The omnibus package proposed on 26 February 2025 is a legislation aimed at simplifying reporting and lessening administrative burdens for companies reporting on e.g. CBAM. In the omnibus package, the de minimis requirement for being subjected to CBAM reporting has changed to a de minimis mass threshold of 50 tonne annual imports across sectors (2025/0039 (COD), 2025). This is expected to exclude 90% of companies from reporting and paying for their imported embedded emissions. The regulation is expected to still capture 99% of imported embedded emissions within iron and steel, aluminium, cement and fertilizers. Hydrogen and electricity are not included in the mass threshold. (European Commission, 2025)
The reduction in CBAM’s scope has the potential to significantly change the impact of CBAM in Europe and in the Nordics. Other than increasing the import threshold to exclude 90% of importing companies, the Omnibus also aims to simplify the reporting burden by delaying reporting deadlines (Article 1(4)), allowing reporting on default emission factors (Article 1(7)), and by delaying the phase-put of free allowances to 2027(Article 1(14)). The simplification has the possibility to significantly decrease the administrative burden, while capturing almost the same level of tariffs on importers.
Other uncertainty factors include the potential treatment of exports outside the EU market. Some industries have argued for export rebates to compensate for higher production costs resulting from the EU ETS and CBAM when competing in global markets. However, there is currently no agreed EU-level legislation providing for such export rebates, and their introduction would raise significant concerns regarding compatibility with WTO regulations. As a result, export rebates remain an uncertain and contested policy option rather than an established element of the CBAM framework.
Other uncertainties for 3rd countries: Will the CBAM tariffs be used to fund development in 3rd countries.
9.1 Impact of the Omnibus package
As part of the Omnibus package, the regulation 2025/2083 of 8th of October amending Regulation (EU) 2023/956 as regards simplifying and strengthening the carbon border adjustment mechanism amends the original CBAM regulation, aiming to simplify and strengthen the regulation. The regulation is expected to still capture 99% of emissions from imports, while exempting 90% of importers from reporting requirements. These estimates are provided at the EU aggregate level, and the regulation does not specify corresponding country-level impacts. As a result, while CBAM’s overall environmental and economic incentives are expected to remain largely unchanged at the EU level, the effects in individual Member States, including Finland, Sweden and Denmark, may differ depending on national import structures and the concentration of large importers. On this basis, CBAM’s impact on Nordic producers is not expected to change materially in aggregate terms, but the precise distributional effects of the Omnibus package at national level cannot be quantified based on the available information.
Importers that are covered by CBAM, will still be faced with increased prices on imports from third countries. The companies that are not exempt in the Omnibus, will naturally be larger companies, with a higher revenue, or a more direct focus on import of CBAM-covered goods. Although the administrative burden on the non-exempt companies will be significant, it is expected that they will have more resources to allocate to the reporting.
The results of this report are expected to largely remain relevant with the implementation of the CBAM Omnibus. Due to the changes in requirements in the CBAM, some of the conclusions drawn in the report might change. In Table 3 is an overview of expected effects of the Omnibus, divided by section of the report.