What the Omnibus Regulation Is
Commission Delegated Regulation (EU) 2025/2083 was adopted 8 October 2025 and published 20 October 2025. It amends the Carbon Border Adjustment Mechanism Regulation (EU) 2023/956 to simplify implementation and reduce administrative burden.
The regulation responds to feedback from nearly two years of transitional reporting. Companies and member states identified excessive complexity for small importers, tight deadlines, and unnecessarily detailed calculation requirements that did not materially improve environmental outcomes.
These amendments apply from publication. Some changes affect the final transitional reports due January 2026. Most changes take effect for the definitive period starting 1 January 2026.
The 50-Tonne Threshold
The most significant change introduces a de minimis threshold. Importers whose total annual imports of CBAM goods remain below 50 tonnes net mass are exempt from CBAM obligations.
This threshold applies per importer across all CBAM sectors combined. If you import 30 tonnes of steel and 15 tonnes of cement annually, your total is 45 tonnes and you are exempt. If you import 51 tonnes, you have full CBAM obligations on all imports.
The threshold is based on net mass (product weight excluding packaging) during a calendar year. It applies to the definitive period starting 2026. Transitional reporting obligations through December 2025 remain unchanged.
This exemption affects approximately 90% of importers whilst keeping 99% of emissions in scope. Small traders importing occasional shipments avoid administrative burden. Large importers of carbon-intensive goods remain fully covered.
The threshold does not apply to electricity or hydrogen imports. These are measured in MWh or specific units rather than mass, making mass-based thresholds inappropriate.
Extended Declaration Deadline
Declaration deadlines extend from 31 May to 30 September following each reporting year. This gives importers four additional months to gather supplier data, complete calculations, and submit declarations.
The first declaration under the definitive period covers 2026 imports and is due by 30 September 2027. Previously this would have been due 31 May 2027.
The extension recognises that obtaining verified emissions data from third-country suppliers takes time. Many suppliers are located in regions with limited verification infrastructure. Verifiers must schedule site visits, review documentation, and issue reports. Four months allows realistic timelines for international verification.
Quarterly certificate purchase obligations adjust accordingly. Instead of purchasing 80% of expected certificates by end of Q3 of the reporting year, the requirement reduces to 50%. This reduces cash flow burden and allows more accurate calculations before large certificate purchases.
Simplified Default Values
Default emission values simplify for the definitive period. Instead of country-specific and production-route-specific defaults, the Commission will publish defaults based on the average emission intensity of the ten highest-emitting exporting countries for each product category.
These defaults will be marked up above actual average emissions to incentivise providing actual data. The markup makes defaults deliberately less favourable than verified actual emissions whilst remaining simpler to apply than current complex default structures.
The simplification removes situations where operators must determine which specific default applies when production routes are unclear or multiple routes exist at one installation. Single default per product category reduces ambiguity.
Default values still allow deductions for carbon prices paid in country of origin where applicable. The carbon price relief mechanism remains unchanged.
System Boundary Adjustments for Steel and Aluminium
System boundaries for certain iron, steel, and aluminium products now exclude finishing processes. Finishing processes are final manufacturing steps that minimally alter the carbon content of products.
For steel, finishing processes that may be excluded include cutting, welding, painting, coating, and assembly operations on finished steel products. The embedded emissions of the steel input material are counted but emissions from these finishing steps are not.
For aluminium products, similar exclusions apply to surface treatment, forming, and assembly processes. The embedded emissions of unwrought aluminium are counted but subsequent processing is not.
This change recognises that these finishing operations add minimal emissions compared to primary production. Including them created disproportionate data collection burden for marginal environmental benefit.
The boundaries now align more closely with EU ETS boundaries for equivalent processes. EU installations performing similar finishing operations often fall below EU ETS thresholds and are not required to monitor emissions. CBAM should not impose greater monitoring burden on imports than domestic production faces.
Operators must still report whether finishing processes were applied and what they involved. But detailed emissions calculations for these steps are not required.
Clarified Indirect Customs Representative Obligations
The regulation clarifies obligations when indirect customs representatives act as reporting declarants. Previously, ambiguity existed about whether representatives could voluntarily take on CBAM obligations or whether importers could compel them to do so.
The amendments confirm that indirect customs representatives can agree to become the reporting declarant. This must be mutually agreed between importer and representative. It cannot be imposed unilaterally by either party.
When a representative agrees to be the reporting declarant, they assume full legal responsibility for CBAM obligations including obtaining authorisation, submitting declarations, purchasing certificates, and surrendering certificates. The importer remains responsible for providing necessary information about goods being imported.
This clarification helps companies using customs agents. Previously, uncertainty about representative obligations created reluctance among agents to handle CBAM goods. Clear rules enable commercial negotiation about who bears CBAM compliance responsibility.
Commission-Published Default Carbon Prices
For third countries with carbon pricing systems, the Commission will publish default carbon price values rather than requiring operators to document actual prices paid. This applies where a country has an established carbon pricing mechanism but obtaining individual installation-level documentation is burdensome.
Operators can still document actual carbon prices paid if these are lower than Commission defaults. The published defaults serve as a fallback when documentation is difficult but a recognised carbon pricing system exists.
This change reduces documentation burden for operators in countries like China where carbon pricing exists in certain regions but obtaining installation-specific payment records in formats acceptable to EU verifiers is challenging.
The Commission will assess which third-country carbon pricing systems qualify for published default prices based on coverage, transparency, and enforceability criteria. Systems that do not meet minimum standards will not have published defaults and operators must document actual payments or claim no carbon price relief.
What These Changes Mean
The simplification regulation reduces administrative burden without weakening environmental integrity. The 50-tonne threshold eliminates disproportionate compliance costs for smallest importers. Extended deadlines give realistic timeframes for international verification. Simplified defaults reduce ambiguity. System boundary adjustments remove marginal emission sources that created excessive data requirements.
These changes respond to implementation feedback. The transitional period revealed where regulatory requirements exceeded practical necessity. The amendments adjust requirements to focus on material emission sources whilst simplifying immaterial ones.
Companies should update their CBAM preparation based on these changes. If you are a small importer near the 50-tonne threshold, calculate whether you remain in scope. If you are submitting the first definitive declaration in 2027, you now have until 30 September instead of 31 May. If you are obtaining supplier data, verify whether simplified system boundaries apply to your products.
The regulation demonstrates regulatory flexibility. The EU Commission adapted requirements based on real-world implementation experience. Further adjustments may follow as definitive period obligations begin in 2026.