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 changes were not cosmetic. They reshaped four operational elements of CBAM that directly affect how exporters are paid, when their buyers need data, and what kinds of shipments are in or out of scope. This article walks through each of the four major changes, explains what was replaced, and lays out the practical consequences for exporters to the EU.

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

Before the Omnibus, CBAM applied to any consignment with an intrinsic value above €150. That low threshold meant that essentially every commercial shipment of CBAM goods was in scope, including small specialist orders.

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 50-tonne 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.

For exporters, this four-month shift is more consequential than it sounds.

The CBAM declaration is the moment when the importer formally states the embedded emissions of the goods they imported in the previous year, and the moment when they must have surrendered enough CBAM certificates to cover those emissions. Before they can file the declaration, the importer needs verified emissions data from the exporter. Before they can verify the data, the exporter needs to have collected it. Before they can collect it, the exporter needs to have monitored it through the relevant calendar year.

The four-month deadline extension translates, in practice, to a four-month extension of the entire upstream chain. Exporters now have until roughly mid-2027 to finalise their 2026 verified emissions data — not mid-spring. Verifier engagements, monitoring plan submissions, and supplier data collection workflows that were planned around the original May deadline have a slightly more breathable schedule.

But this should not be read as a relaxation. 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. This created a cash flow burden — importers had to buy certificates well ahead of the annual surrender date and tie up working capital in a regulatory escrow.

The Omnibus reduced this quarterly holding requirement to 50%. Importers now need to hold half, not four-fifths, of their year-to-date emissions in certificates at each quarter's end.

For exporters, the relevance is indirect but real. The cash flow burden on importers was being passed back to exporters in pricing negotiations. A lower holding requirement reduces the working capital cost to the importer, which weakens the case for the importer to push that cost onto the supplier. It also reduces the urgency for importers to demand verified emissions data early in the year purely to right-size their certificate purchases.

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 — and timing affects negotiating posture.

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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.

For exporters, this is largely an administrative reshuffling on the importer side. But there is one strategic point worth noting. Because importers cannot purchase certificates in 2026 itself, their entire 2026 CBAM cost exposure crystallises in 2027 — and is paid against a 2026 average EUA price that they have already observed in full. There is no hedging value to early certificate purchase in 2026. The Q1 2026 official price of €75.36 per tonne CO₂ equivalent, and the three remaining 2026 quarterly prices that follow, will be the actual reference prices for surrender — not market spot prices at the moment of purchase.

For exporters in active price negotiations with EU buyers, this means the 2026 CBAM cost is no longer a moving target. It will be known with certainty by the time invoices for 2026 deliveries are settled.

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5. The simplification narrative versus the reality for exporters

The Commission described the Omnibus as a simplification package. The European Parliament and Council adopted it explicitly to reduce the administrative burden on importers, particularly SMEs. From the importer side, that framing is largely accurate. The 50-tonne mass threshold takes a meaningful number of small-volume importers entirely out of scope. The lower quarterly holding burden frees up working capital. The later declaration deadline gives the entire CBAM administrative apparatus more time to function.

From the exporter side, the framing is more mixed.

The simplifications on the importer side reduce the urgency of CBAM-driven supplier engagement, which is welcome for small suppliers but unwelcome for exporters who were positioning verified data as a procurement-competitive advantage. If an importer is below de minimis or has more cash flow runway, they may delay the conversation about verified emissions data — and the exporter loses an opportunity to differentiate.

At the same time, the Omnibus made no changes to the substance of the embedded emissions methodology, the default value mark-up schedule, the certificate price calculation, or the Article 9 carbon price deduction principle. All of those remain exactly as they were in the primary regulation. The Omnibus changed when and to whom CBAM applies. It did not change what CBAM does or what it costs.

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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 below 50 tonnes per year are now out of scope and no longer require CBAM data.

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 and the deadline is now closer than it appears.

Treat the 2026 calendar year as the live data collection year, with the full 2026 CBAM cost crystallising in 2027 against known quarterly prices. There is no longer a price uncertainty to hedge in 2026. The strategic 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."

The Omnibus did not relax CBAM. It re-timed it. Exporters who use the re-timing as breathing room will be ready in 2027. Exporters who use it as an excuse to delay will be exactly as exposed as they would have been under the original schedule — just compressed into a shorter preparation window.

If you need help structuring your 2026 data collection and verification timeline against the new September 2027 deadline, the DeCarbonPro CBAM Installation service is designed for exactly that workflow.