As a CBAM specialist and consultant, the year 2025 brought major updates to the Carbon Border Adjustment Mechanism and carbon emissions reporting, generating both uncertainty and important clarifications for producers and importers.
One of the most significant changes this year is the new CBAM reporting obligation threshold: now set at 50 tons or 100 tCO2e per year per EORI, replacing the previous threshold of €150 per shipment. This change is based on default values that are often considered punitive, suggesting that for materials like steel and aluminum, the actual threshold might end up being below 50 tons.
Although the number of affected companies has dropped significantly from around 200,000 to 20,000, the emissions coverage remains broad, still accounting for 99% of total emissions.
Another relevant point is the exclusion of EU-origin precursors from CBAM’s scope, as they’re already covered by the Emissions Trading System (ETS). This also positively impacts non-EU companies sourcing exclusively from EU materials, since the emissions intensity of these inputs is considered zero.
In 2026, the maximum CBAM cost for goods imported into the EU will be calculated using default values based on the average emission intensity of the top ten emitting countries, where data is available. Importers are strongly encouraged to invest in obtaining actual emissions data to avoid potentially high costs.
An important simplification starting this year is the exclusion of emissions from downstream processing of aluminum and steel products from CBAM. This significantly simplifies the emissions accounting process, narrowing it to just the precursor emissions involved in finished products.
Final CBAM costs will be heavily influenced by two variables: EUA prices and emissions intensity. While EUA prices are relatively predictable and manageable with financial instruments, emissions intensity remains a major challenge, as actual installation-level data is only available retrospectively.
Given the uncertainties around emissions intensity, strategic partnerships with reliable and verified data providers, like CarbonChain or Dubrink, are essential for reducing operational and financial risks.
Another key point is the deadline extension for the first annual CBAM declaration, now set for August 31, 2027. This gives companies extra time to collect and verify emissions data from 2026, providing greater operational flexibility.
As we approach the start of the definitive period in January 2026, we expect a wave of updates clarifying how CBAM will work in practice.
The European Commission is expected to publish key implementation guidelines in 2025, which will cover:
- Clarification of independent verification procedures for supplier data
- Procedures for authorization by national competent authorities
- Publication of financial benchmarks and guidelines for certificate acquisition
One source of frustration for business leaders: the financial benchmarks will not be released before July at the earliest.
We have urged the Commission on the urgency of these benchmarks so that companies can begin calculating their future CBAM obligations.
Once the definitive period begins, the Commission intends to review certain aspects of CBAM. Potential changes include:
- Assessing sector expansion and the inclusion of downstream goods based on carbon leakage risks
- Reviewing rules on indirect emissions
However, these changes are unlikely to happen before 2027.