EU adopts CBAM simplification measures ahead of full implementation in 2026

General
23 October 2025

Following the recent EU’s Carbon Border Adjustment Mechanism simplification measures adopted by the European Parliament on 20 October 2025, FIATA would like to draw its members attention to the new developments in the CBAM and what they mean for the freight forwarding and logistics industry as we approach the definitive regime which takes effect as of 1 January 2026.


What is CBAM and what is included in the recent simplification measures?

The EU’s Carbon Border Adjustment Mechanism (CBAM) is designed to ensure that the carbon cost of certain imported goods reflects the price paid by domestic producers, helping to prevent carbon leakage. Currently in a transitional phase (2023–2025), importers are required to report the greenhouse gas (GHG) emissions embedded in their goods, but the surrender of CBAM certificates is not yet mandatory.

On 20 October 2025, the EU adopted simplification measures as part of the “Omnibus I” package. Approved by both the European Parliament and the Council, these changes aim to ease the administrative burden, particularly for smaller importers. One notable amendment introduces a de-minimis threshold: importers whose annual volume of CBAM-covered goods is under 50 tonnes are exempt from CBAM obligations, relieving many smaller businesses while still covering over 99% of emissions from the included products.

Under the CBAM, importers must report and offset the embedded emissions in certain imported goods, such as cement, steel, aluminium, fertilisers, electricity, and hydrogen. The newly adopted simplifications include clearer methodologies for calculating emissions, greater use of default values where verified data are unavailable, and streamlined reporting templates.


What does this mean for the logistics community?

Although importers remain primarily responsible for CBAM compliance, the mechanism will have a ripple effect across logistics and supply chains.

Freight forwarders may increasingly be asked to assist clients in collecting or verifying emissions data, liaising with suppliers outside the EU, and ensuring that relevant documentation accompanies shipments. CBAM compliance could therefore become an integral part of trade documentation and supply chain transparency processes.

To support its members, FIATA provides practical resources, including a CO₂ calculators repository and an interactive CO₂ calculator, allowing members to explore and familiarise themselves with available tools.


What to look forward to / key dates

  • The definitive CBAM regime starts on 1 January 2026. From that date, importers of CBAM-goods must be fully registered, declare embedded emissions, purchase and submit certificates. 
  • The simplification regulation is already adopted, and entered into force shortly after publication on 20 October 2025.
  • Certificates for 2026 imports are to be purchased starting 1 February 2027 (under the simplified rules) and declarations must be submitted by 30 September of the subsequent calendar year.
  • Logistics providers should now consider mapping their supply-chains (importers, origin countries, goods, emissions data), assessing whether goods in transit or handled fall under CBAM coverage, engaging with clients about readiness, and exploring how to develop services around CBAM compliance.
  • Further legislative developments are expected in 2025 regarding scope extension (downstream products, electricity sector) and methodology for emission calculations.

Building awareness and capacity around emissions reporting will be essential as the logistics sector adapts to this new regulatory environment. Forwarders that invest early in understanding the CBAM framework can position themselves as key partners for clients navigating carbon-related trade requirements.

FIATA will continue to monitor regulatory developments and work with relevant industry organisations to provide practical resources and solutions. For questions or comments on the topic, kindly reach out to [email protected].


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