for a given period. In other words, the penalty serves as a lump sum "atonement for sin," because in practice it would be difficult to require an unauthorized entity to settle the emissions after the fact (since it does not have an account in the system). However, for authorized declarants, nothing changes – the payment of the penalty itself does not release them from the obligation to cancel the missing certificates for a given year. They must still make up the shortfall in certificates despite incurring a penalty. This structure is intended to deter people from deliberately "paying the penalty instead of purchasing certificates" – they cannot buy themselves out of the obligation with a substitute.
- CBAM Register and Data Transparency: The operation of the CBAM mechanism is based on a central CBAM Electronic Register, where importer accounts are maintained (similarly to the EU ETS registry for installations). The Omnibus package envisages further development of this system, including: the creation common central platform to handle the sale and redemption of certificates (financed by fees paid by participants), the obligation registration of verifiers (as mentioned) and strengthening supervision mechanisms. The European Commission will have access to data from the register automatically and continuously and will conduct analyses of entities that may be exceeding the threshold or circumventing the regulations. In case of suspicion, national authorities will be able to request additional documentation from the importer or cooperate with customs authorities to confirm the accuracy of declarations. This is a significant shift towards greater transparency. transparency and control – Import data (including weights, CN codes, country of origin, customs declaration numbers) will be cross-checked with CBAM declarations. Additionally, anti-circumvention regulations clearly indicate that artificially splitting shipments to avoid exceeding the 50 tonne threshold will be treated as circumventing the regulations and prosecuted accordingly (the original CBAM mentioned splitting shipments for a threshold of 150 EUR - now it has been updated to the new bulk threshold). As for making information public, the regulation does not provide for the disclosure of data of individual importers (this is commercial information), but it can be expected that the Commission will publish aggregated reports on the functioning of the CBAM, which will increase the transparency of the effects of the mechanism.
Schedule for implementing changes and division of responsibilities over the years
The last key issue is implementation calendar new CBAM solutions. Importers need to know which obligations apply to them and from when. Below is a chronological timeline from the transition phase to full implementation, taking into account changes to the Omnibus package:
- 2023-2025: Transition phase (reporting free of charge). From October 1, 2023 until the end of 2025, importers of goods from the CBAM list submit quarterly reports on the mass of goods and their estimated emissions, without paying any fees yetThe de minimis threshold of EUR 150 per shipment still applies and is taken into account for reporting purposes (this threshold will cease to apply at the end of 2025). Warning: In the transition period the 50 tonne threshold does not apply, so even small entities must report every shipment over EUR 150. The 50-ton exemption will only become effective from 2026, when the Omnibus changes come into force.
- End of 2025/early 2026: Authorisation of importers. Under the original CBAM, entities importing CBAM goods should submit applications for authorization by the end of 2025 (in order to be able to formally act as declarants from 2026). Omnibus Package maintains this obligation for importers who plan to exceed the 50 tonne threshold. Occasional importers, however, can postpone registration – if their volume in 2026 is <50 tonnes, they do not need to be authorized. Practically speaking, it is worth assessing at the turn of 2025/26 whether expected imports in 2026 will exceed the limit. If so, submit an application for authorization (according to a simplified procedure, without mandatory consultations between countries).
- *2026: Entry into force of new regulations and last year free of chargeFrom January 1, 2026 The CBAM target system is officially launched – the new Omnibus regulations will already be in force (the regulation will enter into force 3 days after publication, with application from 2026). 50 tons exemption It takes effect for imports made in 2026 – importers below this threshold no longer need to submit detailed quarterly reports or purchase certificates. Importers above the threshold maintain normal emissions records throughout the year, but they are not yet buying certificates in 2026. (in accordance with the extended transition period). In 2026, quarterly thresholds will not apply either. having certificates – this year is treated as a buffer year. Until December 31, 2026 However, companies must ensure that they have the status of authorized declarants (if they exceed the threshold) and are ready for their first settlement.
