CBAM : New 50 tons threshold and system’s simplification
Regulation (EU) 2025/2083, published in the Official Journal of the EU on 17 October 2025, amends the 2023 CBAM regulation to simplify importers’ obligations and adapt the mechanism to its final phase, which starts on 1 January 2026.
The changes introduce a new de minimis threshold based on the mass of imported goods, clarify how to obtain Authorised CBAM Declarant status and set out updated rules for reporting and certificate management.
1. De Minimis Threshold: 50 tons/year/importer
Imports of goods covered by CBAM are exempt from CBAM obligations where the annual net mass imported by an importer does not exceed 50 tons.
This replaces the previous exemption based on the value of shipments (150 €) and is expected to benefit mainly to SMEs and private individuals, representing nearly 90% of importers.
Exceptions : Electricity and hydrogen remain fully subject to CBAM obligations regardless of volume imported.
2. Requirement to hold Authorised CBAM declarant status
From 1 January 2026, only Authorised CBAM Declarants may legally import CBAM goods.
A transitional tolerance applies for Q1 2026, provided the authorisation request is submitted before 31 March 2026. Beyond this limit, any CBAM import without authorised status will be unlawful and subject to penalties.
3. Annual Reporting and Certificates
Annual CBAM reports must be submitted in the CBAM Registry no later than 30 September of the year following the imports. The first deadline will therefore fall in September 2027 for imports made in 2026.
Declarants may choose between two reporting methods:
– based on actual emissions verified by an accredited body,
– based on default values, which do no require verification but generally require more certificates.
Certificates for 2026 imports will be available from February 2027.
Despite clarifications provided by the French Directorate General for Energy and Climate (“DGEC”), several uncertainties remain: the actual availability of accredited verifiers from January 2026, the ability for importers to anticipate CBAM costs, the stabilisation
