1. New single threshold of 50 tonnes and de minimis exemption:

One of the most significant changes is the creation of a single threshold based on net imported mass. Companies that import less than 50 tonnes per year of products covered by the CBAM into the European Union will be exempt from its obligations. This limit will apply to sectors such as steel, aluminium, fertilisers and cement, but will not affect imports of hydrogen or electricity.

The aim is to reduce the administrative burden for operators with low volumes, especially SMEs, without compromising the environmental coverage of the mechanism.

The threshold will apply from 1 January 2026.

2. Obligation to be a CBAM authorised declarant:

Only authorised declarants — importers or indirect customs representatives — may bring goods subject to the mechanism into the EU. This authorisation becomes a requirement from 1 January 2026.

Temporary exception: If the authorisation application is submitted before 31 March 2026, the importer may continue to operate provisionally until the competent authority has made a decision.

3. New emissions calculation system:

From 2026 onwards:

• Implicit emissions shall be calculated using default values published by the Commission or using actual values verified by accredited verifiers.
• Verification shall only be mandatory when actual values are used.

4. Annual CBAM declarations:

CBAM declarations must be submitted:

• Before 30 September each year
• For the first time in 2027, with regard to imports in 2026

A specific module will be enabled in the CBAM Registry and delegation to third parties will be permitted.

5. Purchase of CBAM certificates:

• The quarterly obligation to hold CBAM certificates is reduced:
• From 80% to 50% of cumulative embedded emissions since the beginning of the year.

6. Additional regulatory impact:

Regulation (EU) 2025/2083 entails the amendment of:

• Implementing Regulation (EU) 2025/486
• Implementing Regulation (EU) 2024/3210

The Commission expects to complete these adjustments in the coming months.

• New formal obligations: need to be an authorised declarant and submit annual declarations.
• CBAM certificate management, albeit with a reduced quarterly burden.
• Lower administrative burden for low-volume importers thanks to the 50-tonne threshold.
• Greater legal certainty in the calculation of emissions using default values.
• Incentives for global decarbonisation, by maintaining consistency with the European Emissions Trading Scheme (ETS).

1. Protection against misleading practices that make it difficult for consumers to make environmentally responsible purchasing decisions, such as:
   • Misleading environmental or social claims about products (e.g., ‘eco-friendly’ without objective backing).
   • Unclear or difficult to verify information on characteristics such as repairability, durability or recyclability.
   • Ambiguous comparisons between products that may be misleading.
2. Improvement of the pre-contractual information that companies must provide before purchase, especially in relation to:
   • the availability of more sustainable delivery options,
   • information on repair and after-sales services,
   • details of durability guarantees or the conditions for software updates on digital goods.

• Transposition deadline:

Member States must transpose the content of the Directive into their national legislation by 27 March 2026.

In Spain, this process has already begun with the drafting of the Preliminary Bill on Sustainable Consumption, which will serve as a regulatory instrument to adapt Spanish law to new European requirements on environmental information, combating greenwashing and protecting consumers.

• Effective application:

The rules may be applied from 27 September 2026, the date on which penalties or contract exclusions may be imposed for failure to comply with the obligations arising from the Directive.

This timetable is key for companies to prepare in advance and adapt their communication, labelling and environmental information management processes. ental.  

• Ensure that all environmental or social statements are clear, verifiable and reliable.
• Avoid ambiguous or unsubstantiated claims that could mislead consumers (greenwashing).
• Provide detailed and accessible information on relevant characteristics of the product or service — including aspects of circularity and sustainability — prior to purchase.
• Facilitate objective comparisons between products when environmental data is included.
• Include information on repair, durability, availability of parts and after-sales services, where applicable.

• Environment: waste management, emission control, dumping, energy efficiency and pollution prevention.
• Occupational health and safety: safe working conditions, occupational risk prevention and staff welfare.
• Quality: compliance with management standards such as ISO 9001 or sector-specific standards to ensure excellence of products and services.
• Data protection: compliance with the General Data Protection Regulation (GDPR) and other privacy regulations.
• Industrial safety: technical supervision of facilities, machinery, processes and compliance with sector-specific regulations.
• Food legislation: compliance with health and hygiene requirements, traceability, labelling and food safety regulations applicable to the entire agri-food chain.

• Rail and aviation: compliance with state regulations on operational safety, maintenance and infrastructure management.
• Construction: adaptation to legal requirements on structural safety, sustainability and working conditions on site.
• Electricity and hydrocarbons: compliance with technical and safety regulations relating to energy installations, supply and transport.
• Tourism: compliance with specific regulations on safety, accessibility, sustainability and quality in the provision of tourism services.

• Regulatory identification: analyse which laws and regulations apply to the specific business activity.
• Legal impact assessment: understanding how these regulations affect internal processes.
• Implementation of corrective measures: adapt operations, procedures and human resources.
• Regular auditing and monitoring: review the degree of compliance and prevent deviations.
• Continuous updating: anticipate legislative changes that may affect the sector.

• Personalised identification of the legal requirements applicable to your activity.
• Clear and schematic extraction of what each regulation requires: EcoGestor tells you, directly, exactly what your company must do to comply with each specific regulation, without ambiguities or unnecessary technicalities.
• Centralised management of tasks, people in charge, key dates and documentation.
• Real-time alerts and updates on legislative changes affecting your business.
• Comprehensive coverage in areas such as environment, occupational safety, quality, data protection and industrial safety.

• Contractor Management (Coordination of Business Activities)
• CMMS (Computer Aided Maintenance Management)
• PPE (Personal Protective Equipment Management)
• Waste (Control of waste generated and its traceability)

• Keep legislation applicable to their business up to date..
• Receive automatic notifications of legislative changes.
• Manage corrective actions with full traceability.
• Prepare confidently for external checks and audits.