CBAM: what will change? Overview of upcoming changes for importers

On 1 January 2026, the transitional period for the CBAM (Carbon Border Adjustment Mechanism) will come to an end. The entry into force of the full CBAM regulations will introduce new administrative and reporting obligations for importers of goods from outside the EU. At the same time, the European Commission has announced significant simplifications for small importers and changes in the rules for accounting for CO₂ emissions. Below we outline the key information on who will be subject to CBAM, what changes the EU is planning, and how to prepare.

What is CBAM and who does it affect?

CBAM (Carbon Border Adjustment Mechanism) is a key EU climate policy instrument aimed at preventing “carbon leakage”—that is, the relocation of carbon-intensive production outside the EU, where environmental regulations are less stringent. The mechanism aims to level the playing field between EU producers and importers by requiring accounting for CO₂ emissions associated with the production of selected goods imported into the EU.

CBAM currently applies to the following product groups:

• Cement,
• Iron and steel,
• Aluminium,
• Fertilisers,
• Electricity,
• Hydrogen.

From 2026, importers will be required to register in the CBAM system and purchase CBAM certificates reflecting the carbon footprint of imported products.

CBAM exemption for small importers

As part of the Omnibus legislative package, the European Commission has proposed a new exemption threshold for so-called “small importers.” If the annual quantity of CBAM goods imported (excluding hydrogen and electricity) does not exceed 50 tonnes, the importer:

• Will not be required to register in the CBAM system,
• Will not be required to submit declarations or purchase certificates.

It is estimated that nearly 90% of current CBAM reporters are small importers, accounting for only around 1% of total emissions covered by CBAM. Thanks to the proposed changes, the system will focus on entities that generate significant emissions.

Note: Importers exempt from CBAM obligations will still need to monitor their import volumes and register in the CBAM system if they approach the exemption threshold.

Changes for importers exceeding the 50-tonne threshold

Companies exceeding the 50-tonne annual threshold may also benefit from certain CBAM-related simplifications:

• Postponement of the obligation to purchase CBAM certificates—this requirement for 2026 emissions is expected to be deferred to 2027, allowing importers more time to prepare for the end of the transitional phase.
• Possibility to use default values (set by the European Commission) if actual emissions data are unavailable.
• Reduction of the requirement to maintain CBAM certificates in individual accounts during a given quarter from 80% to 50% of projected emissions.
• Extension of the deadline for submitting the annual CBAM declaration—from 31 May to 31 August (the first declaration for 2026 will be due by 31 August 2027).
• Ability to delegate reporting obligations to entities other than customs agencies, such as advisors or representatives (although the importer remains responsible for compliance).

CBAM timeline – what’s next?

The European Commission’s proposals still require approval by the European Parliament and the Council of the EU. A vote is expected in the second half of 2025. In the meantime, importers should:

• Monitor legislative developments,
• Collaborate with non-EU suppliers to obtain emissions data,
• Prepare for reporting obligations.

How to prepare for CBAM 2026? A checklist

CBAM is one of the most significant regulatory challenges facing companies importing goods from outside the EU. Regardless of whether a company will benefit from simplifications or be subject to full CBAM obligations, it is worth taking the following steps:

• Verify the CN codes of imported goods to check whether they fall under CBAM scope,
• Estimate the annual import volume and carbon footprint of products,
• Prepare for new reporting and registration requirements and certificate purchases,
• Track legislative changes—both EU-wide and national.

CBAM – how can we help?

CBAM represents one of the key regulatory challenges for importers in the coming years. Compliance with the new obligations requires supply chain analysis and close cooperation with business partners and tax and environmental advisors. We offer comprehensive CBAM advisory services combined with support in customs, VAT, and excise matters.

Learn #MORE >> https://www.mddp.pl/cbam-graniczny-podatek-weglowy/.

Authors: Agnieszka Kisielewska, Magdalena Wiszniewska