- Anyone importing under 50 tonnes a year of these goods falls outside the mechanism.
- The exemption applies from 1 January 2026, when the definitive regime begins.
- Hydrogen and electricity are not covered by the exemption and remain subject to the mechanism.
On 17 October 2025 Regulation (EU) 2025/2083 was published in the Official Journal of the European Union, amending the 2023 regulation on the carbon border adjustment mechanism, known as CBAM. The rule, adopted on 8 October, entered into force on 20 October and simplifies the system before it enters its definitive phase.
The main novelty is a de minimis exemption: importers who bring into the Union less than 50 net tonnes a year, in total, of iron and steel, aluminium, fertilisers and cement fall outside the mechanism. According to Spain’s Ministry for the Ecological Transition, the measure applies from 1 January 2026 and does not cover imports of hydrogen or electricity.
What CBAM is
The carbon border adjustment mechanism is a European instrument so that imported goods from certain sectors bear a cost for the emissions of their production comparable to that paid by Union producers within the emissions trading system. Its aim is to prevent European industry from losing competitiveness against countries with less demanding rules and emissions from simply shifting outside Europe.
Until now, the mechanism required importers of steel, aluminium, cement, fertilisers, electricity and hydrogen to report the emissions embedded in their goods. From 2026 the definitive regime begins, with financial obligations. The simplification regulation seeks to cut the administrative burden, above all for companies with small imports, without giving up the environmental objective. The intention is to keep the ambition of the mechanism while reducing compliance costs for those who import little.
What the exemption changes
For those who import small quantities, the exemption means being outside the regime: they will not have the mechanism’s obligations for those imports. It is a notable relief for small firms, workshops, distributors and small manufacturers that occasionally buy parts, profiles, fasteners or fertilisers from outside the Union, and that until now feared a disproportionate management burden. Even so, confirm with the carrier and the customs agent that the exemption is correctly applied in each declaration.
The threshold is calculated on each importer’s cumulative annual net mass, not per transaction, so importing several times a year can push it over. Nor is it a licence to split purchases: be clear about how much is imported in total, by all routes, before assuming you are within the limit.
What to review
It is worth taking stock of imports in the affected sectors to know which side of the threshold you are on, including goods that arrive indirectly through suppliers or distributors. Those who fall outside should document the calculation; those who exceed it will need to prepare for the obligations of the definitive regime, which include declaring emissions and acquiring certificates. The sooner the position is known, the sooner it can be decided whether it pays to group purchases, change supplier or take on the obligations.
The Ministry for the Ecological Transition publishes information and a guide to find out whether a company is affected, and the European Commission continues to develop implementing rules. It is a technical and changing area: consult your customs and sustainability adviser before assuming your company is outside, and review purchase contracts in case they pass on costs of the mechanism. For companies buying from European distributors, the chain may be indirect, so it is worth asking suppliers about the real origin of the goods.
Simplification lightens the load, but it does not remove the need to know how much is imported and from where.
This article is general information. It is not legal, tax or investment advice, and it does not take anyone’s particular circumstances into account.
