Navigating CBAM changes: what importers and manufacturers must prepare for

The European Commission’s recently proposed CBAM legislative updates introduce key simplifications aimed at reducing the administrative burden on businesses while maintaining the core objective of tackling carbon leakage. The updated rules will raise reporting thresholds, streamline emissions calculations, and adjust CBAM certificate management.

For manufacturers and traders in high-carbon industries, these changes signal an evolving compliance landscape that still demands careful planning and strategic carbon management.

CBAM threshold changes: reducing the burden on small importers

The key change in this update is the new de minimis threshold, designed to remove small and medium-sized enterprises (SMEs) from the reporting scope. Previously set at €150 per consignment, the new threshold now applies at an annual level, covering:

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

This change is expected to remove 180,000 businesses from the CBAM reporting scope, leaving only 10% of importers still required to report — while still capturing 99% of emissions imported into the EU.

However, importers below this threshold must still register as “occasional CBAM importers” in customs declarations and monitor their import volumes to ensure they do not exceed the new limit. The EU Commission’s customs data surveillance system will be used to track compliance, and will flag any importers at risk of exceeding the threshold to National Competent Authorities (NCAs).

Simplifications for large CBAM importers

The proposed CBAM changes introduce four key areas of simplification for in-scope importers:

1. Authorisation of declarants
2. Emissions calculations
3. Reporting requirements
4. Financial liability

Authorization of declarants: streamlining compliance

The requirement for mandatory consultation with NCAs before approving CBAM declarants has been removed. This change accelerates the authorization process, allowing companies to gain CBAM reporting approval more quickly ahead of the definitive phase starting January 1, 2026.

A new category of Authorised CBAM Declarants will be created. These entities, established in an EU Member State, will have full CBAM reporting obligations, including the purchase and surrender of CBAM certificates. However, CBAM representatives — third-party experts — will be able to take on reporting obligations on behalf of declarants, pending the establishment of EU access rights for these representatives.

Emissions calculations: adjustments to default values and scope exclusions

Revised emissions measurement rules

• Non-calcined clay (CN 2507 00 80) has been removed from the scope of EU CBAM, reflecting its close association with the ceramics industry, which remains outside the CBAM framework.
• The use of default values for emissions reporting will be simplified, removing the requirement to justify why actual emissions cannot be determined.
• Default values will be based on the average emissions intensity of the ten highest-emitting countries for which reliable data is available. This provides strong carbon leakage protection without being overly punitive.

Implications for downstream steel and aluminum manufacturers

A major shift in methodology proposes that downstream processing emissions for steel and aluminum will no longer need to be calculated separately. Instead, emissions reporting will focus solely on precursor materials used in production. Pending further information from the EU, it is expected that this will mean:

• If your steel or aluminum production site is not covered by an emissions trading system (ETS) in your country, the only required 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 will still be required.
• Verification of emissions calculated using default values will not be required, further reducing the compliance burden.
• Electricity, as a CBAM-covered good, will not be required to report indirect emissions associated with its production.

CBAM reporting deadlines and certificate management

Extended reporting deadlines

To align CBAM reporting with the certificate surrender process, the annual CBAM declaration deadline will be moved:

• From May 31 to August 31 (coinciding with the CBAM certificate surrender date)
• The repurchase deadline will shift to September 30
• The certificate cancellation date will now be 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:

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

However, the proposed update seeks to lower the quarterly purchase requirement to 50% and offer 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 will allow 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 means that manufacturers and traders still need accurate carbon data to avoid unnecessary costs.

• For smaller importers: Ensure you track annual import volumes to remain below the new de minimis threshold.
• For large manufacturers and traders: Prepare for changes in emissions reporting, including precursor-based calculations and new verification standards.
• For all businesses affected by CBAM: Investing in robust carbon accounting tools will be critical to navigating these updates efficiently.

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. CarbonChain’s CBAM reporting solution is built to streamline data collection, improve reporting accuracy, and forecast CBAM costs effectively. With our premium solution, you can transform your CBAM process from months to minutes.

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Manufacturers and traders should view these changes as an opportunity to reassess their carbon management strategies and invest in the tools necessary to stay ahead of the curve. With CarbonChain’s premium reporting tools, you can ensure your CBAM data is both compliant and commercially robust — helping you stay ahead as the industry transitions to low-carbon competitiveness.

‍Get in touch today to find out how CarbonChain can support your journey towards compliance and ongoing commercial excellence.