The EU Carbon Border Adjustment Mechanism (CBAM) includes a mass-based de minimis threshold introduced under the 2025 simplification. Electricity imports, however, cannot be handled using the same tonne-based exemption logic applied to some other covered goods. As a result, smaller trading positions and occasional power imports still fall under the definitive regime’s authorisation, customs, emissions and certificate controls.
De minimis threshold does not remove electricity compliance
The distinction is relevant for traders and occasional importers that may 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 apply the rules tied to each customs flow.
A single threshold-based approach across different goods can create compliance gaps when electricity is treated differently from other covered products. Even small electricity trading positions can involve carbon exposure per megawatt-hour (MWh) when default-emissions factors and certificate prices are significant. Compliance risk controls therefore need to reflect regulatory obligations tied to emissions and certificates rather than relying only on traded volume.
CBAM certificate payments follow a defined timetable
The timing of CBAM payments can reduce visibility during the initial period, but it does not remove the underlying obligations. 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 are expected to connect import records and emissions calculations with purchasing schedules, cash-flow forecasts and certificate positions.
For smaller operators, establishing controls that match business scale while maintaining compliance is a key operational requirement. Efficient data collection, clear responsibility for reporting, and timely reconciliation of import volumes are identified as measures that can limit administrative costs while keeping potential liabilities visible.
COM(2025) 989 proposes changes to CBAM 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 changes to some conditions for using actual emissions. It also addresses broader recognition of physical power purchase agreements (PPAs) involving intermediaries and adjustments related to congestion and nomination requirements.
The Council adopted its negotiating position on 12 June 2026, while the European Parliament adopted its position on 15 September 2026. The proposal remains under interinstitutional negotiation and has not been enacted legislation. The same file also proposes expanding downstream coverage 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 continues as 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 systems must accommodate regulatory reform
Regulatory reform can affect the value of existing compliance investments and commercial agreements. Contracts are expected to specify how any 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 identified as tools to respond to future changes without embedding proposed benefits prematurely into prices.
Current-law controls are expected to remain in force until adopted rules change applicable requirements. The decision rule described for policy-sensitive investments is to preserve flexibility for reform while maintaining compliance with rules currently in force. For electricity, a small position is described as not functioning as an exemption, but rather as a driver for an efficient compliance architecture that can operate economically at smaller margins.