Updates
What did the 2025 CBAM simplification package change?
The 2025 simplification package: the new de minimis threshold under Article 27a, the targeted exemption, and what it changes for small importers.
Applies to EU CBAM declarants and importers assessing eligibility for the Article 27a de minimis exemption.
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Direct answer
The 2025 simplification package introduced a de minimis exemption under Article 27a of the CBAM Regulation. An importer whose volumes fall below the threshold is exempt from becoming an authorised CBAM declarant and from surrendering certificates, though monitoring obligations still apply.
What the simplification changed
The package introduced a single mass-based de minimis threshold for each importer per calendar year, replacing earlier consignment-level thresholds. It also clarified the rules for representatives and the monitoring of importers below the threshold.
What is and is not removed
- Removed: authorisation requirement and certificate surrender below the threshold.
- Retained: scope of covered goods and embedded emissions methodology.
- Retained: monitoring and verification by national competent authorities, in particular to detect splitting of consignments to stay below the threshold.
How the cumulative threshold works
The threshold is applied per importer of record, per calendar year, and on a cumulative mass basis across all covered CN codes. Once cumulative imports cross the threshold within the year the exemption falls away from that point: the importer must be authorised as a CBAM declarant before any further import and the year's covered imports above the threshold are subject to the full declaration cycle.
Representatives and indirect customs representation
The package keeps the option to act through an indirect customs representative, who can hold the CBAM declarant authorisation on behalf of the actual importer. The representative bears the full set of declarant obligations for the imports it covers, including monitoring whether the represented importer crosses the de minimis threshold.
What an importer should do
An importer should track cumulative annual imports of covered goods. If imports remain below the threshold for the calendar year the importer relies on the Article 27a exemption; if the threshold is crossed the importer must be authorised as a CBAM declarant before any further import. Detailed mechanics and evidence requirements are set out in the Commission Q&A on Article 27a.
Anti-circumvention and consignment splitting
National competent authorities are explicitly tasked with detecting circumvention, including splitting a single commercial flow into multiple consignments or across multiple legal entities to keep each importer below the threshold. Where circumvention is established the exemption is withdrawn retroactively and the importer is treated as if it had been authorised from the start of the period in scope.