EU strengthens CBAM: new rules simplify carbon-border compliance

# EU Strengthens CBAM with Amendment Regulation 2025/2083

The European Parliament and Council adopted Regulation (EU) 2025/2083 on 8 October 2025, amending Regulation (EU) 2023/956 (the original CBAM Regulation). The amendment enters into force ahead of the CBAM's transition from the reporting-only phase to the compliance-and-cost phase on 1 January 2026. The text was published in the Official Journal L on 17 October 2025.

Background and Rationale

The original CBAM Regulation established a transitional period beginning 1 October 2023, during which importers and declarants were required only to report on embedded emissions in covered goods—no financial liability attached. During this reporting phase, the Commission collected quarterly data from reporting declarants to assess implementation and identify areas for simplification and strengthening.

"Based on the experience acquired and data collected during the transitional period on the distribution of importers of goods listed in Annex I of Regulation (EU) 2023/956 into the Union, only a small proportion of those importers account for the vast majority of emissions embedded in imported goods."

This concentration of emissions among few importers prompted the amendment to ensure proportionate compliance obligations.

Key Changes to CBAM Framework

The regulation specifically addresses the inadequacy of existing de-minimis thresholds. The current exemption under Article 23 of Council Regulation (EC) No 1186/2009 applies to goods of negligible value—those not exceeding EUR 150 per consignment—but the Commission determined this threshold does not ensure the CBAM applies to importers proportionate to their actual emissions footprint.

Amendment 2025/2083 revises CBAM's scope and threshold rules to:

• Simplify compliance for smaller importers and those with minimal embedded emissions
• Strengthen enforcement by ensuring the mechanism captures material emissions proportionally
• Align thresholds with the distribution of embedded emissions across the importer base

While the source excerpt does not detail every amendment article-by-article, the regulation's stated objectives indicate changes to:

• De-minimis and negligible-value exemption limits
• Reporting and certification requirements for declarants below certain thresholds
• Default values and embedded-emissions calculation methodology to reflect updated data
• Possible amendments to the list of covered goods in Annex I (HS chapters 25, 72, 73, 76 for cement, iron/steel, and aluminium; plus emerging scope on fertilisers, hydrogen, and electricity)

Who Is Affected

The amendment applies to all importers of CBAM-listed goods into the EU and EEA (text marked "with EEA relevance"). The changes take effect 1 January 2026, when the transitional phase expires and actual CBAM costs become due. Importers must ensure their systems and compliance procedures reflect the new thresholds and rules before that date.

What this means for shippers

If you import cement, steel, aluminium, fertilisers, hydrogen, or electricity into the EU, audit your 2025 shipments now against the revised CBAM thresholds in Regulation 2025/2083—compliance cost rises to real euros on 1 January 2026. Work with your customs broker and carbon-accounting partner to recalculate embedded emissions under the new methodology and confirm whether your consignments fall below any revised de-minimis limit. Declarants must register with the new authorised-declarant system and file certificates by 31 May 2026 for 2025 imports, or face non-compliance penalties. /cbam