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CBAM: Preparing for the Next Phase of Carbon Accountability

Oct 30, 2025

EU Finalizes CBAM Omnibus Amendments, Setting the Stage for Full Implementation

The European Union has officially published the CBAM Omnibus Regulation in the Official Journal, concluding the legislative process and paving the way for full implementation. These key amendments, now formally adopted, reshape the compliance landscape for importers of carbon-intensive goods — introducing new thresholds, timelines, and verification rules that will define the next phase of CBAM readiness.
The key regulatory amendments at a glance:
  • Certificate Purchase Timeline: Obligations begin in February 2027, applying retroactively to 2026 imports.
  • Extended Declaration Deadline: Annual CBAM declarations are now due by September 30, offering more time for data collection.
  • Threshold for Occasional Importers: A 50-ton annual import limit exempts smaller importers from full CBAM obligations.
  • Verification Requirements: Required only when importers use actual emission data, with verifiers registered in the CBAM registry.
  • Expanded Use of Default Values: Importers may rely on default emission values provided by the European Commission, simplifying compliance.
  • Quarterly Certificate Holding: Importers must hold CBAM certificates equal to at least 50% of embedded emissions at the end of each quarter.
  • Default Carbon Prices: The Commission will publish carbon prices for third countries with pricing schemes, which can be deducted from CBAM obligations
While this marks the completion of the primary CBAM legislation, several secondary acts are still pending — including detailed rules on benchmarks, verification protocols, and the recognition of third-country carbon pricing.

Strategic Implications for Businesses

Beyond the regulatory milestone, the Omnibus amendments redefine how companies must position themselves in the evolving carbon border framework. CBAM is not merely an additional compliance layer; it represents a structural shift toward (verified) carbon accountability in international trade. Businesses importing carbon-intensive goods into the EU will need to demonstrate traceable, reliable emissions data — and increasingly, this will become a prerequisite for market access.
The delay of the certificate purchase obligation to 2027 provides companies with temporary administrative relief but also a narrow window to prepare their data, systems, and supplier relationships. Those that use this period to integrate carbon data into procurement, reporting, and product management will turn compliance into a strategic asset. Reliable emissions data can support cost forecasts, supplier evaluations, and long-term decarbonization planning — all of which strengthen competitiveness in a low-carbon economy.
Building Readiness with DEKRA
To support companies in understanding their obligations and preparing for the transition period, DEKRA offers dedicated CBAM Fundamentals Training designed to build competence, confidence, and readiness for upcoming compliance requirements. Learn more
DEKRA also supports businesses in calculating or verifying Product Carbon Footprints (PCFs) across the product life cycle, enabling data-driven insights into emissions and supporting credible climate action. Discover more
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