CBAM Regulation: Changes resulting from the omnibus package

With the Carbon Border Adjustment Mechanism (CBAM), the European Union is pursuing the goal of strengthening climate-friendly production within the EU and preventing the migration of CO2-intensive industries to countries with weaker climate protection requirements (so-called carbon leakage). This is based on Regulation (EU) 2023/956 of May 10, 2023 and Delegated Regulation (EU) 2023/1773 of August 17, 2023.

These regulations oblige importers of certain CO2-intensive products, such as iron, steel, cement, fertilizers, hydrogen and electricity, to pay a CO2 levy if the imported products originate from non-EU countries (Iceland, Liechtenstein, Norway and Switzerland are exempt).

Objective of the omnibus package

In order to minimize legal uncertainties, reduce the administrative burden and make the CBAM requirements more practical, the European Commission published the so-called Omnibus package on February 26, 2025. In addition to simplifications for companies, the innovations are also intended to promote innovation and support the competitiveness of European companies.

Significant changes due to the Omnibus package:

New de minimis threshold:

A central aspect of the Omnibus package is the introduction of a de minimis threshold: the CO2 border adjustment system is only to apply from an annual import volume of 50 tons of CBAM-relevant products. Previously, only low-value imports up to EUR 150 were exempt.

The new de minimis threshold, which is based on the imported CO2 emissions, means that small and medium-sized enterprises (SMEs) and individuals in particular will be exempt from CBAM obligations. Around 182,000 importers (90 %) are to be relieved of administrative obligations as a result of this regulation. Despite this relief, the effectiveness of the CBAM remains intact: according to estimates by the EU Commission, 99 % of CO2 emissions from the affected sectors will continue to be recorded.

A simplified approach to determining specific emissions for CBAM products

Simplifications are also planned for companies still falling under the CBAM regime. This includes, in particular, a simplified approval procedure for declarants and the reduction of associated obligations. In addition, importers will be able to use standard values for specific emissions from CBAM products. Detailed individual calculations no longer need to be submitted.

Avoidance of double pricing

The Omnibus package also includes specific regulations to avoid double pricing. Emissions from upstream products that are already covered by the EU Emissions Trading System (EU ETS) are explicitly excluded. The EU also provides for the publication of CO₂ prices in the exporting countries in order to ensure transparency and comparability.

Delegation of the CBAM Declaration

Another key point of the Omnibus package is the option of involving an external service provider in the submission of CBAM declarations. It will therefore be possible to delegate the submission to third parties. A CBAM representative must fulfill certain requirements. For example, they must be based in the European Union and meet certain technical requirements. In particular, registration will be required. However, the CBAM declarant remains responsible for the CBAM obligations. 

The simplification should also be of interest to corporate groups, which can now process the reports for all companies via an internal CBAM representative.

Postponement of the start of sales for CBAM certificates

The original plan was to start selling CBAM certificates in January 2026. In order to minimize implementation risks and improve the exchange of information between the currently active CBAM registry and the future shared platform, this date has been postponed to February 2027. This gives companies more time to prepare for the new requirements.

With the changes provided for in the Omnibus package, the EU Commission is addressing key challenges in the implementation of the European carbon border adjustment mechanism. The simplified reporting and calculation obligations as well as the postponed start of the sale of CBAM allowances will help to reduce the implementation effort for companies without jeopardizing the mechanism’s actual objective. In particular, the relief for SMEs and the possibility of delegating administrative duties are likely to be positively received by the business community.

At the same time, it remains to be seen how the new regulations will be applied in practice and whether further adjustments will be necessary. Companies should now examine what impact the Omnibus package will have on them and how they can efficiently implement CBAM requirements against this backdrop.