CBAM - Omnibus Initiative
Focus on simplification and effectiveness
The European Commission's Omnibus Initiative aims to simplify the Carbon Border Adjustment Mechanism (CBAM) while maintaining its effectiveness. These reforms entail significant changes that include both simplifications for companies and stricter enforcement of the regulations.
Important changes
One of the key changes is the introduction of a de minimis limit for importers who import less than 50 tonnes of CBAM goods per year. This measure reduces the bureaucratic burden for small importers, while still covering 99% of emissions. Compliance will be facilitated through simpler emissions calculations, simplified authorisation of registrants and simplified financial management. In addition, enforcement of prevention and circumvention measures will be strengthened to ensure fair competition.
Contents of the omnibus package
The European Commission's omnibus package includes several key points:
- De minimis threshold: A new threshold of 50 tonnes for small CBAM importers means that importers importing less than 50 tonnes of CBAM goods per year are exempt from CBAM obligations. Despite this exemption, around 99% of imported emissions remain regulated.
- Expansion of the CBAM goods catalogue: The current catalogue includes iron and steel, cement, aluminium, electricity, fertilisers and hydrogen. By 2030, the catalogue is to be expanded to include all goods covered by EU emissions trading, including chemicals, plastics, paper and pulp, glass, ceramics and textiles.
- Simplification of processes: The authorisation of CBAM declarants and the management of financial obligations will be simplified. The purchase of CBAM certificates does not start until February 2027 and CBAM declarations are now due by October instead of May. Companies only have to cover 50% of estimated emissions with certificates instead of 80%. CO₂ taxes already paid from supply chain countries can be credited.
- Standardised emissions calculations: From 2026, country-specific average values can be used if actual data is not available. These values are based on the average emissions intensity in each country. Importers are still obliged to endeavour to obtain actual emissions data from their suppliers.
Future obligations for companies
From 1 January 2026, more far-reaching obligations for companies will come into force:
- Status as an ‘authorised CBAM notifier’ must be available in order to import CBAM goods into the EU.
- Calculation of the embedded direct and indirect emissions of the imported goods into the EU
- Verification of the specified data on direct and indirect emissions by an accredited testing centre.
- Purchase of the corresponding number of CBAM certificates via a central platform.
- Preparation and submission of an annual CBAM declaration by 31 May of each calendar year.
These reforms bring relief, but also new challenges for companies. It is important that companies reassess their CBAM obligations and prepare for stricter enforcement. The proposal has not yet entered into force and still needs to be discussed politically in the European Parliament.