CBAM Definitive Period in 2026 and the Omnibus Changes

The CBAM definitive period started on 1 January 2026, and it does not look like the regime first set out in 2023. The Omnibus simplification, Regulation (EU) 2025/2083, changed the threshold, the deadlines and the certificate rules, and a package of implementing acts adopted in December 2025 fixed the calculation, verification and default value rules. This article sets out what is now in force, what is still pending and what it means for importers and their non-EU suppliers.

CBAM definitive period at a glance

The 50 tonne threshold replaced the EUR 150 rule

In the transitional period, consignments with an intrinsic value of up to EUR 150 were exempt. The Omnibus replaced this with a mass-based threshold of 50 tonnes per importer per calendar year, counting cement, iron and steel, aluminium and fertilisers together. The Commission estimated that this removes about 90% of importers, mostly small and occasional buyers, while keeping around 99% of embedded emissions in scope.

The threshold is cumulative. An importer that crosses 50 tonnes in November is liable for every tonne imported since January, which is why buyers near the line applied for authorisation early. The Commission reviews the threshold each year and can adjust it by delegated act.

Authorised declarant status became the entry ticket

Only authorised CBAM declarants may import CBAM goods above the threshold. Applications go through the CBAM Registry to the competent authority of the Member State where the importer is established. Importers that applied by 31 March 2026 could continue importing while their application was assessed. After that date, authorisation must be in place before the threshold is crossed.

Indirect customs representatives may hold the status and act for importers. An authorised declarant can delegate the filing of the declaration to an EU-established third party but keeps legal responsibility.

Annual declaration and certificate deadlines moved

The original regulation set 31 May as the annual deadline. The Omnibus moved it to 30 September, and delayed certificate sales to 1 February 2027. The first full cycle therefore runs as follows.

1. Imports during 2026, with quarterly prices published by the Commission (EUR 75.36 for Q1, EUR 75.28 for Q2 and EUR 82.32 for Q3; the Q4 price is due in early January 2027).
2. From 1 February 2027, purchase of certificates for 2026 imports at the price of the quarter in which the goods were imported.
3. By 30 September 2027, submission of the first annual CBAM declaration and surrender of certificates.
4. By 31 October 2027, any request to repurchase excess certificates.

From 2027, the quarterly holding requirement applies at 50% of embedded emissions, down from the 80% in the original text, and certificate prices become weekly.

Verification is now mandatory for actual data

Actual embedded emissions declared from 2026 must be verified by a verifier accredited by a national accreditation body under Delegated Regulation (EU) 2025/2551. Verifiers may be based inside or outside the EU, but must hold EU accreditation. Under Implementing Regulation (EU) 2025/2546, the first verification of each installation requires a physical site visit, with remote or waived visits possible in later years under conditions.

This is the main bottleneck of 2026. Accreditation started only in the second half of the year, and in October 2026 only a handful of verifiers had announced accreditation. Commission guidance on verification and accreditation was published in August 2026. Producers that want their 2026 data verified before the September 2027 deadline should agree a verifier and a site visit date now.

Default values and mark-ups

Default values for the definitive period were set in Implementing Regulation (EU) 2025/2621, published on 31 December 2025, and corrected by Implementing Regulation (EU) 2026/1740 in July 2026 with retroactive effect from 1 January 2026. They reflect the average emission intensity of each exporting country for each product where reliable data exists, and otherwise the average of the highest-emitting exporting countries, with a mark-up on top.

No mark-up applies to electricity. The Commission must review the default values by the end of 2027. Importers who calculated 2026 costs with the original values should rerun them with the corrected tables.

The free allocation adjustment

EU producers still receive free ETS allowances in 2026, so importers get a matching reduction. Implementing Regulation (EU) 2025/2620 sets how this adjustment is calculated, using EU benchmarks for each product and production route. The adjustment shrinks as free allocation is phased out.

This schedule comes from the EU ETS Directive. A Commission proposal of July 2026 to revise the EU ETS would slow the phase-out, but it is a proposal only and the schedule above remains the law in October 2026.

What did not change in 2026

The Omnibus simplified CBAM but left its core intact. The six sectors and the Annex I CN code list are the same, apart from the removal of non-calcined kaolinic clays. The importer, not the foreign producer, still carries the legal obligation. The calculation method still follows EU ETS monitoring principles, with direct emissions for every sector and indirect emissions counted in the obligation for cement and fertilisers.

The link between CBAM and the EU ETS also stands. The certificate price follows the ETS auction price, and the obligation grows as free allocation to EU producers falls. For a supplier with high emissions per tonne, the 2026 bill may look modest because of the 97.5% CBAM factor, but the same emissions will cost several times more by 2030 at a similar carbon price. That is the main reason to invest in data and in emissions reductions now rather than after the first declaration.

Changes still under negotiation

Downstream extension and anti-circumvention

In December 2025 the Commission proposed extending CBAM to about 180 downstream steel and aluminium products from 1 January 2028, treating pre-consumer scrap as a precursor, and tightening rules against circumvention. The Council agreed its position in June 2026 and Parliament in September 2026, with Parliament seeking a much longer product list. Trilogue talks began in October 2026 without agreement. Producers of steel and aluminium articles not yet listed in Annex I should watch this file closely.

Carbon price paid abroad

The implementing rules on deducting a carbon price paid in the country of origin were published in draft in May 2026 and had not been adopted by late October 2026. The Omnibus also provides for default carbon price values for third countries from 2027.

What 2026 means for Turkish exporters

Turkey adopted Climate Law No. 7552 in July 2025, and its ETS Regulation entered into force on 27 August 2026, followed by a market regulation on 21 October 2026. The system covers installations above the national emissions threshold and starts with a pilot whose scope and duration are set by the Carbon Market Board. With free allowances expected during the pilot, Turkish goods should not count on a CBAM deduction for 2026 or 2027.

The more immediate issue is data. Turkish plants already reporting under the national MRV regulation have a head start, but they still need product-level embedded emissions, precursor data and a verifier visit. We cover this in our CBAM embedded emissions calculation service. EU buyers of Turkish goods can use our CBAM support for EU importers. The UK will run its own CBAM from 1 January 2027, with separate rules, so exporters selling to both markets will need to manage two systems.

The official texts are listed on the Commission's CBAM legislation and guidance page. For the basics, start with what is CBAM.