The EU Carbon Border Adjustment Mechanism includes a mass-based de minimis threshold introduced under the 2025 simplification. However, electricity imports cannot be handled using the same tonne-based exemption logic applied to other covered goods. Smaller trading positions and occasional power imports therefore continue to require authorisation, customs processing, emissions controls and certificate requirements under the definitive regime.
De minimis threshold does not remove electricity coverage
The distinction is relevant for smaller traders and occasional importers that may assume limited electricity volumes fall outside CBAM. Electricity is covered under its own customs classification, and the mass-based exemption does not exclude electricity imports from the mechanism. As a result, compliance obligations apply even when electricity flows are limited in scale.
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. Using a single threshold-based approach across different goods can create compliance gaps. Each product stream therefore needs separate consideration for CBAM treatment.
Even a small electricity trading book can involve material carbon exposure per megawatt-hour (MWh). This exposure depends on the applicable default-emissions factor and the certificate price. Risk controls are therefore expected to reflect regulatory obligations and economic exposure rather than relying only on traded volume.
CBAM certificate payments and reporting timelines for 2026 imports
The timetable for CBAM payments can reduce visibility of obligations during the initial period, while obligations remain in place. For 2026 imports, certificate sales are scheduled to begin on 1 February 2027. The first annual CBAM declaration and the certificate-surrender deadline are 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 is part of maintaining compliance. Efficient data collection, clear responsibility for reporting and timely reconciliation of import volumes are cited as measures that can limit administrative costs while preserving visibility over potential liabilities.
COM(2025) 989 proposes changes to electricity treatment
A separate legislative initiative, COM(2025) 989, proposes substantial changes to how electricity is treated under CBAM. The proposal includes a revised methodology for electricity default-emissions values. It also covers changes to conditions for using actual emissions and broader recognition of physical power purchase agreements (PPAs) involving intermediaries.
The initiative further addresses adjustments to congestion and nomination requirements for electricity treatment under CBAM. 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 is not enacted legislation.
The same legislative file proposes 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 continues as the compliance baseline.
Implications for procurement systems and contract planning
Manufacturers planning capital expenditure for 2027–2028 can use the proposed product lists as scenarios when designing procurement arrangements and emissions-data systems. Investment decisions should preserve flexibility if final coverage or the electricity methodology differs from what is proposed. This approach is intended to avoid locking in assumptions that may change during negotiation.
Regulatory reform can also 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 updating. For electricity procurement, modular contract schedules and adaptable calculation systems are cited as tools for responding to future changes.
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 not treated as an exemption; it is presented as a reason to make the compliance architecture efficient enough to operate economically at a smaller margin.