The Omnibus proposal amends Regulation (EU) 2023/956, which establishes the Carbon Border Adjustment Mechanism (CBAM), to simplify reporting and ease compliance burdens. The regulation was introduced to prevent carbon leakage and ensure that imports bear the same carbon costs as domestic production. While these modifications promise efficiency, they may undermine CBAM’s core environmental goals and weaken its effectiveness in driving global emissions reductions.

The Omnibus proposal is not yet enforceable because it still requires consideration and adoption by the European Parliament and the Council. It will only enter into force once an agreement is reached and it is published in the EU Official Journal.  

These are the main points currently in discussion and some possible associated risks for fulfilling climate objectives set in the EU Green Deal: 

Simplified reporting requirements

  1. The revised framework reduces complexity in the calculation of embedded emissions by allowing importers to rely on Commission-provided data (default values) when actual values are difficult to retrieve or unavailable, eliminating the need for detailed calculations.
  2. Introducing the option to delegate reporting to third parties: Authorized CBAM declarants can outsource reporting. However, importers remain legally responsible for the provided information.

⚠️ Risk: The lack of detailed, verified emissions tracking makes it easier for high-emission imports to slip through („evade” reporting obligations), reducing CBAM’s effectiveness in reflecting true carbon costs.

Exemptions for small importers

  1. New mass-based threshold: Importers handling less than 50 tonnes per year are now exempt.
  2. Despite the new exemptions impacting  90% of the estimated importers, approximately 99% of the embedded emissions will still fall under CBAM.

⚠️ Risk: While 99% of emissions remain under CBAM’s scope, the exemption sets a dangerous precedent - importers might split shipments across multiple entities to remain below the threshold. 

Enhanced emissions monitoring and enforcement

  1. Expanded CBAM registry: New registration requirements to be incorporated for foreign operators and installations, to ensure proper tracking of emissions. 
  2. Carbon price adjustments: Authorized CBAM declarants can claim deductions for carbon prices paid in third countries, not just the country of origin. 
  3. Stronger anti-circumvention rules: New measures prevent importers from splitting shipments to evade compliance. 

⚠️ Risk: This could weaken the „polluter pays” principle, allowing industries to manipulate their carbon cost obligations.

Streamlined carbon pricing and financial adjustments

  1. Delayed certificate sales: CBAM certificates will be sold starting February 2027 for emissions embedded in 2026 imports, thus shifting the starting date in around 1 year.
  2. Quarterly ETS pricing alignment: Certificate prices in 2027 will reflect the average ETS prices from the last quarter of 2026.
  3. Lower certificate-holding requirements: The quarterly requirement drops from 80% to 50% of imported emissions.
    This change aims to prevent double counting of carbon costs and reduce financial burdens on importers. For example, under the current 80% rule, an importer needs to purchase “upfront” (for the year) a quantity of certificates that represent an equivalent of the 80% of the total embedded emissions associated to its projected imports. These certificates will need to be purchased at the full CBAM price, requiring a significant financial commitment. In addition, if not all are used, a proportion of these certificates are not refunded, and their value will be lost (financial loss for importers). Now, by reducing the requirement to 50%, importers only need to purchase certificates enough to cover the half of their projected imported (embedded) emissions, thereby lowering the upfront costs. In addition, the risk of financial losses is eliminated, because the current Omnibus proposal ensures that all “upfront” certificates can be refunded (sold) if not used.

⚠️ Risk: Delaying the full rollout weakens CBAM’s ability to drive emissions reductions now, when urgent climate action is needed.

Sector-specific emission adjustments

  1. Aluminium and steel sectors: Emissions related to minor finishing processes that are part of the manufacturing chain of aluminium and steel products under CBAM scope may  now be excluded from the calculation of the total embedded emission. 
  2. Precursor material exemptions: If the input materials are already subject to the EU ETS or to another (liked) carbon pricing scheme, they may be excluded from the calculation of embedded emissions under CBAM.
  3. Electricity emissions: Only direct emissions count towards embedded emissions calculations. 

⚠️ Risk: The changes narrow the scope of emissions considered in certain industries (especially true for the exclusion of indirect emissions like to electricity). Excluding these emissions could distort the carbon price signal, making carbon-intensive industries appear cleaner than they actually are. 

Overall impact
While the revisions to the Omnibus proposal aim to make it more business-friendly, they also introduce uncertainty that could stall the implementation of expected changes. This uncertainty may lead to hesitation among businesses, delaying necessary transitions. In the case of CBAM, these revisions risk creating loopholes that could weaken its impact. If the EU is truly committed to climate neutrality, CBAM must remain a strong, enforceable tool - not just a bureaucratic formality.
What needs to happen? 

What needs to happen? 

  • Ensure stronger monitoring to prevent abuse of exemptions and carbon price adjustments. 
  • Push for the inclusion of all emissions (both direct and indirect) in CBAM calculations. 
  • Avoid the delay of the implementation of the full CBAM mechanism .

Without these safeguards, CBAM could become a watered-down mechanism that looks good on paper but fails to drive real emissions reductions. The EU has set ambitious climate goals—now it must ensure that CBAM delivers on its promises. 

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