On 10 September 2025, the European Parliament and the Council formally adopted a series of simplifications to the Carbon Border Adjustment Mechanism (CBAM), introduced as part of the Omnibus I package. These changes will take effect on 1 January 2026, coinciding with the start of the definitive CBAM phase and integration with the CERTEX system.
The aim of the reform is clear: reduce administrative burden for companies while maintaining CBAM’s climate effectiveness.
Key simplifications starting 1 January 2026
The new measures primarily benefit small and occasional importers and are designed to make CBAM compliance more manageable:
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Exemption for small importers
Companies importing less than 50 tonnes of CBAM goods per year will be fully exempt from CBAM obligations. This is expected to apply to around 90% of importers, while still covering 99% of emissions under CBAM. -
Simplified emissions monitoring
The use of default (standard) values will be permitted more broadly, often without requiring third-party verification. -
No more data on foreign carbon costs
Importers will no longer be required to collect information on carbon prices paid in the country of origin. -
Reduced certificate purchase requirement
The minimum requirement to purchase CBAM certificates quarterly will be lowered from 80% to 50%. -
Option to appoint a representative
Companies may now authorise a third party to submit CBAM declarations on their behalf. -
Additional simplifications
Improvements in the processes for authorisation, data collection, emissions calculation, liability, and reimbursement of carbon costs.
What does this mean for Dutch businesses?
The Dutch Emissions Authority (NEa) is currently evaluating how these changes will affect Dutch importers. Until 31 December 2025, the transitional phase remains in effect and existing CBAM obligations still apply. Now is the time for companies to prepare for:
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Full CBAM compliance from 2026
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Integration with the EU’s CERTEX system
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New rules around reporting, certification, and emissions tracking
What’s next?
Once published in the EU’s Official Journal, the simplification package will enter into force 20 days later. These changes mark an important first step in a broader review of CBAM planned for late 2025, which will explore:
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Expanding CBAM to downstream (processed) products
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Introducing anti-circumvention measures to prevent avoidance of CBAM rules
CBAM becomes fully operational in 2026
The end of the transition period and the start of the definitive CBAM phase on 1 January 2026 will bring significant changes. With the integration into CERTEX and the new simplifications in place, companies must ensure their systems, processes, and contracts are fully updated.
