The CBAM Omnibus Amendment: What Changed in 2025 and Why It Matters for Exporters

By Ahmed Medhat · Published11 May 2026 · Updated 15 September 2026

The CBAM Omnibus Amendment: What Changed in 2025 and Why It Matters for Exporters

The exporter's guide to the structural changes that reshaped CBAM before its definitive phase began

In October 2025, the European Union adopted a substantial amendment to the original CBAM regulation. This amendment — formally Regulation (EU) 2025/2083, commonly referred to as the CBAM Omnibus — was published in the Official Journal on 17 October 2025 and took effect on 20 October 2025, just over two months before the definitive phase of CBAM began on 1 January 2026.

The Omnibus amended many provisions of the regulation. This article walks through four that change who is in scope and when buyers need data, explains what each replaced, then lists what else the Omnibus changed.

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1. The de minimis threshold was raised to 50 tonnes per importer per year

Before the Omnibus, goods of negligible value were exempt: an intrinsic value per consignment not above the limit in Article 23 of Regulation (EC) No 1186/2009, €150 (Regulation (EU) 2023/956 as originally adopted, Article 2(3)(a)).

The Omnibus replaced the €150 value threshold with a 50-tonne mass threshold applied per importer per year. Under the new rule, an EU importer who imports 50 tonnes or less of CBAM goods in total across the calendar year is exempt from CBAM obligations entirely — no authorisation, no reporting, no certificate purchase.

For exporters, this change has three immediate consequences.

The first is that small EU buyers may now drop out of CBAM scope entirely. If an EU customer was importing 20 tonnes of a CBAM good across the year, they are no longer a CBAM-active customer. The administrative burden on them disappears, but so does the conversation about supplying verified emissions data — there is nothing to verify against.

The second is that exporters with a portfolio of small EU buyers need to think about cumulative mass per importer, not per shipment. The threshold is per importer per year, summed across all consignments. An importer who buys 30 tonnes from supplier A and 30 tonnes from supplier B in the same year is over the threshold — even though no individual supplier exceeded it. The exporter's view of "are my customers in scope" is now an importer-level question, not a shipment-level one.

The third is that hydrogen and electricity are explicitly excluded from de minimis relief. The single mass-based threshold does not apply to those two sectors. Any volume of hydrogen or electricity imported triggers CBAM obligations.

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2. The first declaration deadline moved from 31 May to 30 September

The original CBAM regulation required EU importers to submit their first annual CBAM declaration by 31 May 2027, covering 2026 imports. The Omnibus pushed that deadline to 30 September 2027.

The CBAM declaration is where the importer states the embedded emissions of the goods it imported in the previous year, and 30 September is also the date by which it surrenders the certificates for them (Article 22(1)). If the importer declares actual emissions, those emissions must be verified (Article 8(1)), so it needs the exporter's verified data before it files. The later deadline moves that point by four months. The data still has to be collected, verified, and transmitted. The deadline moved; the work did not shrink.

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3. The quarterly holding requirement dropped from 80% to 50%

Under the original CBAM regulation, EU importers had to hold CBAM certificates in their account at the end of each quarter corresponding to at least 80% of the embedded emissions of all CBAM goods imported since the start of the calendar year. Importers had to buy certificates well ahead of the annual surrender date.

The Omnibus reduced this quarterly holding requirement to 50%, from 2027. It is measured either on default values without the mark-up or on the previous year's surrender for the same goods, with the Article 31 adjustment for free allocation taken into account (Article 22(2)).

This change does not affect the eventual total CBAM cost. The full surrender obligation at the September annual deadline is unchanged; what changed is the timing.

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4. Certificate sales were postponed to February 2027

Under the original regulation, CBAM certificate sales were scheduled to open at the start of the definitive phase on 1 January 2026. The Omnibus postponed the actual opening of certificate sales to 1 February 2027.

The 2026 calendar year is therefore a hybrid: CBAM obligations apply to imports from 1 January 2026, embedded emissions must be tracked and recorded, but no certificates can be purchased until 1 February 2027 — and the full surrender of certificates against 2026 imports is due by 30 September 2027.

The Omnibus also set how those certificates are priced. Article 21(1a), which it inserted, prices the certificates for 2026 imports at the quarterly average of the auction closing prices for the quarter in which the goods were imported. The Q1 2026 official price of €75.36 per tonne CO₂ equivalent, and the three 2026 quarterly prices that follow, are therefore the prices for 2026 imports, whenever in 2027 the certificates are bought.

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5. What else the Omnibus changed

The Omnibus is titled as "simplifying and strengthening" the mechanism, and it changed more than timing and scope:

• The certificate price. Article 21(1) keeps the weekly average of auction closing prices, now by reference to Delegated Regulation (EU) 2023/2830, and the new Article 21(1a) prices certificates for 2026 imports at the quarterly average of the quarter of importation.

• The carbon price paid in a third country. Article 9 was replaced. The reduction under Article 9(1) applies where embedded emissions are determined on actual emissions and the price was effectively paid, net of any rebate or compensation; Article 9(4) adds a route by reference to yearly default carbon prices.

• How embedded emissions are determined. Article 7(2) was replaced: embedded emissions in goods other than electricity are determined on actual emissions (Annex IV points 2 and 3) or by reference to default values (Annex IV point 4.1).

• Default values. The Omnibus replaced Annex IV point 4.1: a default value is the exporting country's average emission intensity for the good, increased by a mark-up set by implementing act, and where reliable country data cannot be applied, the fallback is the average of the 10 exporting countries with the highest emission intensities. The rates are in Implementing Regulation (EU) 2026/1740, Annex I, which replaced the table in IR (EU) 2025/2621 from 1 January 2026.

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6. What exporters should take from the Omnibus

The practical takeaways are three.

Map your EU customer base by annual cumulative mass per importer, not by shipment value. Customers whose CBAM imports do not exceed 50 tonnes a year are out of scope, except for electricity and hydrogen.

Re-baseline your verification and monitoring timelines against the September 2027 declaration deadline, not May 2027. There is more time than the original regulation provided, but the work is the same.

Treat the 2026 calendar year as the live data collection year: 2026 imports are priced at their quarter's published price (Article 21(1a)) and surrendered for by 30 September 2027. The question for an exporter is not "what will CBAM cost me" but "what is my verified data going to look like when my customer's declaration is filed in September 2027."

Exporters who use the extra months to collect and verify their 2026 data will have it ready for the September 2027 declaration.