EU proposes CBAM de minimis threshold & compliance simplifications
On 26 February 2025, the European Commission adopted a new package simplifying the Carbon Border Adjustment Mechanism (CBAM). The key proposal introduces a 50-tonne mass de minimis exemption for small importers—mostly SMEs and individuals—while keeping ~99% of embedded emissions in scope. Additional changes streamline declarant authorisation, emissions calculation, and financial-liability management. The Commission will conduct a full CBAM review later in 2025 to assess scope extension to other ETS sectors, downstream goods, and indirect emissions, with a legislative proposal expected in early 2026.
Photo: Tima Miroshnichenko / PexelsEU Commission simplifies CBAM with new de minimis threshold and compliance measures
On 26 February 2025, the European Commission adopted a new package of proposals to simplify the Carbon Border Adjustment Mechanism (CBAM) as part of a broader 'Omnibus' legislative initiative covering sustainable finance, sustainability due diligence, EU Taxonomy, and European investment programmes. The Commission has explicitly designed these changes to reduce administrative burden on SMEs and occasional importers while maintaining the climate and competitiveness objectives of the European Green Deal.
New 50-tonne de minimis exemption
The headline simplification introduces a de minimis threshold exemption of 50 tonnes mass for small CBAM importers. According to the Commission:
This means keeping around 99% of emissions still in the CBAM scope, while exempting around 90% of the importers.
This threshold targets importers who bring in small quantities of CBAM goods representing minimal embedded-emissions flows into the EU. The exemption directly addresses compliance friction for individuals and SMEs that have struggled with CBAM's operational requirements during the transitional phase (which began 1 October 2023).
Compliance facilitation measures
For importers remaining in CBAM scope after the de minimis cut, the Commission proposes:
- Simplified authorisation of declarants — reducing procedural complexity for third-country producers and EU declarants
- Simplified emissions calculation — easing the technical burden of calculating and reporting embedded carbon
- Streamlined financial-liability management — clarifying and reducing the administrative overhead of CBAM certificate purchase and surrender
These measures follow the learning period under the transitional regime and respond directly to stakeholder feedback collected during the pilot phase.
Anti-abuse and anti-circumvention strengthening
Parallel to simplification, the Commission proposes strengthened anti-abuse provisions and commitment to develop a joint anti-circumvention strategy with national authorities. This balances administrative relief with enforcement rigour, preventing importers from structuring purchases or supply chains to exploit the 50-tonne threshold.
Scope review and 2026 legislative proposal
The Commission signals a full CBAM review later in 2025 to assess:
- Extension to other ETS (Emissions Trading System) sectors
- Downstream goods scope
- Indirect emissions coverage
- Support mechanisms for exporters of CBAM products at risk of carbon leakage
A legislative proposal is expected in early 2026 reflecting the outcome of this review.
What this means for shippers
If you import fewer than 50 tonnes of CBAM goods (chapters 25, 72, 73, 76, fertilisers, hydrogen, and electricity) in a reporting period, you will soon be exempt from CBAM declarations and certificate purchases—audit your import volumes immediately to confirm threshold eligibility. For those above 50 tonnes, simplifications to declarant authorisation and emissions calculation will reduce compliance costs, but anti-circumvention rules mean you cannot segment shipments to stay under the threshold; ensure your declarations are consistent with your actual supply-chain structure. Plan for scope expansion in 2026 and monitor the Commission's sector-by-sector guidance. Check your CBAM classification and certificate-purchasing strategy now using our emissions-screening tool.
