The EU Carbon Border Adjustment Mechanism (CBAM) includes a mass-based de minimis threshold introduced under the 2025 simplification. However, electricity imports are not handled through the same tonne-based exemption approach used for other covered goods. As a result, smaller trading positions and occasional power imports remain subject to authorisation, customs requirements, emissions obligations and certificate controls under the definitive regime.
Electricity flows remain covered even at low volumes
The compliance distinction affects smaller traders and occasional importers that might expect limited electricity volumes to fall outside CBAM. Electricity is covered under its own customs classification, and the mass-based exemption does not remove electricity imports from the mechanism. Industrial groups importing modest quantities of electricity alongside steel or aluminium goods are expected to assess each customs flow under the rules applicable to that product.
A single threshold-based approach across different goods can create compliance gaps when electricity is treated differently from other covered categories. Even a small electricity trading book can involve material carbon exposure per megawatt-hour (MWh) if the applicable default-emissions factor and certificate price are significant. Risk controls therefore need to reflect regulatory obligations and economic exposure rather than relying only on traded volume.
CBAM certificate payments follow scheduled deadlines
The timing of CBAM payments can reduce visibility of obligations during the initial period, but it does not remove them. For 2026 imports, certificate sales are scheduled to begin on 1 February 2027. The first annual CBAM declaration and certificate-surrender deadline is set for 30 September 2027.
From 2027, the general certificate-pricing framework shifts to weekly auction-price averaging. Quarterly certificate-holding requirements become part of the treasury cycle. Importers and traders need processes that link import records and emissions calculations with purchasing schedules, cash-flow forecasts and certificate positions.
Smaller operators face the task of setting up controls that match business scale while maintaining compliance. The source material highlights efficient data collection, clear responsibility for reporting, and timely reconciliation of import volumes as measures that can limit administrative costs while keeping potential liabilities visible.
COM(2025) 989 proposes changes to electricity treatment
A separate legislative initiative, COM(2025) 989, proposes changes to how electricity is treated under CBAM. The proposal includes a revised methodology for electricity default-emissions values and adjustments to some conditions for using actual emissions. It also covers broader recognition of physical power purchase agreements involving intermediaries, along with changes to congestion and nomination requirements.
The Council adopted its negotiating position on 12 June 2026, and the European Parliament adopted its position on 15 September 2026. The proposal remains under interinstitutional negotiation and is not presented as enacted legislation. The same file also proposes a downstream expansion from 2028 to selected steel- and aluminium-intensive goods.
Both institutions support extending coverage, but their product lists differ and remain subject to negotiation. Until final legislation is adopted, the current scope remains the compliance baseline. Manufacturers planning capital expenditure for 2027–2028 can use the proposed product lists as scenarios for procurement arrangements and emissions-data systems while preserving flexibility if final coverage or electricity methodology changes.
Contracts and calculation systems must allow for regulatory updates
Regulatory reform may affect the value of existing compliance investments and commercial agreements. Contracts should specify how savings from simplified requirements would be allocated and how reasonable transition costs would be handled if systems, reporting processes or agreements need adjustment. For electricity procurement, modular contract schedules and adaptable calculation systems are highlighted as tools to respond to future changes without embedding proposed benefits prematurely into prices.
The source material indicates that current-law controls should remain in force until adopted rules change applicable requirements. It also states that policy-sensitive investment decisions should preserve flexibility for reform while maintaining compliance with rules currently in force. For electricity specifically, a small position is described as not an exemption, including for building an efficient compliance architecture that can operate economically at a smaller margin.