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With the end of the transition phase of the Carbon Border Adjustment Mechanism (CBAM) on 31 December 2025, the regular phase will begin on 1 January 2026. From this date onwards, only authorised CBAM registrants will be allowed to import goods falling within the scope of the CBAM Regulation into the customs territory of the European Union. The previous quarterly reporting requirement will be replaced by an annual CBAM declaration, which must be submitted by 30 September 2027 for goods imported in 2026.

The omnibus reform introduced a mass-based threshold of 50 tonnes of CBAM goods per importer per calendar year. Below this threshold, the obligations to report and submit CBAM certificates no longer apply. This affects all importers based in the EU who import emission-intensive goods such as iron, steel, cement, aluminium, electricity, fertilisers, hydrogen and certain upstream and downstream products in pure or processed form from non-EU countries.