EU CBAM Proposal: Key Changes and Implications
Explore the proposed updates from the recent Omnibus Simplification Package and how they affect CBAM
13th March 2025
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Explore the proposed changes
- Major Proposed Changes
- New Reporting Deadline
- CBAM Certificate Purchasing Delay
- Digital Operator Registration
- Third Country Recognition
- Reduced Holding Requirement
- Reporting for Importers
- Emissions Verification
- Non-Calcined Kaolinic Clays
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On the 26th February, the EU proposed a set of targeted amendments to the Carbon Border Adjustment Mechanism (CBAM), informed by insights gained during its Transitional Phase. These changes aim to simplify compliance, reduce unnecessary burdens, and align CBAM more effectively with the EU Emissions Trading System (ETS) while ensuring its environmental objectives remain intact.
Overall, the amendments that were part of the Omnibus Simplification Package reflect practical policymaking—they are responsive to business feedback and grounded in real-world implementation challenges. These proposed changes introduce meaningful simplifications, address practical challenges, and reflect a responsive approach to regulatory development.
If approved, CBAM-affected businesses both within and outside the EU will see reduced reporting burdens, clearer carbon pricing rules, and greater certainty on compliance requirements. The amendments now need to pass through the EU’s legislative process, which will take several months at a minimum.
Major proposed changes
| Proposed Change | Overview | Action if approved |
|---|---|---|
| New Mass-Based Threshold | Businesses importing less than 50 tonnes of CBAM goods annually into the EU will no longer be subject to CBAM obligations. | CBAM importers should assess if their annual imports exceed 50 tonnes to determine if they remain in scope. |
| Exclusion of Emissions from Finishing Processes for Steel and Aluminium | Manufacturers engaged only in finishing processes for steel and aluminium products will no longer need to report emissions from these processes, only from their precursors. | Non-EU manufacturers engaged only in finishing should revise their reporting processes to exclude these emissions. |
| Default Carbon Pricing Values | The EU may introduce default carbon prices for third countries from 2027, based on best available data. | CBAM importers and non-EU manufacturers should monitor default carbon price values and incorporate them into reporting where primary data is unavailable. |
| Stronger Penalties for Non-Compliance | The EU is enhancing its authority and increasing the severity of financial penalties under CBAM. | EU importers of CBAM goods not yet reporting to the CBAM Registry must act now or face steep financial penalties |
| Exclusion of ETS-Covered Precursors from CBAM Accounting | Emissions reporting for precursors produced in EU ETS countries, or those with fully-integrated equivalent system, will no longer be required. | Non-EU manufacturers should exclude ETS-covered precursors from emissions reporting. |
CBAM Update Guide
Access a comprehensive breakdown of these key proposed changes to the CBAM, and gain a deeper understanding of the broader impact they may have on your business.
Additional changes
In addition to the major proposed changes, several additional updates could impact CBAM compliance and implementation. These refinements aim to enhance clarity, streamline processes, and address industry concerns. Here’s a brief look at other key adjustments businesses should be aware of:
New reporting deadline
The annual CBAM declaration deadline has been moved from May 31 to August 31, providing businesses with additional months to collect accurate emissions data, secure verification, and purchase the necessary CBAM certificates.
Delay in obligation to purchase CBAM certificates
In a move to provide financial relief, importers will not be required to purchase CBAM certificates for carbon emissions on imported goods until 2027, even though these imports will be subject to carbon pricing from 2026 onwards. This delay offers businesses more time to adjust their financial strategies while ensuring emissions accountability remains intact.
Digital operator registration & data sharing
The introduction of a digital CBAM Registry formalises operator registration, data uploads, and information sharing. By enabling direct uploads from operators, the new system aims to reduce the administrative workload for importers, making compliance more efficient and transparent.
Recognition of carbon pricing paid in third countries
Another major reform is the recognition of carbon pricing paid in third countries at any stage of the supply chain. This ensures that CBAM imports face costs aligned with the EU ETS, preventing overcharging and fostering fair competition between EU-produced and imported goods.
Reduced certificate holding requirement
To ease financial pressures, the EU has also reduced the required holding of CBAM certificates from 80% to 50% of total emissions at the end of each quarter. This adjustment lowers the upfront financial burden on businesses, improving cash flow management and reducing the strain of compliance.
Delegated reporting for importers
On the administrative front, importers will now be allowed to appoint third parties to submit CBAM declarations on their behalf. While legal responsibility remains with the importer, this delegated reporting option alleviates operational complexity and provides flexibility in meeting regulatory obligations.
Emissions verification limited to actual values
The verification process for emissions data is also seeing a crucial update. Only actual emissions data will require verification, with default values now exempt from this requirement. This practical amendment removes redundant verification processes, allowing businesses to focus on accurate and meaningful reporting.
Removal of non-calcined kaolinic clays from CBAM scope
Lastly, non-calcined kaolinic clay has been removed from the CBAM scope, further reducing the compliance burden for industries dealing with this material. This refinement highlights the EU’s commitment to ensuring that CBAM targets high-impact emissions while avoiding unnecessary regulatory complexity.
How Anthesis can help
These updates represent a more pragmatic and business-friendly evolution of CBAM, balancing the EU’s carbon pricing ambitions with the realities of global trade. Companies must stay ahead of these changes to leverage the additional time, financial flexibility, and reduced administrative burdens these reforms provide. As CBAM continues to take shape, proactive compliance and strategic planning will be key to navigating the evolving regulatory landscape.
If you’d like to understand how any of these changes impact your business and its CBAM requirements, Anthesis’ CBAM experts are available to help.
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