EU Introduces CBAM Simplification Regulation: What Exporters and Importers Need to Know

On October 17, 2025, the EU published Regulation (EU) 2025/2083, a key amendment that simplifies and strengthens the Carbon Border Adjustment Mechanism (CBAM) framework. The new rules take effect immediately, impacting all importers and authorised declarants dealing with CBAM Goods.

This update reflects the EU's commitment to reducing the compliance burden while maintaining stringent climate goals.

Key Changes to CBAM You Should Watch

1. Single Mass-Based Threshold Replaces De Minimis Exemption

Previously, goods below EUR 150 per consignment were exempt from CBAM requirements. This has been replaced by a single mass-based threshold set at 50 tonnes per importer per year, covering iron and steel, aluminium, fertilisers, and cement sectors.

If your total imports exceed 50 tonnes in these categories, CBAM obligations apply retroactively to all your imports—including those below the threshold.

2. Annual Review of the Threshold

The European Commission will annually assess the threshold to ensure CBAM covers 99% of embedded emissions in imported goods, adjusting the threshold as necessary.

3. Enforcement and Penalties

CBAM authorities will monitor import volumes closely, exchanging information across Member States. Artificially splitting shipments to avoid exceeding the threshold is punishable with substantial fines.

Importers exceeding the threshold without authorised declarant status face penalties ranging from three to five times the standard EUR 100 per tonne emission fine.

4. Authorised CBAM Declarant Requirements

Importers expecting to exceed the threshold must apply for authorised declarant status beforehand. Applications submitted by March 31, 2026, allow provisional imports until a decision is made.

Authorised declarants can delegate CBAM declarations to third parties within the EU but remain ultimately responsible for compliance.

5. Extended Filing Deadlines and Reduced Quarterly Purchases

Annual CBAM declarations and certificate surrender deadlines are now delayed to September 30 of the year following import. The quarterly minimum purchase of CBAM certificates drops from 80% to 50% of covered emissions.

6. Emissions Calculations Remain Flexible

You can still use either default or verified actual emissions values, but verification is only required for actual data. Default values are based on the highest emitting exporting countries when no verified data is available.

7. Deduction for Carbon Prices Paid Abroad

Importers may reduce CBAM certificate purchases due to the carbon price paid in third countries. The EU Commission will soon publish default carbon prices for certain countries to assist this calculation.

8. CBAM Certificates Market and Repurchase Rules

CBAM certificates covering emissions in 2026 imports will be sold starting February 1, 2027, priced on the average EU ETS auctions. Certificates can be repurchased under specified conditions, especially for importers who over-purchased, anticipating exceeding the threshold.

9. Penalty Harmonisation

Penalties now align with the EU ETS excess emission penalty regime (EUR 100 per tonne carbon emitted), with some relief for minor or unintentional non-compliance.

10. Sector and Technical Updates

• Non-calcined kaolinic clays are excluded from CBAM Goods due to low carbon intensity.
• Third-country operator registration requirements and accreditation rules for verifiers are clarified.

What This Means for Your Compliance Strategy

The CBAM Simplification Regulation eases reporting and compliance without diluting environmental integrity. At Artem Earth, we fully support smart compliance solutions that minimize administrative burden while keeping you audit-ready.

With these amendments, staying ahead requires:

• Tracking your total CBAM Goods tonnage annually and adjusting declarations accordingly.
• Timely application for authorised declarant status to avoid penalties.
• Leveraging automated platforms to generate accurate emissions reports and manage certificates.

For exporters and importers engaged with CBAM, Artem Earth is your partner in navigating these updates effortlessly, with tools designed to ensure accurate, timely, and simplified compliance.