This is some text inside of a div block.
To the overview

EU approves Omnibus changes to CBAM

On 29 September 2025, the European Council formally approved changes to the CBAM Regulation first proposed by the EU commission in their Omnibus I legislative package in February 2025**.** With this, all three EU bodies (commission, parliament & council) have agreed on enacting a number of amendments to the original CBAM Regulation (EU 2023/956).

The legislative act still has to be published in the EU's official journal and will then come into force on the third day after its publication. This is expected to happen in the coming days.

Among other changes, these amendments aim to reduce administrative burdens, smooth cash-flow impacts, and provide greater flexibility and clarity for importers navigating the transition into the definitive CBAM regime.

Motivation for Omnibus Simplification

The initial CBAM design was ambitious and climate-rigorous but faced criticism for being overly complex and burdensome, especially for smaller companies.

  1. Administrative burden & complexity – Reporting embedded emissions, verifying data, and using the CBAM Registry created heavy operational demands for importers.
  2. Cash-flow / working capital stress – The requirement to pre-purchase and hold 80% of CBAM certificates tied up significant working capital.
  3. Data uncertainties & verification constraints – Immature supply-chain emissions data made accurate reporting difficult, prompting the need for flexibility through default or prior-year values.
  4. Encouraging participation & fairness – Policymakers aimed to make compliance feasible for smaller importers to maintain fairness and broad participation.

In short: retain CBAM’s climate integrity, but ease the pain of implementation.

What has changed?

Below is a comparative breakdown of key changes introduced by the Omnibus I amendments. Use this as a quick reference.

Requirement Original CBAM (Pre-Omnibus) Amended CBAM (Omnibus I)
Threshold / De minimiss Based on €150 per consignment rule; small consignments might be exempt. Under the new mass-based threshold, importers handling 50 tonnes or less per year of CBAM-covered goods are exempt from most reporting and compliance obligations. However, electricity and hydrogen remain exceptions — all imports from these two product groups must still be reported, regardless of quantity.
Quarterly reporting deadlines Reports due at end of July following Q2, etc. Deadlines extended; reports will now be due end of October (or as per new schedule) to allow more time.
Annual declaration / reporting in definitive phase Expected annual declarations from 2026, but earlier quarterly obligations continued during transition. Firm adoption of annual reporting in definitive regime, replacing most quarterly reporting obligations.
Certificate holding buffer Importers must hold 80 % of embedded emissions in certificates each quarter. Reduced to 50 %, easing capital burden.
Start of certificate purchase / surrender Full purchase and surrender obligations begin 1 January 2026 for covered imports. For goods imported in 2026, first certificate purchasing/surrender postponed until February 2027, delaying cash pressure.
Use of default vs actual values Strong preference for actual emissions data; defaults used only when no reliable alternatives. Greater allowance for default values, and reliance on prior-year data when goods/country combo unchanged; verification required only when actuals are used.
Delegation / representative appointment Possible but less formally structured; importers largely must handle reporting directly. Formal option to appoint a “CBAM representative” who submits reports on behalf of importers (though legal liability stays with the importer).
Scope clarifications and exclusions Broad product coverage; certain materials or precursors subject to interpretation or inclusion risk. Some precursors/low-intensity items explicitly excluded (e.g. uncalcined clays); clearer rules on direct vs indirect emissions in electricity.

What’s next

  • The legislative act is expected to be published in the Official Journal of the European Union by the end of October 2025, after which the amendments will automatically enter into force on the third day following publication.
  • The definitive phase of CBAM will begin in January 2026, marking the transition from the current reporting-only period to the full compliance regime.
  • Importers will be required to surrender CBAM certificates covering all imports of CBAM-regulated goods from 2026 by February 2027.

Entdecken Sie Tanso –
Ihre Komplett­lösung für Nachhaltigkeit

Other articles that may be of interest to you

Stay up-to-date with news from Tanso.