13 November 2025

For UK exporters who have prepared for the EU’s Carbon Border Adjustment Mechanism (CBAM), a recent legislative update from Brussels – often dubbed the "Omnibus" package – brings both welcome simplifications and critical adjustments. While the core mission of CBAM remains, understanding these nuances is essential to ensure seamless trade with the EU from January 2026.

If your business has already invested in emissions tracking, data verification, and robust communication with your EU importers, you're in a strong position. However, the Omnibus isn't just bureaucratic tweaking; it introduces changes that demand action, particularly around reporting thresholds and refined data scope.

A Game-Changing 50-Tonne Exemption

Perhaps the most significant development is the replacement of the nominal €150 consignment value exemption with a new, cumulative annual mass threshold of 50 tonnes (net mass). This applies across all CBAM-covered goods (cement, iron & steel, aluminium, fertilisers, electricity, and hydrogen).

Action for Exporters:

• Urgent Dialogue with Importers: Immediately contact your EU customers (the CBAM Declarants) to ascertain if their total annual imports of CBAM goods (from all third countries, not just the UK) will fall below this 50-tonne threshold in 2026.
• The Impact: If their total imports remain under 50 tonnes, they are completely exempt from all CBAM reporting and certificate purchase obligations. This could significantly reduce administrative burdens for both parties, but it requires confirmation from your importer.

A Little Breathing Room for Importers with refined timelines

The Omnibus package also extends deadlines for EU importers.

• Annual Declaration: The deadline for submitting the annual CBAM declaration for 2026 imports is pushed from May 31, 2027, to September 30, 2027.
• Certificate Purchase: The obligation for importers to start purchasing CBAM certificates for 2026 emissions is delayed until February 1, 2027.

Action for Exporters:

• Data Provision Flexibility: While this primarily benefits your EU customer's cash flow and reporting cycle, it offers you a slightly more relaxed window for providing final, verified emissions data for the preceding year. However, your commitment to accurate, timely data remains crucial. Don't view this as an excuse to delay; view it as assurance that your well-prepared data will be received well in advance of their need.

Precision in Emissions: Refining Your Calculation Scope

For specific sectors, the Omnibus refines how embedded emissions are calculated:

• Downstream Steel & Aluminium: The calculation of embedded emissions for certain downstream steel and aluminium goods will now exclude emissions from specific finishing processes.

Action for Exporters:

• Review and Adjust Calculation Models: If you export downstream steel or aluminium, review your internal emissions calculation methodology. Adjust your system boundaries to exclude the newly specified final finishing processes. This could result in lower reported embedded emissions, making your products more competitive.

Ongoing Vigilance: Documenting UK Carbon Costs

The EU may introduce default carbon prices for third countries like the UK from 2027.

Action for the Exporter:

• Continue Documenting: Do not rely on potential default values. Continue your tracking and documentation of actual carbon prices paid under the UK Emissions Trading Scheme (ETS) for your exported goods. Providing actual, verified data ensures your EU customers receive the maximum possible deduction on their CBAM levy.

The Bottom Line

The EU Omnibus package streamlines and clarifies certain aspects of CBAM, offering some administrative relief and refining calculation methodologies. For UK exporters who have already done the heavy lifting of preparing, these updates represent a call to fine-tune your strategy, leverage the new 50-tonne exemption through active dialogue, and adjust your emissions accounting with precision. Staying informed and agile will be key to navigating this evolving landscape and safeguarding your vital trade links with the EU.