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A new CBAM framework more friendly for SME? EU Parliament adopted the “omnibus packaging” with simplifications for SME and occasional importers

Settembre 18, 2025 /

The European Union is promoting a new CBAM legal framework in order to set out simplifications and reduction of administrative burden for smal medium enterprises and occasional importers.

The Parliament greenlighted, with 617 votes to 18 and 19 abstentions, the Omnibus I “simplification package” presentend on 26 February 2025 (see press release “Commission simplifies rules on sustainability and EU investments, delivering over €6 billion in administrative relief ).

From the CBAM standpoint, the amended law sets a new de minimis mass threshold whereby imports up to 50 tonnes per importer per year will not be subject to CBAM rules. It replaces the more generic current threshold exempting goods of negligible value.

In the adopted text (P10_TA(2025)0178 Carbon Border Adjustment Mechanism: simplification and strengthening European Parliament legislative resolution of 10 September 2025 on the proposal for a regulation of the European Parliament and of the Council amending Regulation (EU) 2023/956 as regards simplifying and strengthening the carbon border adjustment mechanism (COM(2025)0087 – C10-0035/2025 – 2025/0039(COD) it is laid down, in the preliminary point n.3 that: “A new threshold based on cumulative net mass of the imported goods in a given calendar year per importer (the ‘single mass-based threshold’) should be introduced in Regulation (EU) 2023/956, and initially be set at a level of 50 tonnes. A single mass-based threshold should apply cumulatively to all goods in the sectors of iron and steel, aluminium, fertilisers and cement. Where the net mass of all goods imported by an importer in a given calendar year does not cumulatively exceed the single mass-based threshold, such an importer, including any importer with the status of an authorised CBAM declarant, should be exempted in a given calendar year from the obligations under Regulation (EU) 2023/956 (the ‘de minimis exemption’). Where, within a relevant calendar year, an importer exceeds the single mass-based threshold, that importer should be subject to obligations under Regulation (EU) 2023/956 in respect of all emissions embedded in all goods imported during that relevant calendar year, including, in particular, the obligation to obtain the status of authorised CBAM declarant, the obligation to submit a CBAM declaration in respect of all emissions embedded in all goods imported in that relevant calendar year and the obligation to purchase and surrender CBAM certificates in respect of all those emissions”.

Now the before it entering into force, the text  has to be officially endorsed by Council. It will enter into force three days after publication in the EU Official Journal.

Below you can find a very short “CBAM dictionary” with the link to improve your practical knowledge:

  1. CBAM is the EU “[customs and compliance ]tool to put a fair price on carbon emitted during the production of carbon-intensive goods that are entering the EU, and to encourage cleaner industrial production in non-EU countries”.
  2. Definitive CBAM regime. Authorised CBAM declarant: From the 1 January 2026, thanks to EU regulation n. 2025/486 UE of 17 March 2025, the importers and indirect customs representative will be in the position to apply for the status of authorised CBAM declarant.
  3. Non-EU companies: since 1 January 2025 it is possible for non-EU companies register their data in the CBAM third countries operator portal.
  4. CBAM serious and repeted infringment: CBAM authorized declarant: the implementing regulation, serious and repeated infringements. Some points that should be taken into consideration by the authorized declarant.
  5. AEO and CBAM: AEO status it is not a mandatory datum for the submission of the report. But are not clear the reason for which the AEO company can’t enjoy more simplifications in the CBAM management.
  6. The customs classification plays a very important role for the compliance with CBAM. Indeed, the first step for a correct process is to check the customs code ( combined nomenclature).
  7. CBAM (carbon border adjustment mechanism) obligations require the good knowledge of the non-preferential origin.