CBAM Simplification 2025: Key Amendments and What They Mean for Your Business

Charlotte Anne Whitmore

14 Nov 2025

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7 MIN READ

Introduction

The European Union has published major amendments to the Carbon Border Adjustment Mechanism (CBAM) — via Regulation (EU) 2025/2083 — marking the final step in the formal adoption process on 20 October 2025. These changes aim to make CBAM more business friendly while preserving its climate integrity goal: preventing carbon leakage and ensuring imported goods face comparable carbon costs to EU produced goods.Here’s a deep dive into what has changed, what it means for your business, and what you should do next.

What is CBAM – in a nutshell

To understand the amendments, it helps to recap CBAM’s purpose and structure.

CBAM is an EU mechanism to ensure that imported goods with embedded greenhouse gas emissions face a cost similar to that borne by goods manufactured under the EU Emissions Trading System

Its aim is to prevent carbon leakage (when production shifts to jurisdictions with weaker climate policies) and protect EU industry competitiveness.

The goods initially in scope include cement, iron & steel, aluminium, fertilisers, electricity, hydrogen.

Timeline overview:

Transitional (reporting only) phase began 1 October 2023
Definitive phase with financial obligations begins for imports in 2026; certificate sales from 1 February 2027.

What changed in the 2025 amendment

The 2025 amendment under Regulation 2025/2083 introduces a number of simplifications and clarifications to ease business compliance.

Here are the key changes and how they impact businesses:

A single mass based “de minimis” exemption has been introduced: if an importer’s cumulative yearly net imports of CBAM covered goods do not exceed 50 tonnes, they are exempt from CBAM obligations (reporting, declaration, certificate surrender) for that year.
This threshold applies to goods in the iron & steel, aluminium, cement and fertiliser sectors (Annex I goods) but does not apply to electricity and hydrogen imports
The EU estimates this change will exempt approximately 182,000 importers (mostly SMEs and individuals) while still covering over 99 % of emissions from in scope goods.
Important caveat: if the threshold is exceeded during the year, all emissions from that importers’ CBAM covered imports in that year become subject to full obligations—not just those over the threshold.

What this means

For smaller importers in the eligible sectors, this is significant relief—fewer obligations, less reporting burden. But monitoring volume carefully remains essential.

Formal publication and in force date

The amendment (Regulation 2025/2083) was published in the Official Journal of the EU, with entry into force on 20 October 2025.

The simplified rules apply ahead of the full obligations starting 2026/2027—so businesses must begin preparation now.

Other key simplifications

Use of default emission values where verified supplier data is missing is formalised.
Clarification that third country carbon prices may be acknowledged (deducted) when properly evidenced.
The Commission must annually review the 50 tonne threshold to ensure it still covers at least 99% of emissions, and may adjust it via delegated act.
Improved flexibility around authorised declarants, reporting deadlines and certificate mechanisms.

What it means for your business

Whether you’re an EU importer, non EU exporter, or part of the upstream supply chain, the amendments bring actionable implications.

Reduced burden for smaller importers

If your annual imports of CBAM covered goods (from the eligible sectors) are below 50 tonnes, you may now be exempt from many CBAM obligations—enabling you to focus resources on growth or decarbonisation.

Cleaner methodology and enhanced predictability

With clearer rules on default values, carbon price deduction in third countries, and simplified thresholds, your internal processes (carbon data collection, supplier engagement, reporting) become more predictable and manageable.

Strategic advantage for proactive players

Importers or suppliers who act early to map embedded emissions, ensure documentation and engage suppliers on emissions data become preferred partners and are well positioned as CBAM moves into full force.For exporters and non EU suppliers: being “CBAM ready” (with emissions data transparency) is becoming a competitive differentiator.

Cost planning and compliance risk mitigation

Even with simplifications, for those above threshold the core obligations remain: you will need to calculate embedded emissions, procure certificates (starting with 2026 imports, certificates from 2027 onward), and manage supply chain data. Proactive planning helps mitigate cost surprises and compliance risk (including penalties).

Your action plan: What you should do now

To harness the opportunity and avoid risks, here’s a suggested roadmap:

Assess your import volumes and sector scope

Identify whether you import goods in the sectors covered by CBAM.
Calculate your cumulative annual tonnage of those goods. If under 50 tonnes, document this. If above or approaching, prepare for full obligations.

Map your supply chain and emissions data flows

Identify suppliers of in scope goods and whether you receive emissions data (direct/indirect).
Where data is lacking, use default values or plan data collection improvement.

Update your internal systems

Review carbon accounting and reporting tools.
Prepare for new deadlines, data formats, and possible verification of actual vs default values.

Engage suppliers and contracts

Require suppliers to provide emissions data, evidence of carbon pricing in third countries if applicable.
Consider contractual clauses to cover carbon data compliance, audit rights, decarbonisation incentives.

Budget for certificate cost and scenario modelling

Model costs for your embedded emissions, possible certificate price trends (linked to EU ETS allowance prices).
For importers above threshold: this isn’t just reporting—there’s a cost dimension.

Stay informed and monitor developments

Although the simplification regulation is adopted, implementing acts, delegated acts and sector expansions (downstream goods, other sectors) are still expected.
Changes in methodology, verification rules, scope extension should all be monitored.

Why this matters for global competitiveness

The CBAM amendments reflect a larger global trend: carbon costs linked to trade and supply chains are no longer niche—they are becoming core factors in international competitiveness.
By aligning import carbon costs with what EU producers face (via the EU ETS and CBAM), the EU sends a signal: you must price carbon too, or risk being disadvantaged.
For exporters into the EU or suppliers into EU importer supply chains: being able to demonstrate low carbon credentials, embedded emissions transparency, “CBAM ready” status, will be a growing competitive advantage.
For EU importers: the simplification helps, but the obligation remains—so the businesses that view this as a strategic opportunity (not just a reporting burden) will thrive.

Why your business should act now

The 50 tonne threshold and other simplifications reduce but do not eliminate CBAM obligations. Early preparation gives you lead time.
Supply chain decarbonisation and data collection take time—start now to shape materials, suppliers, processes, and reduce future exposure.
Regulatory risk: the framework is evolving, scope may expand (downstream goods etc.), so being ahead helps avoid scrambling.
Competitive advantage: showing you are CBAM compliant, transparent, low carbon ready is beneficial in procurement, tenders, partnerships.

Conclusion

With the publication of Regulation (EU) 2025/2083, the EU has officially introduced simplifications to the CBAM regime—flagging a transition from “let’s report” to “we’ll enforce”. The 50 tonne threshold, use of default values, verification clarifications and carbon price deductions are significant.However, the core message for business is: this is not a distant regulatory topic—it is here. The best time to act was yesterday; the next best time is now. Whether you import into the EU, export to the EU, or are part of the supply chain for in scope goods, taking proactive steps to understand your exposure, collect data, engage suppliers, budget for cost and align systems will give you not just compliance, but a strategic advantage.

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