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CBAM – changes from January 2026

by Tadeusz Piekłowski

28 October 2025

The European Parliament and the Council have published a new regulation within the framework of the Omnibus I legislative package to modify the CBAM mechanism. The modifications are designed to simplify and strengthen the rules in the definitive period which will begin on 1 January 2026.

What is going to change?

1. New de minimis exemption threshold

The regulation sets a new threshold for exemptions from CBAM obligations. The exemptions so far have applied only to imported goods of real value up to 150 euro. The next year will see the exemption based on a weight threshold. Importers will be exempt from the obligations if the net weight of imported CBAM goods does not exceed 50 tonnes annually (excluding electricity and hydrogen).

2. Rules for obtaining CBAM certificates

CBAM certificates will be available for sale in the EU from 1 February 2027. This means that certificates of 2026 emissions will be available for purchase in 2027. From that year onwards, certificates will be purchased on an on-going basis, and CBAM declarants will have to maintain at least 50% of certificates corresponding to the current emissions, taking account of the free EU ETS allowances.

3. Default data in place of actual data

Another novelty will be the option to use default data to determine embedded emissions without reaching out to and checking data from suppliers (excluding electricity). Declarants may choose between actual and default data. The final default values have not been published yet.

4. Deadlines

CBAM deadlines have been postponed – the annual declaration will have to be filed and certificates will have to be submitted for redemption by 30 September of the year after import (it used to be 31 May). Unused certificates will be cancelled on 1 November.

What does it mean?

2026, being the first year of the CBAM definitive period, gives importers some relief, but the beginning of 2027 will bring about real financial obligations. In the 1st quarter of 2027, companies will have to start buying CBAM certificates for all imports of 2026 and current deliveries of 2027. They will need to have certificates covering at least 50% of emissions embedded in imported goods. Additionally, importers in their capacity of authorised CBAM declarants, will file the first CBAM declaration in 2027.

The upcoming changes to the CBAM system trigger new obligations and risks for importers, especially when it comes to reporting and clearing emissions. It is worth getting ready for the new rules, review your processes and make sure that you have the right data and tools available. By engaging specialists you can cut the risk of errors and help yourself adjust to the CBAM requirements. You are welcome to contact our team of experts.

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Tadeusz Piekłowski

Customs agent (Poland)

Senior Associate

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