Significant simplifications to the EU’s Carbon Border Adjustment Mechanism (CBAM) were approved by the European Parliament on 10 September 2025 under the legislative package known as Omnibus I. These changes primarily benefit small and medium-sized enterprises (SMEs) and importers of limited quantities of CBAM-covered goods.

As the transitional phase of the CBAM ends on 31 December 2025, affected businesses must begin preparing for the full implementation phase starting in 2026. From that point forward, CBAM obligations will extend beyond reporting and will include actual financial liabilities. The first and most critical step in preparation is obtaining the authorised CBAM declarant status, which has been available for application in Hungary since 1 September via the National Climate Protection Authority’s official website.

What are the key changes?

De minimis exemption introduced

Under the new rules, importers bringing less than 50 tonnes per year of CBAM-covered goods into the EU will be exempt from CBAM obligations.

This uniform weight-based threshold applies across the iron, steel, cement, aluminium, and fertiliser sectors. However, imports of electricity and hydrogen remain excluded from this exemption. This rule will relieve approximately 90% of importers, predominantly small and medium-sized enterprises, while maintaining coverage of 99% of emissions from the targeted goods.

If an importer exceeds the annual threshold, all goods imported during the year become subject to full CBAM obligations, including:

• Obtaining authorised CBAM declarant status: applications submitted by 31 March 2026 will be eligible for transitional relief, allowing continued imports until the permit is granted. Applications in Hungary opened on 1 September and can also be submitted electronically via the ePaper platform. The European Commission will review the appropriateness of the threshold annually, and national customs authorities can suspend further imports if the threshold is breached without proper authorisation.

• Annual CBAM declaration and certificate surrender: declarants must submit their annual CBAM report and surrender certificates by 30 September each year, covering the previous year’s emissions. The first deadline is 30 September 2027, with CBAM certificate trading also starting in 2027.

The main challenge for importers remains the acquisition of embedded emissions data from non-EU manufacturers. In Hungary, these difficulties may be reported to the National Climate Protection Authority as part of the excuse mechanism (derogation).

Simplified administrative CBAM obligations

In addition to the de minimis threshold, the Omnibus I package introduces several streamlining measures, including streamlining the authorisation process, clarifying emissions calculation rules and reducing certificate purchase requirements.

Under current CBAM rules, importers must purchase CBAM certificates for at least 80% of embedded emissions in each quarter. The amendment reduces this obligation to 50%, thereby easing initial financial and administrative burdens for businesses.

Status and next steps

The Omnibus I regulation introducing the de minimis threshold has not yet entered into force. Following approval by the European Parliament, it now awaits formal adoption by the Council.

In Hungary, entities expecting to exceed the 50-tonne threshold, or those importing electricity or hydrogen, can now apply for authorised CBAM declarant status. During the transitional period, quarterly data reporting requirements remain in force.

These reforms offer significant relief for smaller market players, while also simplifying compliance for larger importers. However, the upcoming full implementation phase of CBAM will bring increased regulatory pressure in line with the EU’s climate targets. Timely preparation is essential. For expert support with CBAM compliance, reach out to the tax advisers at WTS Klient Hungary.

This article provides general information and does not constitute advice.