The Omnibus I Package: Simplifying the Carbon Border Adjustment Mechanism (CBAM)

In June 2025, the European Commission’s (EC’s) proposal for simplified CBAM measures – the Omnibus I package – was provisionally accepted by the European Parliament. The package will now move for formal endorsement, which is expected later this year. 

Under the proposed amendments, approximately 90% of companies will benefit from exemptions whilst 99% of imported emissions will be accounted for. 

In this article, we explain the key changes within the Omnibus I package and how to keep the disruption of CBAM to a minimum. 

CBAM – a Recap 

The Carbon Border Adjustment Mechanism was introduced to offset the carbon leakage in imported goods being placed on the EU market, aiming to equalise the cost of carbon paid for EU-originating products under the Emissions Trading System (ETS).  

The mechanism is currently in its transition phase, which began in October 2023 and is due to end on the 31st of December 2025. During this period, there is no financial obligation – only the requirement to submit a quarterly CBAM report. 

The initial scope of CBAM applies to the import of: 

• Cement 

• Articles of iron and steel 

• Fertiliser 

• Articles of aluminium 

• Electricity 

• Hydrogen 

Once the mechanism is fully operational in 2026, companies importing these products will be expected to purchase CBAM certificates to offset the embedded carbon. The European Commission will also assess the scope of CBAM in 2026, potentially expanding the commodities list to include more ETS products. 

Over the course of the transition period, the EC has assessed the data from CBAM reports. On review, they have concluded that approximately 10% of companies account for over 99% of emissions. They also received feedback from traders that CBAM measures were overcomplicated, adding significant administrative burden to supply chains. 

Acting on these insights, the EC proposed a simplification to the mechanism with the Omnibus I amendment package. 

The Key Changes for CBAM Companies Following the Omnibus I Amendment

After the official endorsement and adoption of Omnibus I, a new de minimis threshold of 50 tonnes per annum will be introduced, replacing the previous EUR 150 threshold and eliminating the need for CBAM certificates for 90% of companies. 

For those who are still eligible for CBAM measures, there will be: 

• An easier process for registering as a CBAM declarant 

• Simplified valuation methods for embedded emissions 

• Streamlined reporting and verification standards 

• Better recognition for carbon prices already paid in non-EU countries.

The Questions Which Remain Unanswered 

Although the Omnibus I package provides a welcome simplification for traders of CBAM products, the industry is waiting on some key clarifications in the official publication, which is anticipated to be in September. 

For example: 

• Will the 50-tonne threshold be retroactive, or will it only come into effect when the mechanism becomes live in 2026? 

• Will traders still be required to become CBAM-authorised declarants even if they don’t meet the threshold? 

• Will the threshold include all customs regimes, or only apply at the time when the goods are released into free circulation under a 40 customs procedure code (CPC)? 

Once further details are revealed, we will update this article accordingly. 

Save Time, Money and Hassle by Partnering with CSG for Your CBAM Compliance 

Working with you from procurement to audit, CSG helps you to be proactive, efficient, and compliant throughout the entire CBAM process. 

You can rely on us for help with: 

• CBAM Classification: Gain clarity on your obligations and how your country of origin affects them. 

• Due Diligence: Safeguard your supply chain with thorough checks on data and working processes. 

• Digital solutions: Reduce the risk of error and save money with intelligent automation. 

• CBAM Reporting: Avoid common CBAM reporting issues with the help of our trusted experts. 

• EU-Wide Support: Consolidate your EU customs through a single contact, without losing local quality. 

If you need help with streamlining your CBAM processing or understanding what the Omnibus I package means for your business, contact us for more information.