New rules of CBAM — expert article in Rzeczpospolita

Key changes and simplifications introduced by Regulation (EU) 2025/2083 include, but are not limited to:

• new de minimis threshold — exemption for importers importing less than 50 tonnes of goods (excluding electricity and hydrogen),
• greater flexibility in reporting emissions and calculation of embedded emissions
• year 2026 without obligation to purchase certificates — first purchases from 1 February 2027,
• postponement of the deadlines for submission of annual declarations and repurchases of certificates,
• the possibility of entrusting the obligation to submit declarations to a third party.

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During the target period, importers will have to:

• obtain the status of authorised notifier,
• submit annual CBAM declarations,
• ensure verification of emissions by accredited verifiers or use default values,
• purchase and redeem the appropriate number of certificates.

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In Poland, the status of authorised declarant is not yet available, but an application submitted by 31 March 2026 allows imports to continue temporarily. This is the right time to prepare the company for new responsibilities. If you need support in the field of CBAM, data analysis or reporting strategy — contact us!