CBAM Adjustments 2026 – Changes to the Carbon Border Adjustment Mechanism are pending

Relaxations are crucial for the CBAM reform to make the CO₂ border adjustment more practical. A SME-friendly implementation and further development are crucial to ensure that European companies are not disadvantaged in global competition.

The CBAM aims to prevent CO₂-intensive production from being relocated from the EU to countries with lower environmental standards (Carbon Leakage). A transitional phase has been in force since October 1, 2023 – the mechanism will take full effect by 2026. The German Chamber of Commerce and Industry (DIHK) has clearly stated in the paper "CBAM Adjustments 2025 – Proposals from the Economy" what is essential from the industry's point of view to ensure CBAM does not lead to competitive or burden disadvantages.

Making CBAM practical

The CBAM encounters conceptual limits while protecting against carbon leakage. Although a CO₂ border adjustment is fundamentally understandable, the mechanism burdens both imports and domestic production – particularly when export markets or downstream products are affected.

From the perspective of the DIHK, the mechanism must therefore be designed so that European manufacturers are not disadvantaged by CBAM – for example, through disadvantages compared to non-subject competitors from third countries. Only a competitively neutral "Level Playing Field" secures industry and jobs in the long term. In addition, the DIHK warns of possible trade policy countermeasures if CBAM is perceived as a protectionist instrument.

Relaxations are pending

The adjustments proposed by the EU Commission contain many correct elements from DIHK's point of view:

The introduction of an annual de minimis threshold of 50 tonnes for imports under CBAM – this significantly relieves many companies.
The return to the option of using standard values for emissions calculations – important when concrete supplier data is missing.
The design of verification obligations and reporting processes that are SME-friendly and practical – only in this way can CBAM be sustainably implemented in SME structures.

These steps could significantly de-bureaucratize CBAM and provide many companies with planning security – a decisive advantage for energy-intensive imports and the entire value chain.

Strengthening planning security

According to DIHK, the previous speed and brevity of consultations are problematic: Many companies cannot reliably estimate their calculations for 2026 – be it in terms of standard values or benchmarks.

Therefore, DIHK calls for early and transparent involvement of the economy in the development of legislation and implementing regulations. Only in this way can companies prepare in time and plan investments – instead of being confronted with short-term uncertainties.