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CBAM: Amendment regulation entered into force

After Parliament and Council adopted the regulation simplifying the CO2 border adjustment mechanism, it was published in the Official Journal on 17 October 2025. The amendments entered into force on 20 October 2025.

What is the CBAM?

The Carbon Border Adjustment Mechanism (CBAM) aims to ensure that a CO2 levy is paid on imports from third countries into the EU. The CBAM covers aluminium, hydrogen, iron, steel and cement. The aim is to prevent emissions from being shifted from the EU to third countries which, unlike the EU, do not have an emissions trading system.

What does the amending regulation contain?

The amending regulation (Regulation (EU) 2025/2083 of 8 October 2025) is intended to simplify the CBAM, particularly for SMEs. To this end, a new ‘de minimis’ threshold is being introduced: imports of up to 50 tonnes per importer per year are not subject to CBAM regulations. Further changes concern the authorisation procedure, data collection, emissions calculation and testing requirements.

What do companies need to bear in mind in future?

From 1 January 2026, imports of CBAM goods above the new threshold will be subject to a declaration and certificate submission requirement. In order to import goods, approval as a CBAM declarant is necessary. Contrary to previous plans, goods can continue to be imported on a provisional basis until 31 March 2026 when an application is submitted.

Where can I find further information?

The amending regulation can be accessed here, and the press release from the Council of the European Union here. Further information on the changes can be found in our blog post from 4 March 2025.

Mirjam Büsch
Rechtsanwältin | Associate

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