CBAM 2026: The Regulatory Shifts Every Importer Must Know

The European Commission just dropped some major CBAM updates, and honestly? They're actually trying to make life easier for businesses. The new rules simplify reporting thresholds, streamline emissions calculations, and adjust how CBAM certificates work.

If you're in manufacturing or trading high-carbon goods, these changes matter. The compliance landscape is evolving, and you need to stay ahead of it.

CBAM Threshold Changes: Cutting the Burden on Small Importers

Here's the big one: the new de minimis threshold is designed to get SMEs off the hook. Previously, it was €150 per shipment. Now it's annual, covering:

• 100 tCO2e annually, or
• 50 tonnes of material annually

This change removes about 180,000 businesses from CBAM reporting—that's 90% of importers! But here's the catch: they still capture 99% of emissions coming into the EU.

Simplifications for Large CBAM Importers

For those still in scope, the EU is introducing four key simplifications:

• Authorization of declarants
• Emissions calculations
• Reporting requirements
• Financial liability

Authorization of Declarants: Faster Approvals

Good news: the mandatory consultation with National Competent Authorities (NCAs) before approving CBAM declarants? Gone. This speeds up the authorization process significantly, so companies can get approved faster before the definitive phase kicks in on January 1, 2026.

There's also a new category: Authorised CBAM Declarants. These entities (established in an EU Member State) will handle full CBAM reporting obligations, including buying and surrendering CBAM certificates. Third-party experts (CBAM representatives) can take on reporting duties on behalf of declarants—once the EU sets up access rights for them.

Emissions Calculations: Adjustments to Default Values

The EU is tweaking how emissions are measured:

• Non-calcined clay (CN 2507 00 80) is out of CBAM scope—it's closely tied to ceramics, which isn't covered.
• Default values just got simpler. You no longer need to justify why you can't get actual emissions data.
• Default values will be based on the average emissions intensity of the ten highest-emitting countries with reliable data. This protects against carbon leakage without being overly harsh.

Big Shift for Downstream Steel and Aluminum Manufacturers

This is huge: downstream processing emissions for steel and aluminum won't need separate calculations anymore. Instead, reporting will focus solely on precursor materials used in production.

What this likely means:

• If your steel or aluminum production site isn't covered by an emissions trading system (ETS) in your country, your only reporting activity will be a mass allocation of precursor materials to finished products.
• EU-origin precursors will be treated as having zero embedded emissions, since a carbon price has already been paid under the EU ETS.

Verification Requirements for Emissions Data

• Verification of installation data from non-EU producers is still required.
• Verification of emissions calculated using default values? Not required—reducing the compliance burden.
• Electricity, as a CBAM-covered good, won't need to report indirect emissions associated with its production.

CBAM Reporting Deadlines and Certificate Management

To align CBAM reporting with the certificate surrender process, the annual CBAM declaration deadline is moving:

• From May 31 to August 31 (coinciding with the CBAM certificate surrender date)
• The repurchase deadline shifts to September 30
• The certificate cancellation date is now October 1, 2027

This extension gives importers and manufacturers more time to verify emissions data and complete reporting.

Changes to CBAM Certificate Purchasing Rules

Under the current system, importers must:

• Purchase CBAM certificates quarterly to cover at least 80% of their estimated emissions, and
• Only have the ability for the EU to repurchase one-third of excess certificates purchased in the previous year.

The proposed update lowers the quarterly purchase requirement to 50% and offers an alternative approach:

• Importers may choose to exclude the punitive default mark-up from calculations, or
• Base certificate purchases on the previous year's surrendered CBAM certificates.

These changes aim to prevent importers from over-purchasing certificates due to default value uncertainties.

CBAM Certificate Purchasing Schedule

• Sales of CBAM certificates will begin in February 2027
• Pricing for 2026 imports will be based on quarterly average EU ETS closing prices for the relevant import period

This timing creates some continued uncertainty, as importers will need to purchase certificates for 2026 imports before final verified emissions data is available.

Tracking Overseas Carbon Prices: New Default Values

To ease reporting for importers, default values for carbon prices paid abroad will be introduced. This allows importers to:

• Use predefined values for carbon taxes paid in non-EU jurisdictions, or
• Report actual carbon prices paid by producers, provided they can verify the data.

This change increases the importance of carbon price tracking by non-EU manufacturers in ensuring they remain competitive against EU producers under CBAM.

What This Means for Manufacturers and Traders

These CBAM updates will ease compliance for smaller importers while clarifying emissions calculations for larger businesses. However, the continued reliance on default values, evolving verification rules, and certificate purchasing complexities mean that manufacturers and traders still need accurate carbon data to avoid unnecessary costs.

The above proposed changes will now be voted on in European Parliament in advance of the changes being implemented. As the implications of these changes surface, we will continue to provide further market insights.

With CBAM deadlines shifting and reporting requirements evolving, accurate, reliable carbon data is more critical than ever.