SUMMARY

On 20 October 2025, the revision of CBAM introduced under the Omnibus I package entered into force. The revised regulation is directly applicable. However, different provisions have different applicability dates. The final text of the revision is available here.

MORE DETAILS

FESI has updated its Q&A with some of the main changes (highlighted in yellow in the attached document). We expect the Commission to also update the official guidelines accordingly. Once this happens, FESI will once again revise its Q&A and share it with members if any additional details are available.

The revised Regulation introduces amendments to several provisions, notably in the following key areas:

New de minimis mass threshold (applicable from 1 January 2026): new annual de minimis mass threshold of 50 tonnes per importer, replacing the current threshold exempting consignments with a value of less than 150 euro. This means that importers whose total annual imports of CBAM goods in scope (iron, steel, aluminium, cement, and fertilisers) remain below the 50-tonne cumulative threshold will be exempt from CBAM obligations.

New CBAM representative figure introduced to support declarants.

Modified calculation of emissions and verification of emissions.

Revised rules on penalties' calculation.

New deadline to register as CBAM importer.

New deadline to purchase certificates for the definite period.

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NEXT STEPS

The revised regulation is directly applicable. However, different provisions have different applicability dates. Once and if the Commission also updates the official guidelines accordingly, FESI will inform members.

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