Regulation (EU) 2025/2083, adopted on 8 October 2025 and published on 17 October 2025, amends the original CBAM Regulation (EU) 2023/956. It enters into force on 20 October 2025 and aims to streamline compliance, reduce administrative burdens for small importers, and reinforce the mechanism’s environmental effectiveness as the EU transitions to full CBAM implementation from 1 January 2026.
De Minimis exemption for small importers
A central feature is the introduction of a “de minimis” exemption. Importers whose total annual imports of CBAM goods (iron and steel, aluminium, fertilisers, and cement) do not exceed 50 tonnes are exempt from CBAM obligations. This threshold does not apply to electricity or hydrogen imports, reflecting the unique characteristics of those sectors. The exemption is designed so that at least 99% of embedded emissions in imported goods remain covered by CBAM, preserving the mechanism’s environmental integrity.
Obligations for exceeding the threshold
If an importer exceeds the 50-tonne threshold within a calendar year, all imports for that year become subject to the full suite of CBAM obligations, including registration, reporting, and the surrender of CBAM certificates. Indirect customs representatives acting on behalf of importers must also comply and may be subject to penalties for non-compliance.
Monitoring and enforcement
The European Commission and national authorities are empowered to monitor imports and ensure compliance with the threshold. Customs authorities can block further imports if an importer exceeds the threshold without proper authorisation. The regulation also clarifies the use of default values and actual emissions for reporting and allows for the delegation of declaration tasks to third parties, provided certain technical criteria are met.
Reporting, verification, and certificates
Authorised CBAM declarants must submit annual declarations by 30 September for the previous year, including verified emissions data. The deadline for surrendering CBAM certificates is also 30 September. From 2027, each authorised CBAM declarant must ensure that the number of CBAM certificates in their account at the end of each quarter corresponds to at least 50% of the emissions embedded in all goods imported since the start of the calendar year - a reduction from the previous 80% requirement. The final surrender of the total required certificates is due by 30 September of the following year.
Registration deadlines
Any importer established in a Member State must apply for the status of authorised CBAM declarant before importing goods into the EU customs territory. If an importer expects to exceed the 50-tonne threshold, they must submit an application for authorisation before exceeding it. Importers and indirect customs representatives who submit an application for authorisation by 31 March 2026 may continue importing goods in 2026, even after exceeding the threshold, pending the decision on granting authorisation. If authorisation is refused, penalties apply.
Other notable changes
The regulation excludes non-calcined kaolinic clays from CBAM scope and adds electricity to the list of goods for which only direct emissions are counted. The Commission can adjust the mass-based threshold annually if trade patterns or emission intensities change significantly.
Significance
Regulation (EU) 2025/2083 streamlines CBAM compliance for small importers, strengthens enforcement, and maintains the mechanism’s environmental objectives, reflecting the EU’s commitment to preventing carbon leakage and supporting climate goals while reducing unnecessary administrative burdens.
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