The CBAM de minimis threshold introduced by the 2025 Omnibus I package replaces the old EUR 150 per consignment rule with a single mass-based limit of 50 tonnes of CBAM goods per importer each year, exempting around 90 per cent of importers while roughly 99 per cent of embedded emissions stay in scope.
What the 2025 Omnibus changed
The 2025 CBAM simplification arrived through Omnibus I, Regulation (EU) 2025/2083, published in the Official Journal on 17 October 2025 and in force from 20 October 2025, with the 50-tonne threshold applying from 1 January 2026. Its central change for small importers replaced the EUR 150 per consignment exemption in the original Regulation (Article 2(3)) with a single mass-based threshold of 50 tonnes of CBAM goods per importer per calendar year, covering cement, iron and steel, aluminium and fertilisers, while electricity and hydrogen remain in scope at any volume. Scoping and reporting support for organisations near this line sits within CBAM advisory.
The new de minimis threshold at a glance
The Commission estimates that around 90 per cent of importers fall below the threshold and are exempt, yet close to 99 per cent of embedded emissions in covered imports stay within scope, so the relief cuts administrative burden without weakening climate coverage. The change targets the many firms importing occasional small quantities, who would otherwise face full authorised declarant duties from 2026 despite minimal exposure.
| Feature | Original rule | Omnibus rule (definitive period) |
|---|---|---|
| De minimis basis | EUR 150 per consignment | 50 tonnes per importer per calendar year |
| Threshold goods | value based, all covered goods | cement, iron and steel, aluminium, fertilisers |
| Always in scope | not applicable | electricity and hydrogen |
| Importers exempted | not quantified | around 90 per cent |
| Emissions covered | high | close to 99 per cent |
Single-declarant simplifications
For importers that stay above the threshold, the Omnibus simplified the definitive regime without lowering the underlying obligation. Key measures include:
- The annual declaration deadline moved from 31 May to 30 September of the following year.
- Certificate purchase was deferred to 1 February 2027; certificates covering 2026 emissions are surrendered with the declaration by 30 September 2027.
- From 2027, the quarterly minimum certificate holding is 50 per cent, down from 80 per cent, of the embedded emissions imported so far that year, after the free allocation adjustment.
- The sell-back limit changed from one third of the previous year’s purchases to the number of certificates the declarant was obliged to buy under the quarterly holding rule.
Exempt status turns on tonnage alone. An importer that goes over 50 tonnes in a calendar year is subject to all obligations for all goods imported that year, not only the excess. Above the threshold, the importer declares actual installation data, verified by an independent accredited verifier rather than GreenSutra, or default values with a mark-up. A short scoping pass against the CBAM guide confirms whether annual volumes cross 50 tonnes. Every consignment counts toward the 50 tonnes, so repeat shipments add up across the calendar year.
Sources: Regulation (EU) 2025/2083 (Omnibus I) · European Commission CBAM