Redrawing the Lines: CBAM Reform through the EU Omnibus Package

​​​​​​published on ​28 July 2025 | reading time approx. 3​​ minutes ​

With the Omnibus Package of February 2025, the EU revised key elements of the Carbon Border Adjustment Mechanism (CBAM). This article highlights the most important changes – from new de minimis thresholds and simplified reporting obligations to the implications for affected companies – and places them in the broader context of European climate policy​.​​

On 26 February 2025, the European Commission published the so-called Omnibus Package. 
This package of measures proposes various legal amendments in the area of sustainability and ESG. Among them is a revision of the CBAM. 
 

Background and Objective of the Omnibus Package  

The initiative was prompted by increasingly vocal criticism, particularly from industry stakeholders. They argued that various EU initiatives – especially CBAM – were too complex and imposed excessive administrative burdens and costs. With this package, the European Commission has responded to those concerns. 
 
The overarching goal was to reduce the complexity and economic burden of CBAM while maintaining the mechanism’s effectiveness. According to the Commission, the Omnibus Package provides relief for around 90% of affected companies while still covering 99% of relevant emissions. 
 

Proposed Amendments in Detail  

The most prominent change is the adjustment of the threshold. Currently, under Article 2(3)(a) of the CBAM Regulation, goods shipments with a value of €150 or more per consignment are covered – a threshold widely criticized as too low and impractical. In the future, importers will be exempt if they import no more than 50 tonnes of goods per year (new Article 2(3a) CBAM Regulation). Importers expecting to exceed this threshold in a given year must apply for authorization as a CBAM declarant. 
 
Additionally, it will be possible to fully delegate the submission of CBAM declarations – either to internal company units acting on behalf of the entire group or to external service providers. 
 
The deadline for submitting CBAM declarations will also be extended – from 31 May of the following year to 31 August (new Article 6 CBAM Regulation). The certificate holding requirement will be reduced from 80% to 50% of the expected certificates per quarter (new Article 22 CBAM Regulation). 
 
Another important change concerns the use of default values. The verification requirement for CBAM declarations will only apply if actual values – not default values – are used. Furthermore, if no better data is available, default values may also be used to determine the CO₂ price paid in a third country, which can be deducted (new Article 9 CBAM Regulation). 
 
The start of certificate sales, originally planned for 2026, is now scheduled for 1 February 2027 (new Article 20 CBAM Regulation). This extension is expected to ease the implementation burden for affected companies. 
 
The treatment of precursor products has also been addressed. Previously, this led to problematic outcomes when such products were manufactured in the EU, used abroad, and then re-imported as finished goods. The embedded emissions would have had to be included, with only the option of retroactive compensation. Annex IV of the revised CBAM Regulation now clarifies that such precursor materials are excluded from emissions calculations. 
 
Finally, unburnt clay and loam have been completely excluded from the CBAM scope, in recognition of their low emissions potential. 

 
Conclusion and Outlook  

The European Commission has proposed significant changes to the CBAM framework that could provide substantial relief for many affected stakeholders. 
 
It remains to be seen whether companies will perceive these changes as genuine relief and whether they will have the intended effect. 
 
However, it is still unclear if and when the proposals will be transposed into binding law. In particular, the postponement of certificate sales and the reduction of the holding requirement could lead to overlaps with the current rules. It is therefore advisable to continue monitoring developments closely and not to base strategic planning entirely on the assumption of regulatory relief. ​ ​