CBAM for EU Importers: Navigating 2025’s Game-Changing Simplifications and What’s Coming in 2026

As we approach the final months of CBAM’s transitional period, 2025 has delivered both welcome relief for small importers and urgent new tasks for larger players. If you’re importing carbon-intensive goods into the EU, this year’s policy shifts could reshape your compliance strategy—and 2026 will bring the start of real costs.

Let’s break down what’s changed, what you need to do now, and how to prepare for the definitive phase ahead.

The 2025 Game Changer: 90% of Importers Just Got Relief

The biggest news this year: the EU introduced a 50-tonne de minimis threshold, exempting importers who bring in less than 50 tonnes of CBAM-covered goods annually.

This means more than 90% of small and medium importers are now free from CBAM’s

administrative burden.

What this means for you:

• If you import <50 tonnes/year of CBAM goods (cement, iron & steel, aluminium,

fertilisers, electricity, hydrogen), you’re exempt from CBAM reporting.

• SMEs and occasional importers can finally breathe easier and focus on business growth without extra red tape.

• But: exemptions require proof—so keep documentation ready.

Still in the Transitional Period: No Certificates Required Yet

For now, importers don’t need to buy CBAM certificates. That requirement will kick in for 2026 imports, with the first purchases deferred until 2027.

But don’t get too comfortable:

• Reporting remains mandatory for importers above the threshold.

• Supplier emissions data is now crucial—since from July 2025, only the EU method is accepted for calculating embedded emissions.

In short: no cash outflow yet, but plenty of reporting pressure.

What Importers Must Do Right Now

If you import  >50 tonnes annually:

1. Continue quarterly reporting of embedded emissions.

2. Register with your National Competent Authority (NCA) for CBAM registry access.

3. Start verifying supplier emissions data.

4. Budget for 2027 certificate purchases (based on 2026 imports).

If you import <50 tonnes annually:

• You’re exempt, but monitor your volumes carefully.

• Keep an eye on policy updates in case your category expands.

Looking Ahead: The Definitive Phase in 2026

From 1 January 2026, CBAM officially enters its definitive regime.

That means:

• Mandatory purchase of CBAM certificates (first payments in 2027).

• Full financial liability for the carbon embedded in your imports.

• Verified emissions data required—default values are no longer enough.

• Possible expansion to downstream products after the 2025 review.

This is when the real financial impact begins.

Expert Insights: How to Get Ahead

CBAM experts have been advising importers all year. Their key recommendations:

• Build robust carbon accounting systems now.

• Lock in supplier data agreements before 2026.

• Explore hedging strategies for carbon costs.

• Strengthen supply chain due diligence—carbon is becoming a procurement factor.

EU’s Next Steps: A Bigger Picture

By the end of 2025, the Commission will review CBAM and may propose:

• Expanding coverage to more goods and sectors.

• Measures to support EU exporters and balance competitiveness.

• Further simplifications to reduce admin burdens without weakening the mechanism.

For importers, this means staying alert—CBAM is not static policy, it’s evolving.

Strategic Recommendations

Immediate Actions (Q4 2025)

✔ Check if you’re above or below the 50-tonne threshold.

✔ Collect supplier emissions data (use EU method).

✔ Register with your NCA.

✔ Test your reporting systems and model carbon costs.

Medium-Term (2026–2027)

✔ Optimize sourcing toward low-carbon suppliers.

✔ Consider financial hedging against carbon price swings.

✔ Invest in carbon management software.

✔ Deepen supplier partnerships to secure reliable emissions data.

The Bottom Line

2025 was a year of simplifications and breathing room, but 2026 will be the year CBAM gets teeth.

• Small importers? You’re in luck—for now.

• Large importers? The countdown to real costs has already begun.

Use this transitional period wisely: build systems, strengthen supply chains, and prepare financially. Those who plan ahead will not only stay compliant but gain a competitive edge in a carbon-priced market.

The carbon economy is here. The question isn't whether you'll adapt it's whether you'll lead or follow. Make your move now, because January 1, 2026, isn't waiting for anyone.