- 2027: First settlement of emissions (for 2026) and start of quarterly requirements. 1 February 2027 – Authorities begin selling CBAM certificates. Importers should gradually acquire them from that date. 31 March 2027 – end of Q50: importers must have certificates for at least 1% of emissions from Q2027 30. Similarly, on June 50 (1% of Q2+Q30 emissions) and September 50 (1% of Q3–QXNUMX emissions). SEPTEMBER 31, 2027 – deadline for submission CBAM annual declaration for 2026 and at the same time cancel the appropriate number of certificates for the entire year 2026. In practice, importers will be able to purchase the missing certificates until the end of October to meet this obligation. November 1 2027 – Unused certificates purchased in 2027 (e.g., for 2026) will be cancelled. Authorities will redeem any reported surpluses by November 30, 2027 (according to the Commission's proposal: applications by October 31, with reimbursement in November). Furthermore, 2027 is the first year of full system operation: importers will continue to deliver their certificates while meeting the 50% quarterly requirement and preparing to settle 2027 emissions the following year.
- 2028 and beyond: Normal CBAM cycle. From this moment on, the CBAM mechanism will run cyclically: during the import year, importers ensure that they have a sufficient pool of certificates (50% of emissions quarterly), 31 October they submit a declaration and redeem certificates for the previous year, they can declare surpluses for redemption, on November 1st unused units are cancelled. Annually by April 30 The Commission will assess whether the 50 tonne threshold still covers 99% of emissions – if not, it will adjust it before the following year (but only if the difference exceeds 15 tonnes). Between 2026 and 2034, they will also gradually Free ETS allowances withdrawn for sectors covered by CBAM, which will cause a proportional increase in the real burden of CBAM (CBAM is to reach 100% emission coverage only when free allowances disappear – hence the 50%/80% adjustment mechanism takes this into account temporarily). It is assumed that CBAM will be fully integrated with the ETS around 2034., when importers will pay for 100% of emissions (similarly to EU producers without free allocations).
- Controls and scope extension: W 2026. The Commission is expected to present an evaluation and possibly a proposal to extend the CBAM to additional products or sectors (e.g., other metals, chemicals). The potential implementation of the extension would take place after 2026 and will be the subject of separate arrangements. However, the current Omnibus reform is already laying the legal foundations (definitions of complex goods, anti-pacification mechanisms) that will facilitate CBAM coverage of a wider range of products in the future without excessive complications.
At this point, importers should focus on transition from the reporting phase to the financial settlement phase in 2026/2027The key is to ensure that the company has the appropriate status (authorization) or qualifies for an exemption by the end of 2025, and to plan a budget for purchasing certificates from 2027. These schedule changes provide some breathing space – the first expenses will come later – but they do not relieve the company of substantive preparations (collecting emissions data, adapting accounting/IT systems to support CBAM, etc.).
Summary
The CBAM Omnibus package brings significant simplifications and clarifications for importers, while maintaining the ambitious environmental goal of the mechanism. The smallest importers will be virtually excluded from the system (leaving them with only simple import volume monitoring), while larger importers will benefit from extended deadlines and more flexible emission reporting methods. Authorization and reporting procedures will be simplified (e.g., the ability to delegate tasks, fewer unnecessary administrative consultations), and financial risks will be minimized thanks to the possibility of spreading certificate purchases into installments and a surplus buyback mechanism.
For importers, the most important thing now is thoroughly familiarize yourself with new responsibilities and deadlines – especially with the 50-ton threshold, the new declaration calendar (October 31st), and the requirements for emissions data. It's worth assessing now whether your company will benefit from the exemption (which does not exempt it from monitoring import volumes) or whether it needs to prepare for the full CBAM regime. Regardless of the import volume, it is recommended to implement internal procedures for recording the carbon intensity of imported products and tracking the total import volume.
The Omnibus package showed that the European legislator is open to adapting regulations to business realities, without sacrificing the fundamental goal of climate policy. Importers should therefore actively use new facilitations (e.g. using default values where data is difficult to obtain) and at the same time ensure that all obligations – from authorization to timely redemption of certificates – will be carried out in accordance with the new guidelinesOrganizational and systemic preparations already in 2025 will allow for a smooth transition to the new CBAM regime from 2026 and avoid a rush in 2027, when the first actual emissions settlement will take place. Thanks to the above changes, the CBAM mechanism becomes more predictable and business-friendly, which should make it easier for importers to meet their obligations while supporting the achievement of the common goal – level playing field in trade and reduction of global CO₂ emissions.
Źródła: The changes described above are taken from official EU documents and expert analyses, including the European Parliament press release and the adopted text of the EP amendments (A10-0085/2025)
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