CBAM simplification in force: annual 50-tonne threshold introduced

What happened

Regulation 2025/2083 of 8 October 2025, which simplifies the EU's Carbon Border Adjustment Mechanism (CBAM), was published in the Official Journal of the EU on 17 October 2025 and entered into force on 20 October 2025. The European Commission announced that the legislative process for the changes it had proposed in February 2025 as part of the Omnibus package was complete.

Main changes:

• 50-tonne threshold: Importers bringing in less than 50 tonnes per year in total of iron and steel, aluminium, fertiliser and cement products are exempt from CBAM obligations. Once the threshold is exceeded, the obligation applies for the whole year. Electricity and hydrogen are outside this exemption. The Commission says the threshold removes about 182,000 importers from scope while keeping more than 99 percent of covered emissions.
• Timeline: The annual CBAM declaration and certificate surrender are due by 30 September each year; the first declaration, for 2026 imports, will be made in 2027. Member States can start selling CBAM certificates from 1 February 2027.
• Authorised declarant: Importers that apply for the status by 31 March 2026 can keep importing until their application is decided.
• Quarter-end certificate holding requirement: Reduced from 80 percent to 50 percent of embedded emissions.
• Carbon price deduction: From 2027 the Commission may set default carbon prices for third countries with carbon pricing.

Who is affected

Turkish exporters do not file CBAM declarations themselves; the obligation lies with the importer in the EU. However, the exemption for small-volume importers may reshape Turkish suppliers' customer portfolios: EU buyers above 50 tonnes will continue to ask for verified, installation-level actual emissions data. With the establishment of an ETS in Türkiye, having the carbon price paid domestically taken into account in the CBAM calculation is also becoming an important issue for exporters.

What companies should do

• Find out whether your EU buyers are above or below the 50-tonne threshold.
• For buyers above the threshold, prepare your product-level embedded emissions data in time for 2026 imports; default values do not reflect your installation's actual performance.
• Plan the verification timeline and choice of verifier early.

For CBAM's move to the definitive period, see our news item of 1 January 2026. Alalëa supports embedded emissions calculations and supplier data preparation: CBAM readiness.