The CBAM is designed to prevent Europe's climate policy ambitions from being undermined by cheaper imports from less regulated markets. However, the reality for many businesses is quite different: instead of effective climate protection, they face growing bureaucratic burdens, rising costs, and significant legal uncertainty. Small and medium-sized enterprises (SMEs) in particular, lacking their own compliance departments, are reaching their structural limits. The DIHK has therefore formulated specific demands addressed to the German government and the European Commission, stressing a critical point: without fundamental improvements, Europe's industrial base faces a risk of permanent competitive disadvantage.
Background: What is the CBAM, and where does it stand today?
The CBAM was introduced by Regulation (EU) 2023/956 of the European Parliament and Council, and has been fully enforced since 1 January 2026. Importers of cement, steel, iron, aluminium, fertilisers, electricity, and hydrogen must, as of 2026, purchase certificates for CBAM goods, with prices aligned to the EU Emissions Trading System (ETS). Previously, a transitional phase with pure reporting obligations was in place from October 2023 onwards.
In February 2025, the EU Commission proposed simplifications under the so-called Omnibus Package I (COM(2025)87), which came into force in October 2025. The core of this reform is a quantity threshold: companies importing less than 50 tonnes of CBAM-covered goods per year are exempt from CBAM obligations, effectively removing around 90 per cent of affected importers from the regulation. Despite these facilitative measures, the DIHK identifies several issues in its position paper that render the system, in its current form, largely unworkable in practice.
The Key Points at a Glance
- Excessive default values:
The standard values published in December 2025, particularly for imports from China and Indonesia, significantly exceed previous reference values – with severe cost implications for companies unable to change their supply sources in the short term. - Lack of an export solution:
Goods produced in the EU and subjected to a CO₂ price are not relieved in exports. This severely disadvantages European manufacturers in global price competition. - Shortage of certifiers:
There are foreseeable insufficient accredited certification bodies available for the mandatory certification of around 40,000 production facilities, forcing companies to resort to unfavourable default values. - Deadlines too short and unclear rules:
Regulations are passed at short notice, consultations are conducted too late, and fundamental legal issues remain unresolved – such as those concerning processing trade, return shipments, or reusable packaging. - Structural overload for small and medium-sized enterprises:
Companies without specialised compliance teams and IT resources are overwhelmed by the system in its current state – despite the 50-tonne threshold.
The DIHK’s demands on policymakers
Download
The complete paper can be downloaded here:
- Publication
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DIHK impulse paper: CBAM Challenges 2026
- Summary
- Companies in Germany are currently facing massive challenges regarding the implementation of the CO2 Border Adjustment Mechanism (CBAM). The German Chamber of Commerce and Industry (DIHK) lists the issues that the Federal Government and the EU Commission must immediately address and outlines the steps to be taken.
- Information
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File format: PDF (accessible)
File size: 610 KB
Status of: June 2026
Page count: 9 pages
- Relevant in topic:
- International Trade and Market Access
- Key areas:
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- Climate
Released 29.06.2026
Contact
Klemens Kober
Director Trade Policy, EU Customs, Transatlantic Relations