Big Changes Ahead for CBAM: What Importers Need to Know

The European Commission has announced significant changes to the Carbon Border Adjustment Mechanism (CBAM), aimed at reducing administrative burdens for importers while maintaining the system’s climate objectives. The proposals, part of the broader ‘Omnibus’ package, are expected to benefit thousands of companies across the EU, especially smaller importers.

Raising the threshold: a fairer approach for small importers

One of the most impactful proposals is the plan to increase the CBAM threshold. Currently set at €150 per shipment, this threshold has proven disproportionately demanding for smaller importers. The proposed increase would exempt up to 80% of currently affected businesses – those whose emissions and import volumes are relatively low – without weakening the environmental effectiveness of CBAM.

The Dutch Emissions Authority (NEa) supports this development, particularly if a more practical weight-based threshold replaces the current value-based one. This would make compliance clearer and more proportionate, focusing CBAM obligations on those with substantial CO₂ emissions.

Simplifications in the omnibus proposal

In addition to the new threshold, the European Commission has introduced a range of proposed simplifications, including:

• Exemption for small importers: companies importing under 50 tons of CBAM goods per year would be fully exempt from CBAM obligations. This could exclude up to 90% of importers while still covering 99% of total emissions
• Streamlined monitoring: easier use of standard values, removing the need for verification of emissions data
• Simplified cost tracking: no need to separately collect data on carbon prices already paid
• Flexible certificate requirements: the quarterly obligation to surrender 80% of certificates would be reduced to 50%
• Advisors allowed: importers may appoint advisors to handle CBAM declarations on their behalf

Upcoming obligations and key dates

From January 1, 2026, only companies approved as a CBAM declarant will be allowed to import CBAM goods into the EU. Applications for this status must be submitted via the new European CBAM register:

• The register is already open for logging in with eHerkenning
• NEa has begun reviewing applications since 1 May 2025
• A helpdesk and detailed application guide is now available
• Submit your full application now to be approved in time for 2026

If your company imports less than 50 tons of CBAM goods per year, NEa advises waiting until September to apply. This avoids unnecessary paperwork in case the exemption is officially adopted.

Stay informed

These proposals are still working their way through the EU legislative process. More clarity is expected soon. We will continue to monitor developments and provide updates.

Why choose SGS?

The customs environment is evolving rapidly. Through our SGS customs team, we provide expert support to ensure your business remains compliant with current regulations while staying ahead of emerging developments.

We provide dedicated customs support to suit your operational needs, whether as part of a specific project, investigation or simply adhoc support to solve a particular challenge.

Our customs consultancy team can provide:

• Tailored, ongoing customs support, available on a daily, weekly, or monthly basis
• Expertise in managing both short- and long-term customs-related projects
• Comprehensive pre-audit preparation and in-audit support
• System health checks to assess and ensure UK customs compliance
• Assistance with authorization applications and tailored training programs
• Tariff classification of goods
• Assistance with remote audits on specific customs issues
• Reviewing sample documentation
• Testing internal customs processes
• Delivering a detailed report with recommended actions

Find out more by visiting our e-Customs page.

Or please contact:

Andy Maber
Business Development Manger
Trade Facilitation Services
t: +44 (0)151 350 6666