European Commission proposes higher thresholds and major simplifications to ease compliance
The European Commission has announced significant changes to the Carbon Border Adjustment Mechanism (CBAM), aimed at reducing administrative burdens for importers while maintaining the system’s climate objectives. The proposals—part of the broader ‘Omnibus’ package—are expected to benefit thousands of companies across the EU, especially smaller importers.
Raising the threshold: a fairer approach for small importers
One of the most impactful proposals is the plan to increase the CBAM threshold. Currently set at €150 per shipment, this threshold has proven disproportionately demanding for smaller importers. The proposed increase would exempt up to 80% of currently affected businesses—those whose emissions and import volumes are relatively low—without weakening the environmental effectiveness of CBAM.
The Dutch Emissions Authority (NEa) supports this development, particularly if a more practical weight-based threshold replaces the current value-based one. This would make compliance clearer and more proportionate, focusing CBAM obligations on those with substantial CO₂ emissions.
Simplifications in the omnibus proposal
In addition to the new threshold, the European Commission has introduced a range of proposed simplifications, including:
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Exemption for small importers: Companies importing under 50 tons of CBAM goods per year would be fully exempt from CBAM obligations. This could exclude up to 90% of importers while still covering 99% of total emissions.
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Streamlined monitoring: Easier use of standard values, removing the need for verification of emissions data.
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Simplified cost tracking: No need to separately collect data on carbon prices already paid.
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Flexible certificate requirements: The quarterly obligation to surrender 80% of certificates would be reduced to 50%.
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Advisors allowed: Importers may appoint advisors to handle CBAM declarations on their behalf.
Upcoming obligations and key Dates
From 1 January 2026, only companies approved as a CBAM declarant will be allowed to import CBAM goods into the EU. Applications for this status must be submitted via the new European CBAM register.
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The register is already open for logging in with eHerkenning.
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NEa will begin reviewing applications from 1 May 2025.
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A helpdesk and detailed application guide will also launch on 1 May.
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Submit your full application before 1 September 2025 to be approved in time for 2026.
If your company imports less than 50 tons of CBAM goods per year, NEa advises waiting until September to apply. This avoids unnecessary paperwork in case the exemption is officially adopted.
Stay informed
These proposals are still working their way through the EU legislative process. More clarity is expected after summer 2025. We will continue to monitor developments and provide updates.
